Walk through any big mall in Dubai and you will see some of the most carefully policed luxury retail in the world. Walk a few streets away and you will hear a different pitch: “Bags, watches, copy, first quality.” The UAE has always had strong laws against fakes. What it has not always had is speed.
That changed this summer. Cabinet Resolution No. 107 of 2026, the executive regulations to the UAE’s anti-commercial fraud law, has put a clock on the problem. Once a supplier is officially notified that its goods are counterfeit, fraudulent or spoiled, it has 24 hours to get them off the market.
For anyone who makes, imports, stocks or resells fashion in the Emirates, this is the most practical anti-counterfeiting change in years. Here is what it says, who it catches, and what brands and sellers should do about it.
Where the rule comes from
The parent law is Federal Decree-Law No. 42 of 2023 on Combating Commercial Fraud, issued in September 2023. It replaced the 2016 commercial fraud law and covers goods that are counterfeit, adulterated, spoiled or simply not what the seller says they are. A counterfeit, for this purpose, includes goods carrying a mark identical or similar to a registered trademark without the owner’s permission.
The new resolution fills in the detail. It was issued on 13 July 2026, repeals the old 2020 regulations (Cabinet Resolution No. 11 of 2020) and, as Gulf News reported, came into force in mid-August. The Ministry of Economy and Tourism then walked the market through it in early September.
The clock, hour by hour
The core of the resolution is a set of deadlines that start running the moment a supplier receives official notice:
- Immediately: stop selling or displaying the goods.
- Within 24 hours: withdraw them from shelves and warehouses, and tell every shop or business you supplied so they pull them too.
- Within 48 hours: publish a recall notice in Arabic and English, naming the product, the brand, the model and how buyers can get a refund. Authorities can shorten this where there is a health or safety risk.
- Within five working days: file a detailed report on what was withdrawn and what was refunded.
If the supplier does not act, the authorities can do the withdrawal themselves and send the bill. Clyde & Co also notes target timelines on the state’s side: inspections should generally finish within five working days, and laboratory testing within fifteen, at the supplier’s cost. Seized goods that can be sent back must be re-exported within 30 days of seizure, again at the supplier’s expense, and goods ordered destroyed must go within 15 working days of the ruling.
None of these steps waits for a criminal trial. That is the point. Before, a fake could sit on a shelf while the paperwork caught up. Now the shelf has to be empty by this time tomorrow.
Who it catches
The definition of “supplier” is deliberately wide. It covers importers, exporters, manufacturers, producers, marketers, sellers, holders of goods, warehouse operators, transporters and exhibitors. Gulf News reports that the rules apply to all goods and services in the country, including the free zones, and to e-commerce where the supplier is registered in the UAE.
Three groups in fashion should pay attention.
Resellers and pre-owned boutiques. Dubai has a large market in pre-owned luxury. Clyde & Co points out that liability under the framework can reach distributors and resellers who knew, or should reasonably have known, what they were handling. “I bought it in good faith” is a weaker shield when the price, the source or the paperwork should have raised a flag.
Free zone traders. Jebel Ali and the other zones are major transit hubs for goods moving between Asia, Africa and Europe. The rules do not stop at the zone fence.
Online sellers. The Ministry has said it monitors e-commerce and open sources with intelligent systems, and works directly with UAE platforms to take listings down. Khaleej Times quoted Safeya Al Safi, Assistant Undersecretary for Commercial Control and Governance, describing a zero-tolerance approach to commercial fraud.
What happens if you get it wrong
The penalties sit in the 2023 Decree-Law, not the new resolution, and they are not small. Under Article 17, dealing in fraudulent or counterfeit goods can bring up to two years in prison and/or a fine of Dh5,000 to Dh1 million. Article 18 raises the fine to between Dh100,000 and Dh2 million in aggravated cases, such as goods that are harmful to health, medicines or food products. That matters for beauty and fragrance as much as for food.
Courts must also order the goods confiscated or destroyed, can close the shop for up to six months and must publish the judgment in two local newspapers. Repeat offenders within five years face doubled penalties and closure for up to a year.
There is a way out for honest mistakes. Under Article 22 of the resolution, a trader can ask to settle a violation if it came from error or negligence rather than bad faith, has been fixed, and the trader has not been penalised in the previous twelve months. Baker McKenzie notes that settling does not wipe out civil claims by the people who were harmed.
Fraud law and trademark law: two different tools
Brand owners in the UAE now have two tracks, and it helps to keep them apart.
The commercial fraud track is consumer protection. The state acts, the 24-hour clock runs, and the goal is to get bad goods out of the market fast. The brand does not need to be a party.
The trademark track is the brand’s own right. Under Article 49 of Federal Decree-Law No. 36 of 2021 on Trademarks, counterfeiting a registered mark or knowingly selling goods that carry one can bring imprisonment and a fine of Dh100,000 to Dh1 million. This is the track for going after the people behind the supply, and for damages.
As I wrote in my column on the fake Patek Philippe case, a third track runs alongside both: the buyer who was cheated can use fraud and civil law to get their money back. One fake can trigger all three.
What brands should do now
- Register locally. Both the fraud and trademark routes work best with a mark registered in the UAE. The Global Trademark Search Directory links to the official UAE register.
- Feed the regulator. The Ministry has to hear about a fake before the 24-hour clock can start. Test purchases, photos, invoices and marketplace links make a complaint actionable.
- Map the supply chain. Know which importers, free zone traders and platforms keep showing up. The resolution reaches all of them.
- Use both tracks. Let the fraud rules clear the shelf, and use trademark law and the courts against the source. A brand protection programme in the Gulf should plan for both.
What resellers and boutiques should do
Keep invoices and the chain of ownership for every piece you stock. Authenticate before you list, not after a complaint. Write down how you checked. Have a recall plan, because 24 hours is not long enough to design one from scratch. And if something feels too cheap, treat that as a red flag, not a bargain.
For shoppers, the logic runs the other way. If a seller cannot tell you where a bag came from, assume the answer is not one you would like. Our guide on buying fakes abroad explains what can happen at customs on the way home.
The numbers behind it
The Ministry says it carried out 10,023 inspection visits in the first quarter of 2026 and found 189 violations. That is a lot of checking for a fairly small number of cases, which tells you something: enforcement in the UAE is already broad. What the new rules add is speed and a clear process once something is found.
The take
Dubai wants to be the place where the world buys luxury. That only works if buyers trust what they are buying. A 24-hour clock does not end the trade in fakes, and the pitch on the side street will not disappear overnight. But it changes the economics. A shelf that has to be cleared by tomorrow is a shelf that is not worth filling with copies.
For brands, the message is simple: the system will now move fast, but only after someone tells it where to look. Make sure that someone is you.
This column is commentary and analysis, not legal advice. It is based on Cabinet Resolution No. 107 of 2026, Federal Decree-Law No. 42 of 2023 and the reporting and law firm briefings linked above.
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