The UAE's introduction of Federal Law No. 4/2012 (the “Competition Law”) hailed an important landmark in the legislative history of the UAE. It was the first specific competition law in the country. The Competition Law set the expectation for future ancillary legislation which would add important detail to some of the provisions of the Competition Law. The ancillary legislation has now been introduced but significant areas of uncertainty remain.

Before the enactment of the Competition Law, the UAE had laws which addressed anti-competitive behaviour in certain sectors and had undertaken some consumer protection reform to discourage monopolistic practices and encourage consumer confidence through some market liberalisation. It was common, although technically inaccurate, for businesses to assume that the UAE had no competition law. The Competition Law changed this perception.

Three key areas of European-style competition law were introduced by the Competition Law, namely, provisions to address:

• restrictive agreements;

• abuses of a dominant position; and

• merger control.