The short legal answer
Article 44 of Federal Decree-Law No. 34 of 2021 on Combating Rumours and Cybercrimes protects privacy against intrusion through information technology. It covers recording conversations, taking photographs of people without consent, publishing images that harm a person, and tracking location. The penalty is detention of at least six months and/or a fine of AED 150,000 to AED 500,000. If the material was edited or altered to harm the person, it rises to at least a year and AED 250,000 to AED 500,000 (Legal 500).
Two points surprise people who learned photography rules in Europe or the US:
- There is no general public-place exception. Photographing a specific person in a mall, restaurant or street and posting it can still be prosecuted.
- Truth is no defence. The offence is the unauthorised capture or disclosure, not falsehood.
The same idea existed under the old Cybercrime Law: Al Tamimi described a 2018 case where a driver who photographed another driver during a road dispute was fined AED 250,000 at first instance.
Intent matters, but don't build a campaign on it
In March 2026 Alsuwaidi & Company reported an acquittal under Article 44: the photo had been taken only to document apparently unlawful conduct and was never posted or shared. The court held that criminal intent must be proved alongside the act.
For brands, that cuts the other way. A marketing post is published on purpose to reach as many people as possible. If a recognisable person in it did not agree, "we had no intent to harm" is a weak position.
The media-law layer
Separately from criminal law, privacy is one of the 20 NMA media content standards. Breaching it costs AED 20,000 to AED 100,000 under Cabinet Resolution 42/2025, set by the NMA's content committee. In September 2026 the NMA also said it was studying tighter rules on filming at weddings and private gatherings after guests posted clips of attendees, and that existing rules already cover filming people, public figures included, without consent.
Who is in your frame: a decision table for brand shoots
| Situation | Risk | What to do |
|---|---|---|
| Hired model or talent | Low with paperwork | Signed model release covering platforms, territory and duration |
| Your staff | Medium | Separate signed media release; honour withdrawal when they leave |
| Customers or diners, recognisable | High | Ask on the spot, record or sign consent; otherwise reframe or blur |
| Background crowd, no identifiable faces | Low | Wide or shallow focus; check every frame before posting |
| Children | High | Parent's written consent, no names, no school uniforms with logos |
| Patients (clinic content) | High, plus DHA rules | Written consent required by the DHA standard; see our clinic advertising guide |
| Event guests | High | Consent notice at entry plus individual consent for close-ups used in ads |
| Police, military, government sites | Do not shoot without permission | Security rules apply on top of privacy |
What a release should say
A useful release for UAE marketing content is one page and covers:
- Name, contact and signature of the person (guardian for under-18s).
- What is being recorded: photo, video, voice.
- Where it will be used: Instagram, TikTok, website, paid ads, outdoor.
- For how long and in which countries.
- Whether the person is paid and how much (it matters for the ad disclosure rules if they post it too).
- How to withdraw consent and what happens to content already published.
- Language the person understands; an English-only form signed by someone who doesn't read English is weak evidence.
Under the UAE data protection law, images of people are personal data, so store signed releases as carefully as any customer data. See our guide to PDPL for websites.
What nobody tells you
- A sign at the door is not a release. "Filming in progress" notices help show you warned people. They are not the specific, informed consent a court or regulator will look for from a person featured in an ad.
- Reposting a customer's story is publishing it again. If a guest tags your venue, ask before you reshare it, especially if other people are visible in it.
- Blur is cheaper than reshoots. Plan the angle so that strangers fall out of focus. Fixing it in post costs minutes; a complaint costs much more.
- Filming permits do not cover privacy. A filming permit lets you shoot at a location; it does not give you consent from the people in it. See our Dubai filming permit guide.
Vladimir Chernyshev, GM: in a Dubai restaurant at 9pm, almost every wide shot has someone in it who didn't sign anything. Book the shoot before opening hours or bring your own extras. It is the cheapest insurance you can buy.
