Fundraising UAE: Permits, Online Campaigns & Criminal Risk

Fundraising in the UAE is regulated far more tightly than many businesses, community groups and social-media users expect. A campaign may begin with a simple idea—help a family in need, raise money for medical treatment, collect funds after a disaster, add a charity link to an event, ask customers to donate at checkout or invite followers to contribute through a social-media post. But once money or property is being collected for charitable or humanitarian purposes, the activity can fall within the UAE's statutory donation regime.

The principal federal framework is Federal Law No. 3 of 2021 Regulating Donations, together with Cabinet Resolution No. 96 of 2022 as its Executive Regulation. The current enforcement framework also includes Cabinet Resolution No. 160 of 2025, which introduced a detailed schedule of administrative violations and penalties for breaches of the Donations Law and its Executive Regulation.

The system is built around a clear policy: donations should move through licensed or expressly permitted entities, through approved collection channels, with identifiable beneficiaries, bank-account controls, reporting, recordkeeping and regulatory supervision.

This means that a good cause does not itself create legal authority to collect money.

The Donations Law applies broadly

Article 2 of Federal Law No. 3 of 2021 applies to any party wishing to collect or provide donations in the UAE, including free zones.

The statutory definition of donations is broad. It covers money or property collected for charitable or humanitarian purposes, whether cash or in kind, movable or immovable, and expressly includes forms such as national or foreign currency, securities, sukuk and shares. The definition also recognises electronic and digital forms.

Accordingly, the legal analysis should focus on the substance of the activity rather than the technology used to receive the contribution. A QR code, payment link, crowdfunding page, social-media campaign, checkout donation option or digital wallet does not sit outside the Donations Law merely because no physical cash changes hands.

Individuals cannot simply collect charitable donations

Article 6 contains one of the most important rules in the framework: a natural person is prohibited from collecting donations.

This applies even where the individual intends to pass every dirham to a deserving beneficiary and keeps nothing personally.

Common high-risk examples include:

an individual posting a personal bank account for emergency medical donations;
an influencer asking followers to transfer money for a family in distress;
a community organiser collecting cash at a private event;
an employee circulating an office collection for public charitable distribution;
a resident creating an online crowdfunding page for another person; or
a social-media user collecting for an overseas disaster appeal.

The lawful route is generally to work through a properly licensed charitable entity and, where required, obtain the relevant fundraising permit.

Legal persons also need authority to fundraise

Article 6 also prohibits organisations from establishing, organising or carrying out fundraising activity unless they are already among the entities authorised by law to collect donations or have obtained a permit from the competent authority.

Article 7 makes the structure more specific. A permit applicant must be a legal person, and the fundraising must be carried out through a charitable association.

The permit application must identify matters including:

the purpose of fundraising;
the persons responsible for the campaign;
the beneficiary or beneficiaries;
the means of fundraising;
the places where funds will be collected;
the duration of fundraising;
the period for delivering donations to beneficiaries;
proof of the charitable association's approval; and
the administrative or operational expense percentage where applicable.

A commercial company, school, event organiser, sports club or other legal person should therefore not assume that its ordinary institutional or trade licence gives it authority to collect charitable funds.

Permits are campaign-specific

The permit is not a general licence to collect donations whenever the organisation chooses.

Article 9 requires the competent authority to consider the completed application through the statutory approval process. Article 10 also limits the number of permits that may ordinarily be issued to one party in a year unless the head of the competent authority approves otherwise.

Permit conditions matter because the campaign is expected to operate only within the authorised purpose, duration, collection methods, locations and beneficiary structure.

When the permit expires, or when the campaign reaches its permitted target amount where applicable, collection must stop and related advertising must be removed in accordance with the Executive Regulation.

Online fundraising is expressly regulated

Cabinet Resolution No. 96 of 2022 removes any doubt that digital fundraising falls within the regulated system.

Article 10 of the Executive Regulation lists fundraising methods that may be used after competent-authority approval, including:

cash boxes and donation receipts;
SMS;
charitable events, markets, exhibitions and auctions;
recurring deductions from personal accounts;
fundraising bank accounts;
marketing and promotional offers linked to donation requests;
ATMs of licensed banks;
approved digital fundraising platforms;
social media;
direct bank deposits; and
other media channels.

The rule is therefore not that online fundraising is prohibited. The rule is that online fundraising must occur through approved structures and channels.

A crowdfunding platform does not replace the permit

Using a sophisticated online platform can reduce payment and fraud risk, but platform technology is not itself regulatory permission.

Before launching a campaign, the organiser should establish:

who is legally collecting the donation;
which competent authority has approved the campaign;
which licensed charity is involved;
whether the digital platform is approved for fundraising;
which bank account receives the money;
how the beneficiary is identified and verified; and
how the campaign will close when the permit or target ends.

A payment page should be the execution layer of a lawful campaign, not the legal basis for the campaign itself.

Social-media appeals can create direct risk

Social media is specifically listed in the Executive Regulation as a possible approved fundraising method.

Many unplanned campaigns begin with a viral post about a medical emergency, accident, family crisis or disaster. The Donations Law does not create a social-media exception for compassionate motives.

Where a post goes beyond awareness and becomes a request to collect or route donations, the organiser should first ensure that the campaign sits within a licensed and permitted fundraising structure.

Advertising needs separate approval

Article 31 of the Donations Law provides that authorised parties may not publish or broadcast fundraising publicity or advertising without competent-authority approval.

Article 23 of the Executive Regulation expands the advertising concept to include traditional media, telephone calls, letters requesting donations, websites, publication of fundraising bank-account numbers and approved digital platforms.

A permit to collect therefore does not necessarily mean the organiser may advertise the campaign in any format it chooses.

Campaign copy, graphics, beneficiary claims, QR codes, account details, influencer content and promotional mechanics should be checked against the approval granted by the competent authority.

Bank accounts are part of the compliance architecture

Article 17 requires permitted entities to open one or more fundraising current accounts with national banks operating in the UAE and to notify the competent authority of the bank and account details within the statutory period.

This supports traceability and helps separate charitable funds from ordinary operating revenue.

A company should therefore avoid receiving donations into an employee's personal account, a founder's private account, an unapproved corporate operating account or an overseas account that bypasses the permitted collection structure.

Large cash donations trigger additional controls

Article 21 of the Executive Regulation provides that cash donations may not exceed AED 10,000. Amounts above that threshold must move through specified traceable methods such as remittances, bank deposits or cheques, whether the money is being received from donors or delivered to beneficiaries.

This supports transparency and financial-crime controls. Even below the threshold, a licensed entity should preserve receipts and donor records in accordance with the applicable accounting requirements.

Donor and beneficiary data must be traceable

The Donations Law and Executive Regulation require licensed and permitted entities to maintain systems and records concerning fundraising activity.

The Executive Regulation requires relevant records to contain information concerning donation sources, proceeds, purpose, expenditure methods and beneficiaries and generally requires records to be retained for at least 10 years, subject to the applicable controls.

Article 21 also requires systems capable of recording donor and beneficiary data, including identification and contact information in the circumstances specified by the Regulation.

This recordkeeping supports donor protection, beneficiary verification, regulatory audit, financial-crime controls, prevention of duplicate aid, campaign reconciliation and proof that funds reached the authorised purpose.

The money must be used for the permitted purpose

Fundraising compliance does not end when the donation is received.

One of the most serious offences under Article 36 is using donation funds for a purpose other than the purpose for which they were accepted or collected.

A campaign approved to fund medical treatment should therefore not redirect surplus funds to an unrelated cause simply because the alternative cause is also charitable. The competent authority should be consulted on excess proceeds or changed circumstances.

Corporate sponsorship and charitable donations are not always the same thing

Businesses frequently support events, charities and community campaigns through sponsorship.

A genuine commercial sponsorship may involve payment in return for event naming rights, logo placement, advertising exposure, hospitality rights, digital promotion, brand integration or other measurable commercial benefits.

Where the payment is genuinely made under a commercial exchange for promotional rights or services, it is not automatically a charitable donation merely because the sponsored event has a social purpose.

However, labels are not decisive. If a “sponsor” is actually contributing money to be collected or distributed for charitable or humanitarian assistance, or if the company is soliciting third-party donations as part of the sponsorship campaign, the Donations Law may apply.

Calling a payment “sponsorship” does not remove fundraising regulation where the substance of the arrangement is collection of donations for charitable or humanitarian purposes.

Cause-related marketing needs careful structuring

Commercial promotions increasingly promise that part of each sale will go to charity—for example, “AED 5 from every order will be donated”.

The Executive Regulation expressly recognises marketing and promotional offers accompanied by donation requests as a regulated fundraising method.

Before launching cause-related marketing, the company should establish:

the licensed charity involved;
the permit or approval required;
the exact amount or percentage donated;
whether the customer is making the donation or the company is funding it from its own revenue;
how the promotional claim will be verified;
which account receives the donation component;
the campaign start and end dates; and
how final donation amounts will be reconciled.

The distinction between a company donating its own money and a company collecting money from customers is especially important.

A company's own charitable contribution is different from public fundraising

A company can choose to support a charity from its own corporate funds, subject to the charity's ability to receive the contribution and other applicable rules.

That is legally different from inviting customers, employees or the public to provide money to the company for onward donation. The second structure creates collection and custody issues and can bring the activity directly within the Donations Law.

Charity events remain regulated even when fundraising is incidental

A gala dinner, concert, sports event, auction, market or community festival can become a fundraising event even where entertainment is the main attraction.

The Executive Regulation expressly lists charity events, exhibitions and auctions among permitted fundraising means.

In Dubai, IACAD's current charitable-event service confirms that approval is required to set up a charitable event or collect donations through accredited charitable institutions. The service also identifies supporting documents such as the organiser's trade licence and sample advertising material, and notes that other approvals may be required for certain public or hotel events.

Dubai has an additional local regulatory layer

Dubai's Islamic Affairs and Charitable Activities Department (IACAD) supervises charitable activities in the emirate.

Current IACAD communications emphasise licensed digital donation channels and the MUSARRAH authorised mark for charitable events and activities that have obtained the required permits.

IACAD reported that licensed digital channels processed more than AED 530 million in donations during the first half of 2026, illustrating both the scale of digital giving and the regulator's focus on authorised channels.

Organisers in other emirates should identify the equivalent competent local or federal authority rather than automatically applying Dubai procedures nationwide.

Sending donated funds outside the UAE is separately controlled

Article 14 prohibits delivery, provision or transfer of donations to persons or entities outside the UAE except in accordance with the procedures and controls prescribed by the Executive Regulation.

Article 15 further restricts banks and financial institutions from making transfers abroad from donation accounts except in accordance with procedures required by the relevant UAE authorities.

This is particularly important for disaster appeals, refugee assistance and overseas humanitarian campaigns. A UAE organiser should not simply collect locally and then wire money to an overseas individual, NGO or crowdfunding account.

Cross-border campaigns require beneficiary verification

Overseas giving creates additional risks involving beneficiary identity, sanctions exposure, terrorist-financing controls, intermediary organisations, proof of receipt, foreign banking restrictions, delivery of in-kind aid and documentation that the aid reached the authorised beneficiaries.

The donations framework specifically expects evidence that overseas donations are delivered to beneficiaries or spent for the approved purpose.

Trading or speculating with donation money is prohibited

Article 20 prohibits licensed and permitted entities from trading donated funds, entering into financial speculation with them or distributing investment returns to members or employees.

The same Article also prohibits fundraising or donation activity that harms public order, national security or public morals or encourages prohibited sectarian, ethnic, racial, religious or cultural conflict.

Donation money therefore cannot be treated as treasury capital that the organiser is free to invest aggressively while waiting to distribute it.

Zakat now has an additional dedicated legal framework

Organisations handling Zakat should also consider Federal Law No. 4 of 2025 Regarding the National Zakat Platform.

The law applies to receiving, collecting and distributing Zakat in the UAE, including financial and non-financial free zones.

Article 4 prohibits legal persons from receiving, collecting or distributing Zakat without a permit and limits natural-person collection to the controls to be prescribed by the competent authority.

The law also creates the National Zakat Platform as a unified digital system for authorised entities, eligible categories and collected and distributed Zakat funds.

An entity should therefore not assume that a general charitable donation structure automatically resolves all Zakat-specific requirements.

Administrative penalties were strengthened in 2025

Cabinet Resolution No. 160 of 2025 introduced a detailed schedule of administrative violations and escalating penalties under the Donations Law.

The schedule covers continuing fundraising after a permit expires or the target amount is reached, failure to provide required reports, failure to maintain electronic records, failure to comply with permit conditions, late delivery to beneficiaries, donation-box violations and obstruction of regulatory inspection.

For example, continuing fundraising after permit expiry can escalate to an administrative fine of AED 50,000 and suspension of fundraising activity under the 2025 schedule. Other reporting and compliance breaches carry their own escalating sanctions.

Criminal risk for unlawful fundraising is substantial

The Donations Law contains criminal penalties in addition to administrative sanctions.

Article 36 provides that a person who violates Article 6—including the prohibition on natural-person fundraising and organisational fundraising without the required authority—or specified other core provisions can face imprisonment and a fine of not less than AED 150,000 and not more than AED 300,000, or either penalty.

The same penalty tier applies to using donated funds for purposes other than those for which they were accepted or collected. The penalty is doubled for repeat offending.

Certain prohibited uses carry an even higher penalty

Article 36 also provides a higher penalty for violation of Article 20(1), which prohibits trading or speculating with donation funds or distributing returns to members or employees.

The penalty is imprisonment and a fine from AED 200,000 to AED 500,000, or either penalty, with doubling for repeat offending.

In criminal cases under the Donations Law, the court may also order confiscation of donations collected in violation of the law. The statute further provides for deportation of a foreign offender after execution of the sentence.

Managers can be personally exposed

Article 37 addresses the person responsible for the actual management of a licensed or authorised entity.

A responsible manager can face the same penalty where it is proven that the manager knew of the offending conduct or where failure to perform management duties contributed to the offence.

This can be important for general managers, charity directors, finance heads, campaign managers, event organisers and senior personnel approving collection channels.

A practical campaign classification matrix

Activity	Key compliance question
Individual asks followers to transfer money to a personal account for a beneficiary	Natural-person fundraising is prohibited; use an authorised charitable channel instead.
Company launches a public charity campaign	Is there a permit and licensed charity handling the fundraising?
Influencer shares an approved charity link	Is the publicity part of an approved campaign and compliant with advertising conditions?
Brand pays for event naming rights	Is this genuinely commercial sponsorship, or is the payment substantively a charitable donation?
Retailer says AED 5 from each sale goes to charity	Determine whether the company is donating its own funds or collecting donations from customers and obtain appropriate approval.
Online platform hosts a medical appeal	Confirm the legal collector, charity partner, permit, approved digital channel and beneficiary verification.
UAE campaign sends funds overseas	Follow the statutory outbound-transfer controls and proof-of-delivery requirements.
Organisation collects Zakat	Check the Donations Law plus the National Zakat Platform regime.

Practical checklist before launching a fundraising campaign

Classify the payment. Donation, sponsorship, ticket revenue, corporate gift or customer-collected contribution?
Identify the legal collector. Never assume the promoter or organiser may receive the funds directly.
Select the licensed charity. Obtain its written agreement to participate.
Apply to the competent authority. Include purpose, beneficiary, collection methods, duration and campaign managers.
Approve advertising. Clear social-media posts, bank details, QR codes, influencer scripts and event materials before publication.
Use approved channels. Bank accounts, digital platforms, boxes, SMS or events should match the permit.
Segregate funds. Do not mix donations with ordinary operating income.
Control cash. Respect the AED 10,000 cash threshold and maintain receipts.
Verify beneficiaries. Preserve identity and eligibility evidence.
Maintain records. Donor, beneficiary, collection and disbursement records should be auditable.
Track permit expiry and target. Shut down collection and advertising when required.
Control cross-border transfers. Do not send donation funds abroad outside the approved process.
Reconcile final proceeds. Confirm the amount collected, authorised expenses and amount delivered.
Escalate changes. New beneficiary, changed purpose or excess funds should be referred to the competent authority.
Train marketing and finance teams. Fundraising breaches often begin with an advertising or payment decision made before legal review.

Key takeaway

Fundraising in the UAE is a regulated activity, not simply a matter of charitable intention. Federal Law No. 3 of 2021 prohibits natural persons from collecting donations and requires organisations outside categories already authorised by law to obtain a fundraising permit through the competent authority and operate through a charitable association.

Digital activity is fully within the framework. Social media, online platforms, SMS, direct bank deposits, fundraising accounts and cause-related promotions are all expressly contemplated as regulated fundraising methods. Advertising itself also requires approval.

Businesses should distinguish carefully between genuine commercial sponsorship and charitable collection. A sponsor purchasing advertising or brand rights is not necessarily making a regulated donation, but using sponsorship terminology cannot disguise an arrangement whose real purpose is the collection or onward distribution of charitable funds.

Enforcement risk is significant. The 2025 administrative sanctions framework adds escalating fines and suspension measures, while core criminal breaches—including unauthorised fundraising and misuse of donated funds—can attract imprisonment, substantial fines, confiscation and, for foreign offenders, deportation after sentence.

HZ Legal can assist charities, companies, schools, event organisers, digital platforms, influencers and sponsors with UAE fundraising permits, charity partnerships, campaign terms, sponsorship structuring, digital donation channels, advertising approval, cross-border giving, Zakat compliance and investigations involving alleged fundraising violations.

Official and authoritative sources

This article provides general legal and regulatory information only and does not constitute legal, tax, AML or financial advice. Fundraising requirements depend on the identity of the organiser, purpose, beneficiary, emirate, collection channel, advertising method, charity partner, source and destination of funds and any sector-specific rules. A campaign should be reviewed before donations are solicited or collected, particularly where social media, overseas beneficiaries, commercial promotions or personal accounts are involved.