Operating an online marketplace in the UAE is a multi-party compliance exercise. The marketplace may display the offer, the seller may contract with the consumer, a payment provider may process the money, and a logistics partner may deliver the order. The legal result depends on what each party does, what the consumer is told, and which obligations the platform accepts in its terms, advertising, and customer journey.
Federal Law No. (15) of 2020 on Consumer Protection, as amended, applies to goods and services supplied in the UAE, including e-commerce platforms registered in the UAE. Federal Decree-Law No. (14) of 2023 on Modern Technology-Based Trade regulates digital marketplaces and related digital-trade activity. The operator should map both regimes to its operating model before launch or material product changes.
Start by defining the marketplace role
A platform should document whether it is an agent, a disclosed intermediary, the seller of record, a payment facilitator, a logistics coordinator, or a combination of these. The answer should be consistent across the seller agreement, consumer terms, invoices, checkout screens, advertising, and complaint process.
| Function | Primary control question |
|---|---|
| Marketplace operator | Who controls listing approval, ranking, checkout, consumer support, refunds, and the platform promise? |
| Underlying seller | Who owns the goods or provides the service, and who is licensed for the activity? |
| Payment provider | Who receives, routes, safeguards, settles, and refunds the consumer’s money? |
| Logistics provider | Who accepts delivery instructions, charges delivery fees, and handles loss, damage, or delay? |
Calling the business an “intermediary” does not answer these questions. A platform that sets the commercial terms, collects payment, issues the invoice, promises delivery, or advertises its own guarantees may have direct obligations for those functions even when an independent seller is also responsible for the underlying product or service.
Seller verification and onboarding
The marketplace should verify the seller’s legal identity, UAE trade licence or other relevant authorisation, licensing authority, business address, authorised contact, bank-account ownership, and beneficial-owner or control information where required by the risk model. The seller record should preserve the documents checked, the date of approval, expiry dates, reviewer, and the reason for any exception.
Product and service checks must be risk-based. The operator should identify regulated categories such as food, health products, cosmetics, financial products, telecommunications equipment, children’s goods, controlled goods, and services requiring professional or sector approval. Require the seller to provide the relevant permit or approval, and suspend a listing when the evidence is missing, expired, inconsistent, or materially changed.
Federal e-commerce guidance expects online businesses to have the legal capacity and licences needed for their activity, comply with legal, regulatory, and technical requirements, use secure and reliable infrastructure, and protect consumers from misleading or deceptive practices. Sellers should therefore accept contractual duties to provide accurate information, maintain approvals, honour warranties and returns, cooperate with complaints, and notify the platform of recalls, incidents, or licence changes.
Verification is not a one-time upload. Use expiry alerts, periodic re-screening, transaction and complaint monitoring, duplicate-account controls, sanctions and restricted-party checks where appropriate, and a documented escalation path. A seller with repeated counterfeit, safety, non-delivery, or misrepresentation complaints should move to enhanced review or suspension.
Consumer disclosures at every decision point
The consumer should be able to identify who is selling the product, who operates the platform, and who will perform each promised function before payment. For UAE-registered e-commerce providers, the Consumer Protection Law requires disclosure of the provider’s name, legal status, address, and licensing authority, together with sufficient information in Arabic about the commodity or service, contracting terms, payment, and warranty. The provider must also give a dated Arabic invoice containing the trade name, address, product or service, price, quantity, and other required details.
A clear marketplace checkout should show, in Arabic and in any additional language used by the consumer:
- the seller’s legal name, licence or registration details where appropriate, contact route, and place of establishment;
- the platform’s legal name and its role in the transaction;
- product specifications, condition, material limitations, availability, and any required approvals or warnings;
- the item price, VAT or other applicable charges, delivery fee, service fee, customs or import charge if known, and the total payable amount;
- delivery timing, delivery area, cancellation, return, exchange, warranty, repair, replacement, and refund conditions;
- the contract terms, payment method, recurring-payment terms, and the process for correcting an order before submission; and
- the invoice or receipt and a durable means of accessing the order record.
Arabic should be treated as the control version for mandatory disclosures, contract terms, advertising, and invoices. Translations should be checked against the Arabic text so that a promotion, warranty exclusion, delivery promise, or refund condition does not change meaning between versions.
Payments, settlement, and refunds
Modern Technology-Based Trade legislation recognises digital payment portals and subjects digital payment channels and methods to applicable legal and technical requirements. The platform should identify whether it is only using a licensed payment service provider or whether its own activities amount to operating, facilitating, or controlling a payment function.
Consumer-facing payment terms should state when the consumer is charged, the currency, all platform and delivery fees, any instalment or recurring-payment feature, the refund route, expected refund timing, and the treatment of failed, duplicated, reversed, or disputed payments. The platform should not describe a payment as “protected” or “guaranteed” unless the contractual and operational arrangements support that claim.
Keep payment and seller settlement records that reconcile the order, invoice, payment authorisation, fees, refunds, chargebacks, and payout. Define which party bears fraud loss, unauthorised transactions, delivery failure, and seller insolvency risk. Use segregation of duties, role-based access, strong authentication, transaction monitoring, and incident escalation with the payment provider. If the marketplace holds customer money or controls delayed settlement, obtain specialist advice on licensing, safeguarding, consumer terms, and insolvency treatment before launch.
Platform liability follows the service actually provided
Article 12 of the Modern Technology-Based Trade Decree-Law states that a person subject to the Decree-Law is liable for the obligations imposed by it. Liability analysis therefore starts with the platform’s actual conduct and representations. The operator’s exposure may include its own advertising, checkout disclosures, invoice, payment handling, delivery promise, complaint handling, data practices, and platform guarantees, in addition to the seller’s liability for the product or service.
The platform should allocate responsibilities expressly, but mandatory consumer protections remain relevant. A term that attempts to exclude obligations imposed by the Consumer Protection Law, or that obscures the party responsible for a consumer remedy, creates avoidable risk. The operator should explain whether a complaint is sent to the seller, handled by the platform, or covered by a platform guarantee, and should keep evidence that the stated process was followed.
Risk increases where the platform selects or bundles the product, sets the price, brands the transaction, receives the full payment, promises a delivery date, issues the invoice in its own name, or resolves the dispute without involving the seller. Those facts may support a consumer or regulator treating the platform as more than a passive noticeboard for the relevant obligation.
Delivery, logistics, returns, and complaints
The 2023 Decree-Law allows digital traders to provide storage, shipping, transport, or delivery directly or through a licensed person. It also addresses logistics fees: additional charges should not be imposed contrary to the digital contract or the published terms. Display delivery charges before the consumer commits, and reconcile the amount charged with the amount shown at checkout.
Build one owner for each after-sales path: non-delivery, damaged goods, wrong item, defective product, cancellation, return, warranty, refund, and payment dispute. The Consumer Protection framework expects prompt dispute settlement and fair compensation where the consumer is harmed. Cabinet Decision No. (66) of 2023 provides executive rules on supplier duties, defects, warranties, returns, after-sales service, complaints, and administrative penalties.
Retain complaint timestamps, seller responses, evidence requested from the consumer, delivery scans, refund approvals, and the final outcome. A marketplace should be able to show the regulator not only the written policy but also how a sample of real cases was handled.
Data, marketing, and account controls
The Consumer Protection Law recognises consumer privacy and data security and prohibits using consumer data for promotional or marketing purposes in breach of the applicable rules. Obtain the necessary consent for marketing, keep transactional messages distinct from promotions, provide a usable opt-out, and restrict seller access to the data needed to fulfil the order or provide support.
Seller agreements should prohibit scraping, resale, profiling, or independent marketing use of marketplace data unless the legal basis and consumer notice support it. Maintain retention schedules, access logs, deletion and correction workflows, breach escalation, and vendor controls for analytics, cloud hosting, customer support, and payment services.
Enforcement and debarment-style business risk
Misleading product information, undisclosed fees, unlicensed sellers, prohibited goods, weak complaint handling, inaccurate invoices, and failures in digital-trade controls can lead to administrative action, consumer claims, contract termination, payment holds, listing suspension, and reputational loss. Cabinet Resolution No. (200) of 2025 sets a schedule of administrative violations and penalties under the 2023 Modern Technology-Based Trade Decree-Law. The Consumer Protection framework also provides administrative enforcement mechanisms.
Maintain an evidence file for each high-risk seller and product category. It should connect the approval decision to the licence, permit, listing content, disclosure version, payment and delivery terms, complaints, corrective action, and suspension or reinstatement decision. This record supports a proportionate response when a seller misrepresents its authority, product safety, origin, or performance.
Practical launch and review checklist
- Map the platform, seller, payment, logistics, advertising, and customer-support roles.
- Verify each seller’s identity, licence, address, bank details, authorised contact, and regulated-product approvals.
- Design Arabic-first listing, checkout, invoice, warranty, return, refund, and complaint disclosures.
- Document payment flows, settlement timing, refunds, chargebacks, fraud allocation, and safeguarding responsibilities.
- Publish clear rules for ranking, promotions, reviews, counterfeit reports, recalls, suspension, and appeal.
- Test delivery, return, warranty, complaint, and refund journeys with real evidence and timestamps.
- Limit seller access to consumer data and maintain consent, opt-out, retention, and incident processes.
- Monitor licence expiry, complaints, refunds, chargebacks, product removals, and repeat misrepresentation.
- Review material changes against Federal Law No. (15) of 2020, Cabinet Decision No. (66) of 2023, and Federal Decree-Law No. (14) of 2023.
How HZ Legal can help
Hossam Zakaria Legal Consultancy can assist with UAE marketplace role mapping, seller and product onboarding terms, consumer disclosures, Arabic contract review, payment and logistics allocation, complaint and refund procedures, data-use controls, enforcement response, and launch-readiness audits. Visit HZ Legal to discuss your marketplace model.
Official sources and verification
- UAE Government consumer protection guidance, including the Consumer Protection Law, consumer rights, supplier duties, e-commerce disclosures, privacy, invoices, and complaint principles.
- UAE Government eCommerce guidance, including Federal Decree-Law No. (14) of 2023 and the expectations for digital businesses, secure infrastructure, accurate information, approvals, and digital invoices.
- UAE Legislation portal, for the current official text of Federal Law No. (15) of 2020 on Consumer Protection, Cabinet Decision No. (66) of 2023, and Federal Decree-Law No. (14) of 2023 on Modern Technology-Based Trade.
- UAE Legislation portal, for Cabinet Resolution No. (200) of 2025 on the schedule of administrative violations and penalties under the Modern Technology-Based Trade Decree-Law.
Editorial verification before publication: Confirm the current Arabic text, implementing decisions, licensing requirements for the proposed payment model, sector approvals, VAT treatment, consumer-remedy rules, and any regulator or payment-network notices. The correct allocation of liability depends on the platform’s contracts, representations, data flows, and operational control.
Prepared on 9 October 2026. General legal information, not advice on a particular marketplace or transaction.