Dubai Health Authority (DHA) investigations and disciplinary action: what professionals face

The Dubai Health Authority's powers over the professionals it licenses now sit in one instrument: Executive Council Resolution No. 49 of 2024, issued on 28 August 2024, which replaced Resolution No. 32 of 2012. Article 4 tasks the DHA with investigating complaints against health professionals, including complaints passed to it by judicial bodies and government entities, auditing medical records, and referring Medical Liability Committee decisions, together with the patient's complaint, to the Medical Practices Committee. The Resolution reaches every health facility in Dubai, including Special Development Zones and free zones such as the Dubai International Financial Centre; federal government facilities are outside it.

In practice a single incident can run on two tracks at the same time:

• The medical liability track is federal and works the same way in every emirate. Where a patient alleges a medical error, the DHA refers the complaint to a Medical Liability Committee under Federal Decree-Law No. 4 of 2016, which decides whether an error occurred, whether it was gross, and whether it caused the harm.
• The disciplinary track is Dubai's own. The Medical Practices Committee decides whether you committed a violation listed in the Resolution and, if so, which penalty and which remedial measures follow.

The tracks inform each other but do not cancel each other out. Article 38 of the Medical Liability Law says criminal liability does not affect disciplinary liability, and Article 24 of Resolution No. 49 says an acquittal or a finding of no liability does not stop the DHA from imposing administrative penalties. A good result on one track is welcome, but it does not close the other.

Not every case begins with a patient. Concerns also come from the DHA's clinical audits of records, from inspections, and from the Health Regulation Sector's Fitness to Practice Policy (2025), which allows the DHA to suspend, restrict or revoke a licence where a professional's conduct or health puts safe practice in doubt.

Article 18 of the Resolution lists prohibited acts in two schedules. Schedule 4 holds 62 items that go before the Medical Practices Committee. Schedule 5 holds 61 lower-level items carrying fixed fines of AED 1,000 to 50,000, imposed by the Director General; repeat the same Schedule 5 violation within a year and the fine doubles and the case moves to the Medical Practices Committee (Articles 19 and 21).

The Schedule 4 items that individual professionals meet most often:

Item 19 reaches further than it looks. Because breaching the code of ethics is a violation in its own right, the DHA's Standards for Code of Ethics and Professional Conduct, in force since 3 September 2025, become the measure for conduct the schedules do not spell out: conflicts of interest, boundaries, social media, insurance claims. The DHA regulator guide summarises its 12 standards.

For a Schedule 4 violation, Article 19 gives the committee these options for an individual professional:

Remedial measures

Article 19(c) also lets the committee require the professional to:

• attend specific training courses within a specific time frame;
• work under the supervision of another health professional for a period of up to one year;
• be reassessed, with further action depending on the result of the reassessment.

Two further rules shape outcomes. Penalties do not have to be applied in sequence (Article 19(d)), so a first violation can lead straight to suspension if the committee considers it serious. And under Article 23, failing to remedy a violation within the time the DHA sets is a new violation, which can bring suspension until it is put right.

Two separate powers allow the authority to stop you practising before anything has been decided:

• Resolution No. 49 of 2024, Article 22: the Director General or the Medical Practices Committee may suspend a professional as a precautionary measure for up to three months pending investigation, extendable once for the same period with reasons. The DHA Manual (section 23.2) names risk to patient safety, a discrepancy found in primary source verification, and action by another regulator as grounds.
• Federal Decree-Law No. 4 of 2016, Article 23: the health authority may temporarily suspend a licence while a Medical Liability Committee report is awaited, or while other violations are investigated, for up to 30 days at a time, renewable.

A precautionary suspension is neither a penalty nor a finding against you, and it can be challenged. A grievance goes in writing to the Director General, and the Medical Grievances Committee may stay a precautionary suspension on substantial grounds, deciding within three working days. Note the date you were told of the suspension, because the 30-day grievance window runs from notification.

A Medical Liability Committee report that is not challenged within 30 days becomes final and cannot then be challenged before any other authority (Article 20). The two 30-day windows are separate routes to separate committees: one disputes the finding of error, the other disputes the DHA's penalty. The DHA's published service catalogue describes the stages after a liability outcome only in summary, so rely on the notification you receive for the exact route and deadline, and take advice before the clock runs down.

1. Write down the dates. Record when the notice arrived, what it asks for and by when. Every grievance window above runs from notification, not from when you get round to reading it.
2. Tell your medical liability insurer and your facility. The profession may not be practised in the UAE without insurance against civil liability for medical errors, which the facility owner arranges and pays for (Federal Decree-Law No. 4 of 2016, Articles 25 and 26), and the insurer steps into the insured's rights and obligations (Article 27). Check your policy terms and your facility's claims process; many policies include access to legal advice.
3. Leave the record exactly as it is. Changing or deleting data in the medical file is Schedule 4 item 34, and the DHA Code forbids altering, falsifying or destroying records under any circumstance. A genuine correction goes through your facility's documented process, which keeps the original entry visible, dated and attributed.
4. Reconstruct the facts while memory is fresh. The committee works from the original medical file (Cabinet Resolution No. 40 of 2019, Article 10). Note who was present, the timings, the guideline or protocol you followed and why, and anything that is not in the notes.
5. Check who will judge the case. A committee member may not sit if related to a party up to the fourth degree, if working under a party's supervision, if they treated the patient for the same condition, or if you consulted them about the case (Article 12). Raise a conflict as soon as you see it.
6. Write a factual, professional response. Separate what happened, your clinical reasoning and what you have learned. Have your lawyer or insurer review anything in writing before it is sent, because the same document may be read in a civil claim.
7. Begin relevant learning early. Learning that starts after notification, linked to the specific concern, shows engagement; learning that starts after a decision can look reactive.

The DHA Good Standing Certificate is generated in Sheryan and reflects Medical Practices Committee and appeal decisions from the past ten years. Under appendix 3 of the DHA Manual for Licensing Healthcare Professionals, a Current Status Certificate is issued instead of a Good Standing Certificate when:

• an investigation or appeal is in progress;
• less than two years have passed since a warning or notice letter;
• less than two years have passed since a suspension or revocation;
• two years or more have passed since a suspension or revocation without reinstatement.

Two years or more after a warning, or after reinstatement following a suspension or revocation, the DHA issues a Good Standing Certificate with a disciplinary history statement. Because the national qualification requirements ask for a good standing certificate no older than six months when you apply for a licence elsewhere, an open DHA case can delay a move to Abu Dhabi or the Northern Emirates.

After revocation the route back is narrow: an application can be made only after two years from the decision date, the Medical Practices Committee reviews it, the licence returns at the same title and not higher, and adding or upgrading a licence category is not possible with a suspension or revocation history (Manual, section 24.2). Keep a structured record of what you learned and changed during that period; it is the evidence you will have to offer when you apply.

When the Medical Practices Committee requires training under Article 19(c), it decides the course content and time frame case by case. The DHA does not publish a list of approved external remediation courses, and none of the DHA documents reviewed for this guide names a specific ethics course. If training has been ordered, complete exactly what the decision specifies, and ask the DHA in writing before substituting anything else.

Where nothing has been ordered, voluntary learning can still help you show that the risk behind the complaint has been addressed. Relevance carries more weight than volume: learning aimed at the standard in question, a reflective account linking it to what happened, and evidence that your practice actually changed, such as a revised consent template, an audit of your own records or supervisor feedback.

Healthcare Practise courses are built for that purpose. They are not accredited by the DHA, do not award CPD points, and do not replace training the committee has ordered unless the DHA accepts them. Many DHA-licensed professionals begin with the 4-hour core course and add one topic course that matches the concern.