Dubai Healthcare City Authority – Regulatory (DHCR): complaints and investigations during the move to DHA licensing

DHCC is a free zone with its own authority, the Dubai Healthcare City Authority, whose regulatory arm is known as DHCR. For years DHCR licensed the healthcare professionals working there under the DHCC Healthcare Professionals Regulation No. 2 of 2013, made under Dubai Law No. 9 of 2011. That regulation set up DHCC's own complaints system, with a Customer Protection Unit, a Complaints Panel and a Fitness to Practice Panel.

Dubai Law No. 16 of 2024 Concerning the Dubai Healthcare City came into force on publication on 4 September 2024 and repealed Law No. 9 of 2011. Two provisions shape every DHCC case now:

• DHA licensing: Article 20(b) says no individual, establishment or company may conduct healthcare activity within the health sector of the emirate inside DHCC "unless they have obtained the relevant licences and permits from the DHA".
• Transitional rule: regulations made under the old law "continue in force to the extent that they do not contradict this Law, until new superseding resolutions … are issued".

DHCA Rule No. 1 of 2025, effective 2 May 2025, deals with commercial licensing in DHCC and requires a Clinical Operating Permit and DHA approvals. Dubai's Executive Council Resolution No. 49 of 2024, the framework under which the DHA disciplines its licensees, covers free zones "such as the Dubai International Financial Centre" but does not name DHCC.

Because DHCC is mid-transition, more than one set of rules may be relevant at once. Work out where you stand before you write a word of your response.

The Regulation, as still published on dhcc.ae, uses three defined terms that decide where a complaint goes (Art. 15):

• Inappropriate Professional Practice: providing healthcare services "below the Required Standard of Competence", with examples in Schedule Three.
• Professional Misconduct: "conduct that constitutes improper or inappropriate conduct affecting his provision of Healthcare Services" or compliance with the regulations, with examples in Schedule Four.
• Fitness to Practice: having met, and continuing to meet, the Required Standard of Competence, and not engaging in Professional Misconduct.

Who reports

Patients complain, but the Regulation also builds in reporting from inside the system. A manager of a licensed healthcare operator, a licensed healthcare professional or the authorised representative of an employing entity must notify the CPU of practice below the required standard (Art. 72). A case can therefore start with a colleague or a line manager rather than a patient.

What the CPU does

1. Makes a preliminary assessment and classifies the concern (Arts 73 and 76(1)).
2. Sends you the complaint and requires your written explanation "within a stipulated time" (Art. 76(2)).
3. Sends the complaint and your explanation to an expert for an opinion on whether an offence is disclosed (Art. 76(3)).
4. Decides: refer to the Fitness to Practice Panel; or, where the opinion discloses no misconduct offence, issue advice, require a Competence Program, require medical or psychiatric treatment or reporting on fitness; or dismiss the complaint for lack of evidence (Art. 76(4)).
5. Tells both sides how the complaint was classified and what it will do "as soon as reasonably practicable" (Art. 76(7)).

Either you or the complainant may appeal the CPU's course of action to the chairperson of the Complaints Panel within 30 days. Orders do not take effect while that appeal is pending, and there is no further appeal from the chairperson's decision (Art. 76(8)). The CPU may also refer a case to mediation at any time, but mediation goes ahead only if both sides consent (Arts 76(5) and 77).

Interim orders

Where a complaint is classed as Professional Misconduct and there are reasonable grounds to believe you pose "an imminent risk of serious harm to the public", the CPU may ask the chairperson of the Complaints Panel to decide whether an interim order should be made, before or after the expert opinion (Art. 78). An interim order protects the public while the case continues; it is not a finding.

If a case reaches the Panel, the question is whether your fitness to practise is impaired (Art. 86). If the Panel finds that it is, it may make one or more of four orders (Art. 87):

Licensing decisions follow a separate route. If DHCC's Licensing Board refuses an application or attaches conditions, the Regulation provides an appeal to an Appeals Board within 30 days of receiving the notification, and no further appeal from the Appeals Board's decision (Arts 39, 40 and 44).

The 2013 Regulation names remediation directly. The CPU may require a professional whose practice falls below the Required Standard of Competence to complete a Competence Program (Art. 73(5)), "within such timeframe as may be specified by the CPU" (Art. 74). If the results are unsatisfactory, the CPU may refer the matter to the Fitness to Practice Panel (Art. 75), and the Panel can order a program itself (Art. 87).

A Competence Program is set by the regulator for your case. An online course you choose yourself is not a substitute for it, and you should never present one as if it were. Independent learning helps around the program instead:

• before it starts, to show the CPU you have begun to engage with the concern;
• alongside it, to cover related areas the program does not, such as communication or record keeping;
• afterwards, to keep the change going and to document it for a future licensing authority.

If you are unsure whether DHCR or the DHA would take anything into account alongside an ordered program, ask before you enrol in anything.

Whatever happens to DHCR's own procedures, the Medical Liability Decree-Law applies to "any person who practices the profession in the State" (Art. 2), so it reaches DHCC. That means:

• an alleged medical error is judged on the federal test in Article 6, and a gross medical error on the criteria in Cabinet Resolution No. 40 of 2019, Art. 5;
• compensation claims arising from medical liability are not accepted unless first referred to a Medical Liability Committee (Art. 18);
• either side may file a grievance against the committee's report within 30 days of notification, decided by the Supreme Committee of Medical Liability (Arts 20 and 21);
• a licence may be suspended for up to 30 days, renewable, while a report is pending (Art. 23);
• practice requires civil liability insurance with a UAE-licensed insurer, paid for by the facility owner (Arts 25 and 26), and DHCR's renewal guideline also asks for valid medical malpractice insurance.

Which health authority receives DHCC medical-error complaints and refers them to a Medical Liability Committee, DHCR or the DHA, is not confirmed. Your first notice should say; if it does not, ask.

Several published DHCR documents set specific duties. A breach can be raised as Professional Misconduct under the 2013 Regulation, so it is worth checking your practice against them now.

• Advertising: the DHCR Advertisement Policy and Procedure (PP/AD/001/01) requires approval for all medical advertisements, including social media, submitted 14 working days in advance and valid for six months. It bans false or misleading claims, patient photographs or videos without written consent, comparative or superiority claims, claims of effectiveness in all cases, claims to treat cancer, HIV/AIDS or mental illness, and content aimed at under-18s.
• Renewal: the licence runs for two years (Regulation No. 2 of 2013, Art. 46). Renewal needs the required CPD, valid medical malpractice insurance and a BLS certificate no more than two years old.
• Good standing: DHCR's licensing requirements ask for a good standing certificate issued within the last six months confirming the applicant "is not disqualified, suspended or prohibited".
• Time away from practice: DHCR's Gap in Clinical Practice policy (PP/HCO/003/02, revised 16 June 2023) sets CPD and supervised training for gaps of three to five years and treats a gap of more than five years as not eligible. If a case keeps you out of practice for a long time, ask how the gap rules would apply on your return.

The direction of the law is DHA licensing. Once you hold a DHA licence, the DHA's Standards for Code of Ethics and Professional Conduct for Health Professionals (Version 1, in force since 3 September 2025) apply to you, alongside its Fitness to Practice Policy. We found no named DHCR code of ethics; conduct in DHCC was framed by the 2013 Regulation's definitions. For anyone in DHCC who wants to show that their practice meets current expectations, the DHA's 12 standards are therefore the most useful benchmark.

• Declare your history: whether DHCC complaint history carries across to the DHA's records has not been confirmed. Declare any DHCC case honestly on every application; the national definition of good standing covers "pending or previous disciplinary orders".
• Where to read next: the DHA complaints and disciplinary guide for how the DHA handles cases, the DHA regulator guide for licensing and CPD, and the DHCR regulator guide for DHCC licensing and CPD.

Our courses are built for the situations described above: understanding the process, addressing the specific concern and showing insight. A sensible plan for most DHCC professionals is the Core Course for Healthcare Professionals Facing a Complaint, Investigation or Disciplinary Action, one course matched to the concern from the table above, and Developing Insight to connect the learning to your own case.