UAE Media Law: What Hotel Marketers Need to Know When Engaging Influencers to Produce Social Media Content

Influencer collaborations, user-generated content, and targeted social media campaigns are increasingly important for hotel and hospitality businesses globally, and this is no different for the UAE market. The UAE has recently introduced Cabinet Resolution No. 42 of 2025 (“Resolution”) which came into effect on 29 May 2025. This Resolution sets out the administrative penalties for individuals or other legal persons who carry out media activities in the absence of requisite licensing. The preceding decision, Cabinet Resolution No. 41 of 2025, sets out the licensing requirements for respective operators in the Media space within the UAE.

Key Changes 

The Resolution applies to all natural or legal persons carrying out media activities in the UAE (including the free zones), such as providing advertising or media content via social media. It obliges all such participants to obtain appropriate licensing from designated competent authorities. 

To the extent that hotels and other hospitality businesses engage marketing companies or social media influencers in the UAE, irrespective of whether the content is sponsored, the persons carrying out the promotional activity using any form of media will need to be in possession of all required licenses. There are escalating financial penalties that apply for violating licensing requirements and for repeated offences.

Practical Implications for Hospitality Industry

The usual recommendation to hoteliers remains that they should at all times be diligently reviewing advertising content concerning their business prior to publication in order to ensure compliance with legal requirements under UAE laws. These include best practice standards, such as (i) avoiding being vague or misleading with advertisements, (ii) content being appropriately labelled as advertising, (iii) identifying the commercial relationships  to distinguish commercially motivated content from editorial content, (iv) avoiding the promotion of prohibited products, and (v) obtaining necessary regulatory approvals. In light of the recent decisions outlined above, hoteliers are advised to check that their promotional partners (including influencers) are properly licensed and to obtain evidence of this prior to contracting. This should be part of a compliance policy when onboarding UAE partners and should be a condition of any related contract. Hoteliers should also review licensing obligations in any subsisting contracts. To ensure compliance of partners with local media laws, it is always advisable to seek expert local counsel advice to mitigate risk. Whilst an owner or operator itself might not be the subject of the administrative action where violations arise, non-compliance could be costly to business  reputation.