Replaces the 2006 e-commerce law: electronic documents, signatures and seals cannot be denied legal effect merely because they are electronic; trust service providers must be licensed by TDRA, with an additional qualified status for qualified electronic signatures and seals; and the Cabinet may bring transactions or documents into or out of the law's scope.
Federal Decree-Law No. 46 of 2021 gives electronic documents, signatures and seals the same standing as paper and ink, and licenses the providers who supply the trust-service activities behind them. It repealed Federal Law No. 1 of 2006 on Electronic Commerce and Transactions (Article 53) and has been in force since 2 January 2022 (Article 54). It remains in force; its executive regulations are issued by the Cabinet on the proposal of the TDRA chairman (Article 52), and the related penalties were set by Cabinet Resolution No. 52 of 2024.
Article 2 applies the law to anyone who adopts electronic transactions and trust-service activities and to the transactions, documents and procedures themselves, with Cabinet power to add, remove or exclude any transaction, document, service, procedure or entity; the text itself lists no excluded documents.
The core rule is Article 5: an electronic document does not lose its legal force or enforceability for being in electronic form, though no one can be compelled to use electronic means without consent, which may be inferred from conduct. Articles 6 to 9 then say that electronic records satisfy legal requirements for retention, writing, signature and originals, provided the information remains accessible and its integrity can be shown. Articles 10 and 11 allow contracts to be formed by electronic offer and acceptance and between automated systems, and Articles 12 to 14 fix attribution, acknowledgement and the time and place of sending and receipt.
Article 18 governs evidential weight. Electronic evidence may not be rejected merely because it is electronic; a reliable electronic signature or seal is valid and legally effective if it meets the law's conditions, and a qualified electronic signature is equal in authenticity to a manual signature. Article 19 sets the reliability test (sole control of the signatory, identification, detection of later alteration, compliance with the technical standards of the executive regulations) and Articles 20 and 21 the stricter conditions for a qualified signature: a valid qualified certificate, a qualified creation device and validation through a qualified service.
Trust-service activities may be carried on only under a TDRA licence, and qualified ones need a licence plus qualified status (Article 15). Article 17 lists the services: creating electronic signatures and seals and issuing their certificates, and for the qualified tier certificate issuance, devices, remote management, data storage, validation, qualified time stamps and qualified electronic delivery. TDRA keeps a UAE Trust List and may suspend or cancel licences (Articles 4 and 16); comparable foreign qualified services are recognised (Article 37); providers bear civil liability for breach (Article 38).
Articles 39 to 45 add criminal penalties for forging electronic documents, unlawful use, improper certificates, breach of confidentiality and providing trust-service activities without a licence, with fines from AED 20,000 to AED 1,000,000 and imprisonment.
Any person who adopts electronic transactions and trust-service activities in the UAE and the electronic transactions, documents, procedures and services concerned, including companies that sign resolutions, contracts and bank forms electronically; trust service providers, which must be licensed by TDRA; and government entities offering e-services. The Cabinet may exclude transactions, documents or entities.
| Article 2 | Applies the law to anyone adopting electronic transactions and trust-service activities and to the transactions, documents and procedures themselves; the Cabinet may add, delete or exclude any transaction, document, service, procedure or entity. |
| Article 5 | An electronic document does not lose its legal force or enforceability because it is in electronic form, but no person is obliged to use electronic means without consent, which may be inferred from conduct. |
| Articles 6–9 | Electronic records satisfy legal requirements for retention, writing, signature and originals where the information stays accessible and usable and its integrity can be technically established. |
| Articles 10–11 | Contracts may be concluded by electronic offer and acceptance, and between automated electronic systems without direct human intervention. |
| Article 15 | No person may provide trust-service activities without a licence from TDRA, and qualified trust-service activities require in addition qualified status; the executive regulations set the licensing conditions and standards. |
| Article 17 | The licensed activities are the creation of electronic signatures and seals and the issuance of their certificates; qualified trust-service activities add qualified signature and seal creation, devices, remote management, data storage, validation, qualified time stamps and qualified electronic delivery. |
| Article 18 | Electronic evidence may not be excluded because it is electronic; a reliable electronic signature or seal is valid and legally effective if the statutory conditions are met, and a qualified electronic signature is equal in authenticity to a manual signature. |
| Article 19 | A reliable electronic signature or seal must be under the signatory's exclusive control, identify the signatory, reveal any later alteration of the signed data and be created to the technical standards in the executive regulations. |
| Articles 20–21 | A qualified electronic signature requires a valid qualified certificate, a qualified creation device that protects and single-uses the creation data, correct identification of the signatory and validation through a qualified service. |
| Article 37 | Qualified trust-service activities provided from outside the UAE are recognised where they are comparable to those provided under the Decree-Law and TDRA decisions. |
| Articles 39–45 | Criminal penalties: forgery of electronic documents AED 100,000 to AED 300,000 (AED 150,000 to AED 750,000 for government documents); unlawful use AED 100,000 to AED 1,000,000; false certificate data AED 20,000 to AED 100,000; unlicensed trust-service activities AED 500,000 to AED 1,000,000, each with imprisonment. |
| Articles 53–54 | Repeals Federal Law No. 1 of 2006 and conflicting provisions; the Decree-Law entered into force on 2 January 2022. |
Article 39: imprisonment and/or a fine of AED 100,000 to AED 300,000 for forging an electronic document, rising to temporary imprisonment and AED 150,000 to AED 750,000 for government documents. Article 40: up to one year and/or AED 100,000 to AED 1,000,000 for unlawful use or fraud. Article 41: up to one year and/or AED 50,000 to AED 500,000 for improper certificates. Article 42: temporary imprisonment and fines of at least AED 500,000 for breaching confidentiality of sensitive information. Article 43: up to six months and/or AED 20,000 to AED 100,000 for false certificate data. Article 44: AED 50,000 to AED 250,000 for licensee violations. Article 45: imprisonment and/or AED 500,000 to AED 1,000,000 for unlicensed trust-service activities or obstruction. Administrative penalties are set by Cabinet decision under Article 48.
This law is why most of our clients' corporate paperwork no longer needs a wet signature. Shareholder and board resolutions, engagement letters, KYC declarations and intra-group agreements are signed electronically on the strength of Articles 5 and 18, and we keep the signing platform's audit trail so that integrity and attribution can be shown if a document is ever challenged. The distinction that matters is between an ordinary or reliable signature and a qualified one: where a registrar, notary, bank or court wants the authenticity of a manual signature, Article 18 requires a qualified electronic signature issued by a TDRA-licensed provider or a comparable foreign qualified service under Article 37, and we tell clients in advance which documents fall on that side of the line. Because Article 2 lets the Cabinet exclude transactions, we check the position for each registry before relying on electronic execution for a filing.
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