Autonomous Vehicles: Asymmetric Legal Framework, UAE

A company that wants to run self-driving vehicles in Dubai meets one sentence early: no Autonomous Vehicle may travel on a Road unless it is licensed by the RTA. Two licences sit behind that sentence, one for the vehicle and one for the operator of the fleet. The same rules then settle what the vehicle records while it drives, who answers when it causes an accident, and what insurance must be in place.

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The law came first, the operating detail followed in 2025

The Dubai Self-Driving Transport Strategy aims to convert 25% of total transportation trips in Dubai into self-driving journeys by 2030. Law No. (9) of 2023 Regulating the Operation of Autonomous Vehicles, the AV Law, was the first dedicated piece of legislation in the UAE to establish a licensing, regulatory and liability framework for autonomous vehicles.

Administrative Resolution No. (939) of 2025, the Executive Regulations, followed. It details the practical requirements for the operation of autonomous vehicles in Dubai. Together, the two documents provide a clear, structured pathway for the commercial operation of self-driving technology.

The operator is licensed as well as the vehicle

The Executive Regulations define six distinct categories of self-driving vehicles, ranging from light vehicles to buses and specialised transport, and set out the conditions for obtaining and renewing licences. The RTA’s framework then distinguishes between two primary types of licence.

The Operator Licence is required for the entity responsible for managing and operating the fleet of autonomous vehicles, and is crucial for companies seeking to run commercial autonomous transport services. The Autonomous Vehicle Licence is specific to the vehicle itself, and confirms that it meets the technical and operational standards before it is allowed on public roads.

Operator obligations include adherence to designated routes, maintaining specific operational zones and the continuous monitoring of the vehicles. The regulations also specify requirements for adult supervision in certain categories or during initial testing phases.

A first step the technology does not cover

For an international or local entity entering this market, establishing a legal entity and securing operational licences in the UAE is a critical first step. That work runs through the RTA’s specific requirements, corporate compliance, and structuring the business to meet the standards set by the Dubai government. Our corporate and commercial law team advises on corporate structuring and regulatory compliance for that entry, and our corporate governance advisory service covers the governance side of it.

Inspection does not end at the first pass

Every Autonomous Vehicle must successfully pass a technical inspection conducted in accordance with standards and requirements approved by the RTA. That inspection is not a one-time event but a continuous process, with the types, frequency and standards of inspection prescribed by the RTA. The technology itself is the driver, and must be held to the highest standards.

Key technical requirements include:

• Certificate of Compliance: a certificate issued by the Competent Entity, confirming that the vehicle’s autonomous driving system meets all approved specifications.
• Data recording system: the vehicle must be equipped with a system capable of recording and storing operational data, acting as a black box. That data is vital for accident investigation and liability determination.
• Cybersecurity and data protection: the regulations require cybersecurity measures that protect the vehicle’s systems from external threats and safeguard the data collected.

Companies must ensure their hardware and software architectures are compliant with UAE standards, which are continuously evolving.

Related: Our technology and intellectual property law advisory service supports AV operators and manufacturers on technical compliance, protecting proprietary data, and the data governance mandates in the UAE.

Liability sits with the Operator or the Agent

The AV Law shifts accountability away from the traditional human driver model. It primarily places liability on the Operator, or on the Agent, meaning the entity responsible for the vehicle’s operation and maintenance. After an accident, the investigation will focus on:

1. Operational liability: was the accident caused by a failure of the autonomous driving system, or by a flaw in the system’s software? Or was it caused by a breach of the operator’s obligations, for example operating outside approved zones or failure to maintain the vehicle?
2. Product liability: was it caused by a manufacturing defect in the vehicle’s hardware, or by a fundamental flaw in the design of the autonomous driving system?

The law allows the operator to potentially seek recourse against the manufacturer or the software provider if the fault is determined to be a product defect. That chain of liability takes careful legal analysis to untangle.

Insurance answers what the liability chain leaves open

The Executive Regulations mandate that every Autonomous Vehicle must be covered by a comprehensive insurance policy issued by an insurance company licensed to operate in the UAE. The policy must cover:

• damage to the vehicle itself;
• damage to third-party property;
• bodily injury or death resulting from the operation of the AV.

That requirement means victims of AV-related accidents have a clear and reliable path to compensation, regardless of the complexity of determining fault between the operator, the manufacturer and the software.

Abu Dhabi regulates its robotaxis through the ITC

Fully autonomous robotaxi services have launched in Abu Dhabi, which has positioned itself as a hub for commercial autonomous vehicle operation. The Integrated Transport Centre (ITC) oversees the regulation of those services, focusing on a safe and efficient environment for Level 4 (fully autonomous) vehicles.

A key technological component is the AVITOMS platform, a system for real-time monitoring, testing and oversight of self-driving vehicles. It is how operational data is tracked and compliance is maintained.

Emirate rules now, federal harmonisation expected

Specific laws are often enacted at emirate level, with the RTA in Dubai and the ITC in Abu Dhabi, and both sets of efforts align with the UAE’s federal vision for smart, sustainable mobility. Future developments are expected to include greater federal harmonisation of standards, particularly concerning cross-emirate travel and the finalisation of technical regulations for all levels of autonomous driving.

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Disclaimer: The information provided in this article is for general informational purposes only and does not constitute legal advice. Readers should seek professional legal advice tailored to their specific circumstances before making any decisions or taking any action based on the content of this article.

Nour Attorneys Team