AutoSmart GuidebooksWhat this guidebook covers
Under the Commercial Agencies Law (Federal Law 3/2022, in force since June 2023), agency activity is reserved for UAE nationals, agencies must be registered with the Ministry, and agents must provide spare parts and after-sales service. An unregistered agency isn't legally recognised.
This guidebook covers the 5 agency standards with 15 checkpoints: registration with MoET, national ownership, spare parts, the after-sales and warranty network, and handling agency changes lawfully.
The 5 agency standards
Open a standard to see the law behind it, what is checked, what it can cost and the evidence. Ideal fix times are counted from audit submission.
AG-01Agency registered with MoET30 days
- The law
- Federal Law No. 3 of 2022 Regulating Commercial Agencies (in force 16 Jun 2023) · Cabinet Decision No. 89 of 2023 (penalties) · Federal Law 3/2022: agencies must be registered in the Ministry's register to be recognised
- What we check
- Every brand the dealer distributes as agent is registered in the Ministry's commercial agency register, with the registration current and matching the agency contract.
- What it can cost
- Operating without approvals is fined from AED 5,000 up to AED 400,000, and the agency isn't legally protected.
- Evidence
- Register extracts + contracts
AG-02UAE national ownership maintained30 days
- The law
- Federal Law No. 3 of 2022 Regulating Commercial Agencies (in force 16 Jun 2023) · Cabinet Decision No. 89 of 2023 (penalties) · Federal Law 3/2022: agency activity reserved to UAE nationals and companies wholly owned by nationals (or PJSCs with 51% national capital)
- What we check
- The company holding the agency meets the ownership rule: wholly owned by UAE nationals, or a public joint-stock company with at least 51% national ownership, and changes are monitored.
- What it can cost
- Ownership breaches are fined up to AED 400,000 and can lead to licence revocation.
- Evidence
- Shareholder register
AG-03Spare parts available7 days
- The law
- Federal Law No. 3 of 2022 Regulating Commercial Agencies (in force 16 Jun 2023) · Cabinet Decision No. 89 of 2023 (penalties) · Federal Law 3/2022 agent obligations to provide spare parts and after-sales service · Consumer Protection Law
- What we check
- The agent keeps spare parts available for the models it sells for the period the law and warranty require, and supplies them within a reasonable time and at reasonable prices.
- What it can cost
- Parts failures can bring agency penalties and consumer fines of AED 100,000+ per case.
- Evidence
- Parts KPIs
AG-04After-sales and warranty network30 days
- The law
- Federal Law No. 3 of 2022 Regulating Commercial Agencies (in force 16 Jun 2023) · Cabinet Decision No. 89 of 2023 (penalties) · Federal Law 3/2022 after-sales service obligations
- What we check
- The agent provides maintenance and warranty service across its territory, with workshops, trained technicians and tools for the brands it sells.
- What it can cost
- Poor after-sales can bring agency fines and repeated consumer fines of AED 300,000+.
- Evidence
- Network map + training
AG-05Agency changes handled lawfully30 days
- The law
- Federal Law No. 3 of 2022 Regulating Commercial Agencies (in force 16 Jun 2023) · Cabinet Decision No. 89 of 2023 (penalties) · Federal Law 3/2022 termination, non-renewal and the Commercial Agencies Committee
- What we check
- Terminations, non-renewals and disputes follow the law: correct notice, the transition protections, and referral to the Commercial Agencies Committee or arbitration, with no disruption to customers.
- What it can cost
- A wrongful termination can bring compensation claims worth years of agency income.
- Evidence
- Termination files
How to run a UAE commercial agency compliance audit, step by step
- Confirm what applies. List every brand and territory the group holds, and check each against the MoET agency register.
- Walk the site, standard by standard. Score each of the 15 checkpoints Pass, Fail or N/A. N/A only where the standard rules it out, with the reason recorded. Compare the register entry with the agency contract, and check parts availability for a sample of models.
- Capture the evidence. A pass counts only with proof captured at the time of the audit: the MoET registration, ownership records, parts availability reports and service network listings.
- Give every fail an owner and a fix time. Record what you saw and who owns the fix. Each standard carries an ideal fix time, from 7 days to 30 days, counted from audit submission (see the table above).
- Fix it, then prove it. The site fixes the cause and uploads proof of closure; the auditor checks the proof before closing the finding.
- Re-check at the next audit. Confirm closed findings stay closed, and look for the same fail at your other sites so one gap doesn't repeat across the network.
Who this guidebook is for
- Dealer principals and GMs
- After-sales and parts managers
- Auditors
A reference document, not legal advice. Fines and rules change: check the current text with the regulator or your legal adviser before acting.
