AutoSmart GuidebooksWhat this guidebook covers
The 2023 Competition Law bans price-fixing, market sharing, bid rigging and abuse of dominance. With the executive regulations issued in April 2026, the Ministry has a full framework to enforce it: fines up to 10% of annual UAE sales, closure of the establishment and publication of the judgment.
This guidebook covers the 6 competition standards for UAE dealers and agents, with 14 checkpoints, including notifying deals before closing.
The 6 competition 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.
CM-01No price-fixing between dealersImmediate
- The law
- Federal Decree-Law No. 36 of 2023 Regulating Competition · Cabinet Decision No. 59 of 2026 (Executive Regulations) · FDL 36/2023 prohibited agreements: fixing prices, discounts and terms
- What we check
- Dealers never agree with competitors on car prices, discounts, trade-in values, service rates or fees.
- What it can cost
- Up to 10% of annual UAE sales, closure for up to 6 months and a published judgment.
- Evidence
- Training + contact log
CM-02No market sharingImmediate
- The law
- Federal Decree-Law No. 36 of 2023 Regulating Competition · Cabinet Decision No. 59 of 2026 (Executive Regulations) · FDL 36/2023 prohibited agreements: sharing markets, customers or territories
- What we check
- Dealers never agree with competitors to split emirates, customers or fleet accounts.
- What it can cost
- Up to 10% of annual UAE sales.
- Evidence
- Bid records
CM-03No bid riggingImmediate
- The law
- Federal Decree-Law No. 36 of 2023 Regulating Competition · Cabinet Decision No. 59 of 2026 (Executive Regulations) · FDL 36/2023 prohibited agreements: collusive tendering
- What we check
- Government and corporate fleet tenders are prepared without contact with other bidders.
- What it can cost
- Up to 10% of sales, and possible exclusion from government tenders.
- Evidence
- Tender files
CM-04No abuse of dominance30 days
- The law
- Federal Decree-Law No. 36 of 2023 Regulating Competition · Cabinet Decision No. 59 of 2026 (Executive Regulations) · FDL 36/2023 abuse of a dominant position
- What we check
- Where an agent or group is dominant for a brand's parts or service, it doesn't refuse supply, discriminate on price or impose unfair conditions on independent workshops or dealers.
- What it can cost
- Abuse of dominance: up to 10% of annual UAE sales.
- Evidence
- Policy + refusal log
CM-05No sensitive information exchange30 days
- The law
- Federal Decree-Law No. 36 of 2023 Regulating Competition · Cabinet Decision No. 59 of 2026 (Executive Regulations) · FDL 36/2023 agreements and concerted practices
- What we check
- At industry meetings and events, no one shares future prices, margins, stock or staff pay with competitors.
- What it can cost
- Treated as a prohibited agreement: up to 10% of sales.
- Evidence
- Minutes
CM-06Deals notified before closing30 days
- The law
- Federal Decree-Law No. 36 of 2023 Regulating Competition · Cabinet Decision No. 59 of 2026 (Executive Regulations) · FDL 36/2023 economic concentration notification · CD 59/2026
- What we check
- Acquisitions of dealerships, agencies or workshops are checked against the notification thresholds and, if required, notified and cleared before completion.
- What it can cost
- 2-10% of revenue, or AED 500,000-5,000,000 where turnover can't be set.
- Evidence
- Deal files
How to run a UAE competition law compliance audit, step by step
- Confirm what applies. Identify where staff meet or message rivals (dealer councils, trade events, chat groups) and which fleet tenders the group bids for.
- Walk the site, standard by standard. Score each of the 14 checkpoints Pass, Fail or N/A. N/A only where the standard rules it out, with the reason recorded. Review recent fleet tenders and pricing decisions, and ask managers about contact with competing dealers.
- Capture the evidence. A pass counts only with proof captured at the time of the audit: tender files, pricing approvals, the competition policy and training records.
- 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 immediate 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
- Sales and fleet managers
- Legal and compliance teams
- Auditors
A reference document, not legal advice. Fines and rules change: check the current text with the regulator or your legal adviser before acting.
