For many businesses in the UAE, music is an important part of creating the right customer experience. Background music in a restaurant, songs playing in a hotel lobby, a playlist in a retail store or music during fitness classes may appear to be an ordinary part of daily business operations.

However, from a copyright perspective, playing music in a commercial environment is different from listening to music privately.

The UAE Ministry of Economy and Tourism has introduced the Collective Management in Music Guide, issued pursuant to Ministerial Resolution No. 136 of 2026, creating a nationwide framework for the collective management and licensing of relevant music rights. The Ministry has announced that applicable music-use fees will begin from 1 December 2026. The framework affects a wide range of businesses, including restaurants, cafés, hotels, shopping malls, fitness centres, airlines, broadcasters and event organisers.

For UAE businesses that regularly use music as part of their operations, this development is an important copyright and compliance consideration.

What Is Changing Under the UAE Music Licensing Framework?

The UAE's new Collective Management in Music Guide establishes a more structured framework for managing music rights and licensing the commercial use of protected musical works.

The framework is intended to regulate the collective management of copyright and neighbouring rights associated with music and to provide a more consistent system for licensing and collecting payments relating to commercial music use.

According to the Ministry of Economy and Tourism, the categories of businesses and activities covered include:

• Restaurants and cafés;
• Hotels and floating hotels;
• Shopping malls and commercial establishments;
• Fitness centres and gyms;
• Airlines;
• Radio stations;
• Television channels;
• Concerts; and
• Similar events and activities involving the commercial use of music.

The applicable framework recognises that the use of music in these settings may involve copyright and neighbouring rights.

The Ministry has stated that the fees will begin to apply from the beginning of December 2026, and the licensing framework provides for licences relating to collective management activities to operate for a one-year period, subject to renewal in accordance with the applicable rules and conditions.

Does a Spotify or Other Streaming Subscription Cover Commercial Use?

One of the most common questions businesses may ask is:

“We already pay for a music streaming subscription. Do we still need a commercial music licence?”

Businesses should not automatically assume that a personal or ordinary music-streaming subscription gives them all the rights required to play copyrighted music publicly in a commercial establishment.

There is an important distinction between:

• Listening to music privately or personally; and
• Using music as part of a commercial environment or customer experience.

For example, a restaurant playing music for diners, a hotel using music in public areas or a fitness centre playing music during classes may be using music in circumstances that involve commercial copyright and neighbouring-rights considerations.

The new UAE framework is designed to address the collective management and licensing of relevant music rights in commercial settings. Businesses should therefore review the terms of their existing streaming, entertainment and music-service arrangements rather than assuming that a personal subscription automatically covers public or commercial use.

Which Businesses Are Affected by the New UAE Music Licence Rules?

The new framework has broad potential relevance across several industries.

Restaurants and Cafés

Restaurants and cafés commonly use music to create an atmosphere for customers. This may include:

• Background music;
• Curated playlists;
• Music played through speakers;
• DJ performances;
• Live singers or musicians; and
• Music played during special events.

The nature and scale of the music use may affect the applicable licensing category and fees.

Hotels and Hospitality Businesses

Hotels may use music across multiple areas, including:

• Hotel lobbies;
• Restaurants;
• Bars and lounges;
• Pool areas;
• Event halls;
• Wedding venues;
• Entertainment areas; and
• Other public spaces.

Businesses operating larger hospitality venues may need to consider the different ways in which music is used across their premises.

Shopping Malls and Retail Businesses

Music is commonly used in:

• Retail stores;
• Shopping centres;
• Malls;
• Commercial common areas; and
• Promotional or customer-experience environments.

The applicable fee structure may depend on the category of the establishment and other factors relating to the scale and nature of the activity.

Fitness Centres and Gyms

Music is often an essential part of the customer experience in fitness centres.

Businesses may use music during:

• Group fitness classes;
• Personal training sessions;
• Gym floor activities;
• Yoga and wellness classes; and
• General background entertainment.

Fitness businesses should review how and where music is used as part of their operations.

Events, Concerts and Live Entertainment

The framework also covers concerts and similar events.

Businesses and organisers involved in:

• Live music;
• DJ events;
• Concerts;
• Entertainment programmes;
• Cultural events; and
• Music-based customer experiences

should consider the licensing implications before organising or promoting these activities.

Live entertainment may involve different licensing considerations from simply playing recorded background music.

How Much Will Businesses Have to Pay for a Music Licence in the UAE?

There is no single standard music licence fee that applies to every business.

The applicable fee may depend on factors such as:

• The type of business;
• The size of the establishment;
• The nature of the music use;
• The scale of commercial activity;
• Seating capacity;
• Floor area;
• Number of rooms; or
• Other criteria applicable to the relevant business category.

The published framework uses different approaches for different sectors. Reported tariff structures for hospitality, retail and other businesses are therefore based on the specific category and characteristics of the establishment rather than applying one uniform annual amount to every business.

Businesses should identify the precise category applicable to their operations and confirm the relevant licensing requirements and tariff with the authorised rights-management organisation.

What If a Restaurant or Hotel Has Live Music or a DJ?

This is an important distinction.

Not every form of music use is necessarily treated in the same way.

A restaurant playing recorded background music may have different licensing considerations from a venue that regularly hosts:

• Live singers;
• Musicians;
• DJs;
• Concerts;
• Entertainment nights; or
• Ticketed music events.

The scale and nature of the music activity may affect the applicable licensing requirements and fees.

Businesses that regularly organise live entertainment should therefore avoid assuming that a general background-music arrangement automatically covers every type of musical activity conducted at the venue.

Hotels, restaurants, clubs and event venues should review their entertainment programmes in advance and consider how licensing responsibilities are allocated between:

• The venue;
• The event organiser;
• The DJ;
• The entertainment company; and
• Other service providers.

Clear contractual arrangements can help reduce uncertainty regarding compliance responsibilities.

Who Will Collect the UAE Music Licence Fees?

The UAE Ministry of Economy and Tourism has authorised the Emirates Music Rights Association and Music Nation to undertake collective management of relevant music rights.

Their functions include the collection and distribution of payments relating to the relevant rights within the collective management framework.

The Ministry has stated that these entities are responsible for managing the relevant rights efficiently, transparently and fairly and for organising the collection and distribution of payments to music creators and rights holders.

Businesses should confirm the appropriate licensing process, applicable repertoire and rights covered for their particular use directly through the relevant authorised organisation.

Where Do the Music Licence Fees Go?

The new framework is not simply about introducing an additional operational cost for businesses.

The collective management system is intended to support the rights of individuals and organisations involved in creating and producing music.

Rights holders may include:

• Composers;
• Songwriters;
• Singers;
• Musicians;
• Sound recording producers; and
• Music publishers.

The framework is intended to facilitate the collection and distribution of payments associated with the commercial use of relevant musical works and recordings.

The Ministry has also announced the establishment of a Cultural Support Fund for Music.

According to the Ministry, 10% of the total amount collected will be allocated to this Fund. The Fund is intended to support areas including music production, artistic development, training, live performances and emerging creative talent.

The broader objective is therefore not only rights management but also supporting the development of the UAE's cultural, music and creative industries.

Are Any Uses of Music Exempt?

Yes. The Ministry has identified several categories and uses that are exempt from the applicable fees.

These include:

• Certain educational and academic institutions;
• Government entities;
• Uses occurring during national occasions; and
• Non-commercial personal celebrations and events.

The Ministry may also introduce additional exemptions through future resolutions.

However, businesses should not assume that an activity is exempt merely because it is not directly charging customers for music. The commercial context and the nature of the use may be relevant.

Businesses should confirm whether a specific exemption applies to their circumstances.

Why Is the New Music Licensing Framework Important for UAE Businesses?

For businesses, this development is about more than paying an annual fee.

It means that copyright and music-rights compliance should now be considered as part of ordinary business operations.

A single business may use music in several different ways, including:

• Background music in public areas;
• Music during events;
• DJ performances;
• Live entertainment;
• Fitness classes;
• Promotional activities;
• Digital content;
• Social media marketing; and
• Customer-experience activities.

Each type of use may raise different copyright, contractual or licensing considerations.

Businesses should therefore avoid assuming that:

One music subscription = permission to use music everywhere.

The rights provided under a particular agreement depend on the terms of that agreement and the nature of the intended use.

What Should Businesses Do Before 1 December 2026?

Businesses that regularly use music should begin reviewing their arrangements before the new fee regime takes effect.

1. Identify How Music Is Used

The first step is to identify every situation in which music is used.

Businesses should ask:

• Is music played for customers?
• Is it background music?
• Are DJs regularly engaged?
• Are live musicians or singers hired?
• Is music played during fitness classes?
• Is music used during events?
• Is music used in promotional videos or social media content?

A clear internal review will help businesses understand the scope of their music use.

2. Review Existing Music and Entertainment Agreements

Businesses should review existing agreements with:

• Streaming providers;
• Entertainment companies;
• DJs;
• Musicians;
• Event organisers;
• Hotels or venue operators; and
• Music service providers.

The key question is whether those agreements actually provide the rights required for the intended commercial use.

Businesses should not rely solely on informal assurances that a service is “licensed” without understanding precisely which rights and territories are covered.

3. Identify the Correct Fee Category

The applicable fee may depend on the nature and scale of the business.

Businesses should identify:

• Their business category;
• The type of music being used;
• The size of the establishment;
• The relevant tariff criteria; and
• Whether multiple types of music use are involved.

Larger businesses and businesses with multiple branches may need to conduct this review across each location.

4. Review Live Entertainment and Events

Businesses planning:

• DJ nights;
• Live music;
• Concerts;
• Entertainment programmes; or
• Special events

should consider licensing requirements before launching those activities.

This is particularly important for:

• Hotels;
• Restaurants;
• Clubs;
• Event venues; and
• Entertainment businesses.

Contracts with performers and event organisers should also clearly address responsibilities relating to applicable licences and rights.

5. Avoid Leaving Compliance Until the Last Minute

The applicable fees begin from 1 December 2026.

Businesses should therefore start reviewing their music arrangements in advance, particularly where they:

• Operate large premises;
• Have multiple branches;
• Regularly host entertainment;
• Use several music providers; or
• Have complex contracts with third-party event organisers.

Early preparation can help businesses understand their potential obligations and budget for any applicable costs.

A Broader Development in UAE Intellectual Property Protection

The Collective Management in Music Guide forms part of the UAE's broader approach to strengthening intellectual property protection and supporting the development of creative industries.

The framework is connected to the UAE's existing copyright and neighbouring-rights legislation and aims to provide a more structured approach to collective rights management, licensing and the protection of creators and rights holders.

The Ministry has described the framework as an important development in strengthening transparency, fairness and efficiency in the management of music rights while supporting the growth of the UAE's creative economy.

For businesses, the practical message is straightforward:

If music is part of your commercial operation, music licensing should also be part of your compliance considerations.

How Concept Lawyers Can Help

At Concept Lawyers, we assist businesses with commercial, regulatory and intellectual property matters, including helping businesses understand how new legal and regulatory requirements may affect their day-to-day operations.

For businesses that use music as part of their customer experience, an early review of existing arrangements before 1 December 2026 may help identify potential licensing and compliance issues.

Whether you operate a:

• Restaurant;
• Café;
• Hotel;
• Gym;
• Retail business;
• Shopping centre;
• Event venue; or
• Entertainment business,

understanding how music is used within your organisation can help you assess the applicable legal and licensing considerations.

Our legal team can assist businesses in reviewing relevant contractual arrangements, commercial activities and regulatory obligations to help identify potential intellectual property and copyright compliance issues.

Disclaimer: This article is intended for general informational purposes only and does not constitute legal advice. The applicable licensing requirements, tariffs, rights and exemptions may depend on the nature of the business, the type of music used, the applicable repertoire and the manner in which the music is used. Businesses should review the current official framework and obtain specific legal or professional advice where required.