2.1 UAE Legal Framework and Security Legislation
Key Takeaways
Federal Law No. 37 of 2006 Concerning Private Security Companies was published in Official Gazette No. 455 on 12 October 2006 and was last amended by Federal Decree-Law No. 1 of 2017.
The executive order is Ministerial Decision No. 557 of 2008, issued by the Minister of Interior; it contains the guard licensing, training, uniform and fine rules.
Article 12 of the Law limits a security company's work to preventive security protection and bars it from performing the tasks of law enforcement officers.
Providing security services without the required security approval carries a fine of not less than AED 500,000 under Article 20(1) of the Law.
Other breaches of the Law or its executive regulations carry imprisonment and/or a fine of AED 20,000 to AED 200,000, doubled for repeat offences.
Quick Answer: Two instruments govern private security outside Dubai. Federal Law No. 37 of 2006 Concerning Private Security Companies sets the principles and penalties. Ministerial Decision No. 557 of 2008, the executive order issued by the Minister of Interior, sets the detailed rules on licences, training, uniforms, cash-in-transit work and fines. A guard is also bound by the general federal criminal laws, including the Crimes and Penalties Law (Federal Decree-Law No. 31 of 2021) and the Criminal Procedure Law (Federal Decree-Law No. 38 of 2022).
Why the legal framework matters to a guard
A guard's daily decisions are legal decisions: whether a person may enter, whether a bag may be checked, whether a suspect may be held, and whether force is lawful. The licensing examination tests whether candidates know where their authority comes from and where it stops. Every power a guard uses is either granted by the client's property rights, permitted to any member of the public by general law, or authorised by the private security legislation. Nothing else gives a guard authority.
The UAE legal hierarchy
| Level | Instrument | Who issues it | Example relevant to guards |
|---|---|---|---|
| 1 | Constitution of the UAE (1971) | Federation | Personal liberty and the privacy of homes are protected |
| 2 | Federal laws and federal decree-laws | President of the State, through the federal legislative process | Federal Law No. 37 of 2006; Federal Decree-Law No. 31 of 2021 |
| 3 | Executive regulations, Cabinet resolutions and ministerial decisions | The Cabinet or the competent minister, as the law delegates | Ministerial Decision No. 557 of 2008 (Minister of Interior) |
| 4 | Directives of the competent authority and site instructions | The licensing department, police, the employer and the client | Inspection requirements, post orders, assignment instructions |
A lower instrument can never authorise something a higher one forbids. A post order that tells a guard to search a visitor against their will, for example, cannot override the general law that gives private persons no power to do so.
Article 23 of the Law lets the Minister issue the regulations needed to implement it. That is why the executive order is a ministerial decision. It is not a Cabinet decision, although some unofficial study material calls it one.
Federal Law No. 37 of 2006: the articles a guard should know
The Law was issued on 9 October 2006, published in Official Gazette No. 455 on 12 October 2006, and came into force on publication (Article 24). Federal Decree-Law No. 1 of 2017 amended it, including the weapons and penalty provisions.
| Article | Rule in plain language |
|---|---|
| 1 | Defines the Competent Authority: the department at the Ministry of Interior or a Police General Department that supervises security companies. "Security staff" includes guards of buildings, facilities, events and celebrations, whether full-time or part-time. |
| 3 | No company may be established or licensed to provide security services without security approval from the Competent Authority. |
| 9 | A company's activity is limited to the emirate where it is licensed. Exceptions are moving money or valuables between emirates and protecting people while they travel between emirates. |
| 10 | A company may provide only the class of security service named on its licence. |
| 11 | A company may not appoint security staff without the Competent Authority's approval. |
| 12 | Company business is limited to preventive security protection and does not extend to the tasks of law enforcement officers. |
| 13 | The company must coordinate fully with the Competent Authority so that its work does not conflict with established security measures. |
| 15 | The company must run a communication centre at its head office using licensed wired and wireless devices. |
| 16 | Weapons may be acquired or carried only with the approval of the security bodies and with licences for both the company and the employee. |
| 17 | Security staff must complete a training course at a licensed Training Institute. |
| 18 | The uniform must be distinct from that of the police and armed forces. |
| 19 | The company must keep organised records, and the Competent Authority may inspect them at any time. |
| 20 | Criminal penalties (see below). |
| 21 | The Minister sets administrative violations and fines, each of which may not exceed AED 5,000. |
Penalties under Article 20
Article 20 applies "without prejudice to any more severe punishment" in another law:
- Providing security services without security approval (Article 3): a fine of not less than AED 500,000.
- Breaching the weapons rules in Article 16: imprisonment and a fine of not less than AED 1,000,000.
- Any other breach of the Law or its executive regulations: imprisonment and/or a fine of AED 20,000 to AED 200,000.
- Repeat offences: the penalties are doubled, and the company's licence may be revoked.
Article 117 of Ministerial Decision No. 557 lists conduct that triggers these Article 20 penalties. The list includes providing a security service without a licence, a company using an unlicensed security employee, giving the authority false information, obstructing the authority's work and refusing to pay fines. It also covers a company or employee with more than ten recorded infringements, or a single infringement fine above AED 5,000.
Ministerial Decision No. 557 of 2008: the executive order
The English edition of the order, published by the Ministry of Interior's Private Security Business Department, has nine chapters:
- General rules
- Company licensing
- Cash-in-transit service requirements
- Cash centre requirements
- Licensing of security training institutes
- Licensing of security employees
- Licensing of security trainers
- Infringements and fines
- Final rules
Rules every guard is expected to know include:
- Article 2: no one may provide any security service before obtaining the required licence.
- Article 4: apart from family residences, no person, government body or company may employ a security guard on its premises except through a security company.
- Article 9: the titles private security employee, manager, supervisor and guard are reserved for security companies.
- Article 99: a guard may not perform any duty before receiving the individual licence, and the company may not allow it.
- Article 105: a security employee may not possess any firearm, or any weapon that fires, while on duty.
- Article 112: no individual licence is granted or renewed unless the employee passes the Competent Authority's test with at least 70%.
General laws that also bind guards
| Law | Provisions a guard meets in practice |
|---|---|
| Crimes and Penalties Law, Federal Decree-Law No. 31 of 2021 (replaced Federal Law No. 3 of 1987) | Article 58 legitimate defence; Article 395 unlawful detention; Article 431 violating private life, including photographing a person in a private place; Article 432 disclosing a secret learned through one's work; Article 454 keeping lost property; Article 474 entering or staying in a dwelling, or in a place used to keep money or property, against the will of the person entitled to exclude others; Articles 278–279 bribery in the private sector |
| Criminal Procedure Law, Federal Decree-Law No. 38 of 2022 (replaced Federal Law No. 35 of 1992) | Article 43 defines flagrante delicto; Article 49 allows anyone who witnesses such a crime to hand the offender to the nearest public authority officer without a warrant |
| Cybercrime Law, Federal Decree-Law No. 34 of 2021 | Article 44: using technology to photograph people or publish their images without consent carries imprisonment of at least six months and/or a fine of AED 150,000 to AED 500,000 |
| Labour Law, Federal Decree-Law No. 33 of 2021 | Working hours, overtime and leave (see Section 3.3) |
Case study: the unlicensed relief guard
Guard Tariq is on duty at an office tower on Al Reem Island when his relief calls in sick. The control room sends Rashid, a new recruit who has had his medical but has not yet completed training or obtained an individual licence. It tells Tariq to hand over the keys and leave.
- Under Article 99, Rashid may not perform guard duties, and the company may not let him.
- Under Article 117(2), a company using an unlicensed employee faces the Article 20 penalties of the Law. Those include imprisonment and/or a fine of AED 20,000–200,000, doubled on repetition.
- Tariq should decline to hand over the post. He should inform his supervisor that the replacement is unlicensed, stay on post until a licensed guard arrives, and record each call and instruction in the occurrence book.
Section summary checklist
- The governing law is Federal Law No. 37 of 2006. Its executive order is Ministerial Decision No. 557 of 2008.
- Security work is preventive (Article 12). Guards do not perform law-enforcement tasks.
- The uniform must be distinct from police and armed forces uniforms (Article 18).
- Penalties: at least AED 500,000 for unapproved services; imprisonment plus at least AED 1,000,000 for weapons breaches; imprisonment and/or AED 20,000–200,000 otherwise; doubled for repeats.
- Ministerial administrative fines may not exceed AED 5,000 each (Article 21).
Which instrument is the executive order that sets the detailed licensing, training, uniform and fine rules under Federal Law No. 37 of 2006?
Cabinet Resolution No. 1 of 2022 on the Labour Law regulations
Federal Decree-Law No. 31 of 2021 on crimes and penalties
Dubai Law No. 12 of 2016 on regulating the security industry
Ministerial Decision No. 557 of 2008 of the Minister of Interior
According to Article 12 of Federal Law No. 37 of 2006, what is the business of a private security company limited to?
Preventive security protection, without performing the tasks of law enforcement officers
Any protective or investigative task the client chooses to include in the contract
Investigating crimes reported on the client's premises and preparing case files for court
Enforcing traffic and municipal rules on the public roads next to the protected site
A company starts guarding a shopping mall before obtaining security approval from the Competent Authority. What does Article 20(1) of Federal Law No. 37 of 2006 provide?
A fine of AED 20,000 to AED 200,000 with no other consequence
An administrative fine capped at AED 5,000 under ministerial rules
A written warning on the first occasion, then a fine if repeated
A fine of not less than AED 500,000, under Article 20(1) of the Law
Sections you finish are checked off in the contents.