The UAE’s New Merger Control Framework: What the 2026 Executive Regulations Mean for Dealmakers

In this piece for Covington & Burling, authors James Marshall, Haykel Haykel & Mélanie Perez examine the UAE’s sweeping overhaul of its merger control regime through the adoption of the 2026 Executive Regulations under the country’s updated competition law framework. The reforms complete a broader modernization process launched with the 2023 Competition Law and new 2025 filing thresholds, signaling the UAE’s ambition to align its antitrust system with international best practices. The regulations are expected to enter into force in July 2026 and introduce clearer procedures, enhanced timing certainty, and expanded opportunities for third-party participation in merger reviews.

The article explains that the new rules significantly clarify filing obligations and procedural requirements for transactions caught by UAE merger control thresholds. Acquiring parties are now clearly responsible for filings in acquisitions, while all parties share responsibility in mergers and joint ventures. The regulations also require detailed economic analyses covering market definition, competitive effects, overlaps, and potential efficiencies, while simultaneously reducing burdensome notarization and corporate documentation requirements that existed under the prior framework.

The authors highlight the introduction of more predictable review timelines and expanded investigative powers for the Competition Department. The new framework imposes a structured completeness review process capped at roughly 30 business days before the formal statutory review begins. Third parties are also now permitted to submit comments and formal objections to transactions, giving competitors and market participants a direct role in merger proceedings. In addition, the Competition Department gains authority to investigate transactions that should have been notified but were not, reinforcing enforcement capabilities under the revised regime.

Beyond merger control, the piece notes that the 2026 Executive Regulations also strengthen the UAE’s broader behavioral antitrust enforcement framework. The reforms include new guidance on dominance assessments, below-cost pricing prohibitions, complaint procedures, and ex officio investigations. The article also points to recent enforcement initiatives — including sector-specific exemptions, updated complaint guidelines, and investigations into alleged poultry-sector price fixing — as evidence of a rapidly evolving competition landscape that businesses operating in or transacting with the UAE will increasingly need to monitor closely…

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