Can a Non-Doctor Own a Clinic in the UAE? Ownership and Medical Director Rules

What the law says about owners

Two federal texts apply in every emirate, including free zones:

• Federal Law No. 4 of 2015 on Private Health Facilities applies to "all private health facilities in the State, including free zones". It defines a private health facility as one owned or managed by a natural or legal person, so a company can own a clinic. It says a facility may only be managed by a qualified person, and leaves ownership terms to the executive regulations.
• Cabinet Resolution No. 29 of 2020, the executive regulations, sets the owner conditions. The owner must have no legal impediment to ownership. A company can own a facility if it takes a form allowed under the Commercial Companies Law (Federal Decree-Law No. 32 of 2021) and meets its ownership rules. The licence cannot be assigned to someone else without the health authority's written approval.

None of these conditions requires the owner to hold a medical degree. Dubai's licensing portal confirms that its owner guidelines are based on Cabinet Decision No. 29 of 2020 (DHA Sheryan FAQ).

One caveat: MOHAP's facility licence page for the Northern Emirates asks for "proof of owner qualifications" at the initial licence stage. Ask MOHAP what it expects for a non-clinical owner before you file.

The medical director requirement

This is the rule that matters for a non-doctor owner. Every licensed facility must have a director who carries clinical responsibility. Article 9 of the executive regulations, restated on MOHAP's technical director page, sets the minimum:

Each health authority can add requirements. If the director leaves, the owner must appoint a replacement and notify the authority within two weeks, or close the facility temporarily (Article 10).

Emirate rules on the medical director

• Dubai (DHA): the medical director must come from the facility's own licensed professionals, hold an active licence and not be medical director of another facility outside the same group. They may not be away from their duties for more than two weeks (DHA Manual for Licensing Health Facility). DHA's medical director policy makes them responsible for clinical governance, staff licensing, malpractice cover and every health advertisement the facility posts. An owner can be the medical director if they meet the licensing criteria.
• Abu Dhabi (DoH): the medical director's details must be kept current in TAMM. See how to open a clinic in Abu Dhabi.
• Sharjah (SHA): the final licence needs a licensed medical director and technical supervisor. Changing the director costs AED 1,000, and the new director cannot start until SHA approves.

In practice, a non-doctor owner hires a senior licensed doctor as medical director, pays them as a key employee, and gives them real authority over clinical and advertising decisions. Budget for this salary from day one; it is not optional.

Foreign ownership: mainland vs free zone

Being a non-doctor and being a foreigner are separate questions. Since amendments to the Commercial Companies Law took effect in 2021, mainland companies no longer automatically need an Emirati majority shareholder. Each emirate publishes which activities are open to full foreign ownership, and a federal list of "strategic impact" activities stays restricted. That federal list covers areas such as defence, banking, insurance and telecoms, and does not include healthcare (Covington).

Free zone status does not exempt you from health licensing. Federal Law No. 4 of 2015 covers free zones, and in Dubai, DHA licensing now applies in DHCC as well. Weigh DHCC against a neighbourhood location in our sibling guide DHCC or mainland Dubai.

Some Dubai licences use an Emirati local service agent who holds no shares; DHA's facility manual includes a procedure for changing the "Local Service Agent". Setup consultancies describe this mainly for professional licences held by individual practitioners. Treat that as indicative and confirm the structure with Dubai Economy and Tourism.

How non-doctor investors usually structure it

1. Company owns, doctors are employed. An LLC or free zone company owns the clinic. It employs a licensed medical director and clinicians. This is the cleanest model for investors.
2. Investor plus doctor partner. A doctor takes equity and serves as medical director. It aligns incentives, but write a shareholder agreement covering what happens if the doctor leaves, because you then have two weeks to replace the director.
3. Buy an existing clinic. You inherit the licence, staff and patients, but ownership changes need the authority's approval. SHA charges AED 3,000 to modify owners; in Abu Dhabi, changing a primary owner is treated as a new facility licence; DHA treats it as a paid amendment.

What a non-doctor owner must never do

• Let anyone practise before their licence is active. In March 2026 DoH closed five Abu Dhabi facilities, partly for employing unlicensed practitioners (DoH).
• Override clinical decisions or approve health ads yourself. In Dubai, the medical director must approve ads and influencer content that name the facility.
• Leave the director post empty. Two weeks is the federal limit.

Marketing before you open

As owner, you control the marketing budget, but your medical director signs off what the ads say. Agree that approval workflow before launch so campaigns are not stuck waiting on the first day. Our free launch plan sets out the build order, and marketing a new clinic: the first 90 days covers Google Business Profile, search campaigns, tracking and ad permits.

Frequently asked questions

Can a non-doctor open a clinic in Dubai?

Yes. DHA bases its owner rules on Cabinet Decision No. 29 of 2020, which does not require the owner to be a doctor. You must appoint a DHA-licensed medical director from the clinic's own staff who is not medical director of another facility outside your group.

Can the owner also be the medical director?

Yes, if the owner is a licensed professional who meets the medical director criteria. DHA's Sheryan FAQ says so directly.

Do I need an Emirati partner to own a clinic?

Not necessarily. Healthcare is not on the federal strategic impact list, and Dubai lists health activities as open to 100% foreign ownership. In the Northern Emirates, MOHAP needs a local authority letter setting the foreign ownership percentage. Free zones such as DHCC and SHCC allow 100% ownership.

Can a nurse or pharmacist own a clinic?

Ownership rules do not depend on profession. Who can direct the facility does: a physician for most clinics, or a qualified specialist professional for some outpatient, diagnostic and allied health units. A pharmacy needs a pharmacist in charge.

What happens if my medical director resigns?

You must appoint a replacement and notify the health authority within two weeks, or temporarily close. In Sharjah the new director cannot start until SHA approves the change.

Sources

• MOHAP: Federal Law No. 4 of 2015 on Private Health Facilities (Articles 1 and 2)
• MOHAP: Federal Law No. 4 of 2015 (Articles 3 to 7)
• UAE Legislation: Cabinet Resolution No. 29 of 2020 (executive regulations)
• MOHAP: Changing the technical director of a private medical facility
• MOHAP: Issue a Health Facility License
• DHA Sheryan: Frequently asked questions
• DHA: Manual for Licensing Health Facility (DHA/HRS/HLD/MA-1)
• DHA: Role and Responsibilities of Medical Director policy
• Sharjah Health Authority: Facility licensing services
• Abu Dhabi Media Office: DoH and foreign direct investment (July 2021)
• Gulf News: Activities that allow 100% foreign ownership
• Covington: UAE foreign investment liberalisation (strategic impact list)
• Sharjah Healthcare City: About
• DoH: Five facilities closed (March 2026)

Published 26 Oct 2026 · Access One