UAE edition · Independent education for MOHAP, DHA, DOH, SHA and DHCR licensed healthcare professionals

Guide · Complaints and investigations

Complaints and investigations against healthcare professionals in the UAE: the clinician's side

When a patient, a family member or an authority raises a concern about your practice, it can be examined by a Medical Liability Committee, by your licensing authority's disciplinary process, or both. This guide explains how that works across MOHAP, the DHA, the DOH, the SHA and DHCR, written for the healthcare professional on the receiving end.

How a concern about a clinician is examined in the UAE

The UAE has no single "fitness to practise" hearing of the kind some other countries use. A concern about a healthcare professional runs on separate tracks, and the same event can put you on two or three of them at once.

TrackThe question askedWho answers itMain rules
Medical liabilityWas there a medical error? Was it gross? What damage did it cause?The health authority's Medical Liability Committee; the Supreme Committee of Medical Liability on grievanceFederal Decree-Law No. 4 of 2016; Cabinet Resolutions No. 40 of 2019 and No. 14 of 2020
Disciplinary (licensing)Did the professional break the law, a code or a licence condition, and what penalty or measure follows?The licensing authority, through its committees (for example the DHA Medical Practices Committee)Federal Law No. 5 of 2019; Federal Law No. 6 of 2023; emirate rules in Dubai, Abu Dhabi and Sharjah
CriminalWas an offence committed?Public Prosecution and the courtsChapter V of the Medical Liability Decree-Law and other criminal laws
EmployerWere facility policies followed, and what happens to the employment?Your facilityYour contract and the facility's own policies

The tracks are linked but independent. Criminal liability does not remove disciplinary liability (Federal Decree-Law No. 4 of 2016, Art. 38), and in Dubai an acquittal does not stop administrative penalties (Executive Council Resolution No. 49 of 2024, Art. 24). Not every case starts with a patient: the DHA investigates complaints referred by judicial bodies and government entities and audits medical records (Art. 4), and in March 2026 the DOH suspended staff at five facilities, pending referral to the Public Prosecution, after finding sick-leave certificates issued without examination and manipulated medical records.

The legal detail of the liability track is in our guide to UAE medical liability law; this page follows the case from your side.

How the process usually runs

  1. Complaint reaches the authority

    A patient, relative or representative files with the health authority, usually online; courts and the Public Prosecution also pass medical-error cases to it.

  2. Screening and the medical file

    The authority separates administrative from medical complaints and obtains the original medical file; your facility may be asked to respond first.

  3. Committee review

    For a suspected medical error, a Medical Liability Committee hears the parties and witnesses and writes a reasoned report, due within 30 days of referral but often extended.

  4. Report and grievance window

    Both sides are notified and either can file a grievance with the Supreme Committee of Medical Liability within 30 days.

  5. Disciplinary decision

    The licensing authority decides any penalty or remedial measure under the profession law and its own rules, after hearing you.

  6. Grievance or return to practice

    A penalty can be challenged within the applicable deadline; any training, supervision or reassessment ordered must then be completed.

Which authority handles a complaint about you

A complaint is normally handled by the authority that licenses the facility where the care took place. Each one works differently; the summary below links to the detailed page for each.

AuthorityCoversHow complaints arriveDisciplinary route
Ministry of Health and Prevention (MOHAP)MOHAP-licensed private facilities in Sharjah, Ajman, Umm Al Quwain, Ras Al Khaimah and Fujairah, and federal facilitiesMOHAP website, app or customer service centres; service time 45 days under its complaint proceduresAdministrative complaints can go to the Health Practices Control Committee; medical complaints to the Medical Liability Committee, whose reports go to the Medical Licensing Committee for action
Dubai Health Authority (DHA)All health facilities and professionals in Dubai, including free zones such as DIFC; federal facilities excluded"Submit Medical Complaint" online, free, one to six monthsMedical Practices Committee; grievance to the Medical Grievances Committee
Department of Health – Abu Dhabi (DOH)Abu Dhabi, Al Ain and Al Dhafra"Investigation Request for Medical Error" online, free; investigations "might take months"Administrative penalties under Abu Dhabi Law No. 10 of 2018 and the disciplinary regulations of the Abu Dhabi healthcare sector
Sharjah Health Authority (SHA)Sharjah government health establishments and private facilities in the emirate and its free zones; federal facilities excludedAsk the SHA which channel applies to your facilityCommittees on accountability, medical practice and grievances under Executive Council Resolution No. 29 of 2025, amended in May 2026 to add administrative penalties
Dubai Healthcare City Authority – Regulatory (DHCR)The DHCC free zone, now moving to DHA licensing under Dubai Law No. 16 of 2024Confirm the current channel with DHCRDHCC Healthcare Professionals Regulation No. 2 of 2013, which provides for a Fitness to Practice Panel

Sharjah and DHCC are in transition. MOHAP's complaints service still lists Sharjah, while Sharjah Executive Council Resolution No. 29 of 2025 places private facilities in the emirate under the SHA. In Dubai Healthcare City, Dubai Law No. 16 of 2024 requires DHA licences and permits, but older DHCC regulations stay in force until replaced. If you work in either, confirm in writing which authority has opened the file before you respond.

The federal Medical Liability Decree-Law applies wherever you practise, so an alleged medical error always ends up before a Medical Liability Committee. Emirates Health Services, which runs federal government hospitals and clinics, is a healthcare provider and employer rather than a licensing authority; complaints about government hospitals are handled through it.

Who can complain, and what the committee will see

The federal rule (Cabinet Resolution No. 40 of 2019, Art. 8) is that a complaint goes to the competent health authority on paper or electronically, in Arabic or with a translation, stating its subject precisely, with supporting documents where possible and the details of the complainant and the patient. The complainant can amend it, withdraw it or add documents until the committee's report is issued.

  • MOHAP: a UAE citizen or resident who is a mentally sane adult above the legal age of 21, or the patient's guardian, family member or authorised representative, with the complaint form and relevant medical documents.
  • DHA: patients or care givers, whether UAE nationals, expatriates, residents or visitors, online and free of charge. The DHA service catalogue states that a complaint cannot be filed more than three years after the event.
  • DOH: patients or their authorised representatives, including first-degree relatives of a patient who has died, through the DOH complaint management system, with Emirates ID, any power of attorney or death certificate and medical reports if available. The DOH also publishes a user guide for healthcare professionals using the system.
  • Courts and prosecution: must pass medical-error cases, with their attachments, to the health authority.

The federal regulation sets no filing deadline, and the three-year limit is the DHA's own. A complaint can therefore reach you long after you have forgotten the patient, which is why the record you write today is your defence later.

Professional misconduct: what the rules actually prohibit

UAE legislation seldom uses the phrase "professional misconduct". The DHCC regulation is the exception: it defines "Professional Misconduct" as conduct that constitutes "improper or inappropriate conduct affecting his provision of Healthcare Services", and separates it from "Inappropriate Professional Practice", conduct "below the Required Standard of Competence". The other authorities work from lists of prohibited acts and violations. Common concerns that lead to action, and where the rules deal with them:

ConcernWhere the rules address it
Treatment, or an examination of a patient of the opposite sex, without consent or a third partyFederal Decree-Law No. 4 of 2016, Art. 5; Dubai Schedule 4, items 27 and 28
Disclosing patient secretsFederal Decree-Law No. 4 of 2016, Art. 5; Dubai Schedule 4, item 17
Changing or deleting data in the medical fileDubai Schedule 4, item 34; DOH action over manipulated records (March 2026)
Misuse of narcotic, controlled or semi-controlled prescriptionsDubai Schedule 4, item 47
Referral commissions, kickbacks, selling medicines or steering patients to a pharmacyFederal Law No. 5 of 2019, Art. 24
Practising outside the licensed scopeFederal Law No. 5 of 2019, Art. 24; DHA Fitness to Practice Policy
Self-advertising beyond what is regulatedFederal Law No. 5 of 2019, Art. 19
Breaching the code of ethics, or bringing a colleague into disreputeDubai Schedule 4, items 19 and 18
Personal or romantic relationships with current patients or their immediate familyDHA Standards for Code of Ethics and Professional Conduct, s.10.3.5
Insurance fraud and false claimsDOH sanctions have included exclusion from the Thiqa programme, fines, recovery of claims, licence restrictions and referral to the legal authorities
Dishonesty, fraud or substance misuseDHA Fitness to Practice Policy (2025), which lets the DHA suspend, restrict or revoke a licence

"Dubai Schedule 4" means Schedule 4 of Executive Council Resolution No. 49 of 2024, a list of 62 prohibited acts for which the Medical Practices Committee imposes penalties. Item 16 lists "committing a malpractice" as a violation, and the DHA refers Medical Liability Committee decisions to the Medical Practices Committee (Art. 4).

Disciplinary penalties compared

The penalty scale depends on your profession and on who licenses you. Under the federal profession laws no penalty may be imposed without hearing your statements and defence, but failing to attend without an acceptable excuse does not stop a decision (Federal Law No. 5 of 2019, Art. 28; Federal Law No. 6 of 2023, Art. 13). In Dubai, penalties need not be applied in sequence (Executive Council Resolution No. 49 of 2024, Art. 19(d)), so a first finding can lead straight to suspension.

RulesWho they coverPenalties and measures
Federal Law No. 5 of 2019, Art. 28Physicians and dentistsWritten notice; written warning; fine of AED 1,000 to 1,000,000; temporary suspension of up to one year; licence revocation
Federal Law No. 6 of 2023, Art. 13Nurses, midwives, allied health and other professions that are not physicians or pharmacistsWritten reprimand; written notice; fine of AED 1,000 to 50,000; temporary suspension of up to six months; partial revocation; revocation with removal from the register
Dubai Executive Council Resolution No. 49 of 2024, Art. 19 (Schedule 4)DHA-licensed health professionalsWritten warning; downgrading; suspension of up to one year; revocation; fine of AED 2,000 to 100,000; plus training courses, supervised practice of up to one year and reassessment
Dubai Schedule 5DHA licensees and facilitiesFixed fines of AED 1,000 to 50,000 set by the Director General; a repeat within a year doubles the fine (up to AED 200,000 for a professional) and goes to the Medical Practices Committee
Abu Dhabi Law No. 10 of 2018, Arts 11 and 12DOH licenseesNotice; warning; financial, administrative and technical supervision; temporary suspension of activity; suspension or cancellation of the licence; closure; fines of up to AED 10 million, which can be settled by paying 75% within 60 days
DHCC Healthcare Professionals Regulation No. 2 of 2013DHCR licenseesConditions; suspension; revocation; refusal to renew; competence programmes ordered by the Board
Sharjah Executive Council Resolution No. 29 of 2025, as amended in May 2026SHA licenseesAdministrative penalties were added in 2026; the official announcement does not list them, so ask the SHA for the current text

When a licence is revoked

  • Physicians and dentists (federal): a new licence may be granted once the grounds for revocation no longer exist (Cabinet Resolution No. 67 of 2020, Art. 8). After a suspension of three to twelve months the authority may re-evaluate competence or restrict clinical privileges or practice (Art. 7.2).
  • Nurses, midwives and allied health (federal): you may reapply once the grounds cease, and the authority can require mandatory training addressing the causes of revocation, a competence reassessment, a restricted scope of practice or practice under direct supervision for a set period; after a conviction involving honour or trust, proof of rehabilitation is needed (Cabinet Resolution No. 176 of 2025, Art. 11).
  • Dubai: a revoked licence can be reissued only after two years from the decision, on review by the Medical Practices Committee, at the same professional title and not higher; no additions or upgrades are allowed with a suspension or revocation history (DHA Manual for Licensing Healthcare Professionals, s.24.2).

What a case does to your good standing

  • National rule: the PQR defines a Good Standing Certificate as evidence that you have "not been found guilty of professional misconduct" and have no pending or previous disciplinary orders or criminal proceedings, and it must be no older than six months when you apply for a licence.
  • DHA: the certificate reflects Medical Practices Committee and appeal decisions from the past ten years. While an investigation or appeal is in progress, or within two years of a warning, suspension or revocation, a Current Status Certificate is issued instead; later, a certificate "with disciplinary history statement".
  • DOH: past or current suspensions, revocations, investigations and warnings are stated on the certificate.
  • MOHAP: no certificate is issued to a person sentenced for a medical offence.

Moving emirate does not leave a case behind. The DHA can impose a precautionary suspension where another regulator has taken action (DHA Manual, s.23.2), and every new licence application needs a current Good Standing Certificate.

Interim suspension before any finding

An interim suspension is a protective step, not a verdict, but it stops you working. Treat it as urgent and take advice the same day.

PowerHow longWhat to know
Federal Decree-Law No. 4 of 2016, Art. 23 (all emirates)Up to 30 days, renewable for similar periodsWhile a medical-error report is pending or other violations are investigated
Dubai Executive Council Resolution No. 49 of 2024, Art. 22Up to 3 months, extendable once for the same period, with reasonsOrdered by the Director General or the Medical Practices Committee; the Medical Grievances Committee can stay it on substantial grounds, deciding within 3 working days
DHA Manual for Licensing Healthcare Professionals, s.23.2Until the concern is resolvedPrecautionary suspension where there is a risk to patient safety, a discrepancy in primary source verification, or action by another regulator
DOHPending investigation or referralThe DOH suspends staff as a precautionary step, and a suspended DOH licence cannot be renewed

Check your licence expiry date as soon as a suspension starts and ask your authority, in writing, how the suspension affects renewal.

Grievance deadlines you cannot miss

"Grievance" is the statutory word for challenging a report or a penalty (the DOH's service calls it an "appeal request"). Deadlines are short and run from the date you were notified, so ask for written proof of that date.

Decision challengedDeadlineDecided byTime to decide
Medical Liability Committee report (all emirates)30 days from legal notificationSupreme Committee of Medical Liability, through the health authority30 days from referral, extendable; final
DOH medical-error report (appeal request)30 days from receiving the report; fee AED 5,000Higher Medical Liability Committee at MOHAPNo fixed time frame
Penalty on a physician or dentist (Federal Law No. 5 of 2019, Art. 29)15 days from notificationComplaints committee at the health authority30 days; no reply means rejection; final
Penalty on a nurse, midwife or allied health professional (Federal Law No. 6 of 2023, Art. 14)15 daysThe Minister or the head of the health authority30 days; no reply means rejection; final
Refusal, revocation or non-renewal of such a licence (Cabinet Resolution No. 176 of 2025, Art. 6)15 daysThe licensing authority30 days; no reply means rejection; final
DHA decision or measure (Executive Council Resolution No. 49 of 2024, Arts 25 and 26)30 days, in writing to the Director GeneralMedical Grievances Committee30 days; final
DOH administrative penalty (Abu Dhabi Law No. 10 of 2018, Art. 12)60 daysThe DOH90 days

A report you do not challenge becomes final. If a Medical Liability Committee report is not challenged within 30 days, it cannot be challenged before any other body (Federal Decree-Law No. 4 of 2016, Art. 20). Whether to file is a decision to take with your insurer or lawyer, but the clock does not wait for that conversation.

What to do when you learn of a complaint

  1. Find out exactly what has been opened. A medical-error complaint before a Medical Liability Committee, an administrative complaint, a disciplinary case, an inspection finding and an internal facility review are different processes with different consequences. Ask for the notice in writing and note the date you received it.
  2. Diary the deadline from the table above, with a reminder a week before it.
  3. Tell your insurer and get advice. Liability cover is compulsory and arranged by the facility owner, and the insurer steps into the rights and obligations of the insured (Federal Decree-Law No. 4 of 2016, Arts 25 to 27). Follow the policy's notification terms and speak to a UAE lawyer before you send any written statement.
  4. Follow your facility's process. Facilities must cooperate with the authority, and MOHAP asks the facility to respond to administrative complaints first. Tell your line manager or medical director through the proper channel.
  5. Leave the record alone. Do not add to, change or delete anything in the medical file. If something genuinely has to be added, make it a clearly labelled, dated late entry under your facility's policy. Changing or deleting file data against DHA instructions is a violation in itself (Schedule 4, item 34).
  6. Write a private chronology for your adviser while your memory is fresh: what happened, when, who was present, what you were thinking at each point.
  7. Check the panel. If a committee member is related to a party, works under a party's supervision, treated the patient for the same condition or was consulted on the case, raise it (Cabinet Resolution No. 40 of 2019, Art. 12).
  8. Attend when you are called. The committee's Rapporteur calls the parties to be heard, and in disciplinary proceedings a failure to attend without an acceptable excuse does not stop a decision.
  9. Do not contact the patient or family about the complaint without advice, and do not discuss it with colleagues beyond what your facility's process requires.

Writing a response a committee can use

Committees and disciplinary bodies decide mainly on paper. Your written response is often the most useful document you contribute, and a poor one can do harm. A structure that works for any authority:

  1. Your background: profession, licence, role, setting and relevant experience.
  2. A chronology drawn from the records, with dates and times, quoting the notes rather than recalling them.
  3. Your clinical reasoning at the time: what you knew, what you considered and why you chose what you did.
  4. A response to each point the complainant or authority has raised, in the same order.
  5. Reflection: what you would do differently, and what you have already changed.
  6. Evidence: training completed, audits, supervision feedback, changes to your practice.

Keep the tone factual and respectful of the patient. Do not blame colleagues without evidence; bringing a fellow professional into disrepute is itself a violation in Dubai (Schedule 4, item 18). Reflection and an admission of legal liability are different things, and your lawyer or insurer can help you show the first without volunteering the second, so have them review the response before it is sent.

Where an authority is weighing remedial measures such as training, supervised practice or reassessment, evidence that you understand what went wrong and have acted on it can help show the risk of repetition is low. It does not decide the outcome, and no course can.

Incident reports, sentinel events and complaints

Many complaints follow an incident the facility has already reported. Incident systems run on different rules from complaints and are built for learning, not blame:

  • Abu Dhabi: under the DOH Incident Reporting and Management Standard (version 2, effective December 2024), staff report incidents in the facility's electronic system within 24 hours, and reporting "will not result in disciplinary proceedings, except in the most exceptional circumstances". Sentinel events go to the DOH within 48 hours, the root cause analysis and corrective action plan within 45 calendar days, and facilities must have a process for disclosing patient-safety events to patients and families.
  • Dubai: the DHA Standards for Sentinel Events Notification and Management (ST-53) require notification to the DHA within 48 hours, a preliminary report within 72 hours and a final root cause analysis within 45 days. Facilities need an open disclosure process and support for staff involved in an event.
  • Candour: the DHA Code of Ethics expects professionals, if harm occurs, to "promptly disclose the incident to the patient and initiate appropriate remedial actions".

A root cause analysis looks at systems; a Medical Liability Committee decides individual liability. The same facts can appear in both, so make sure what you say in each is accurate and consistent.

Matching training to the concern

Training enters a UAE case in two ways. An authority may order it, as Dubai's Medical Practices Committee can under Executive Council Resolution No. 49 of 2024 (Art. 19(c)); or you may choose it yourself, to understand the standard that was in question and to show what you have changed. Ordered training is defined by the authority, and only it can say whether a course you took meets the order.

For a broad concern, the 4-hour core course for professionals facing a complaint, investigation or disciplinary action covers the UAE liability and disciplinary systems, insight, reflection and remediation evidence together. For a specific concern, the remediation courses page and the page for your authority match common concerns to topic courses. Prevention matters too: the course on avoiding patient complaints looks at the triggers that most often start a case.

Healthcare Practise is independent: our courses are not accredited by any UAE health authority, carry no CME/CPD points or credits, cannot change the outcome of a case and are not legal advice. Speak to your medical liability insurer, a UAE lawyer or your employer about your own case.

Questions

How long after treatment can a patient file a complaint against a doctor in the UAE?

The federal Executive Regulations set no filing deadline. The DHA applies its own limit: a complaint cannot be filed more than three years after the event. Other authorities may set their own rules, so check with the authority concerned. Because complaints can arrive years later, clear and contemporaneous records are a clinician's best protection.

Will I be heard before a disciplinary penalty is imposed?

Yes. The federal laws for physicians (Federal Law No. 5 of 2019, Art. 28) and for other health professions (Federal Law No. 6 of 2023, Art. 13) forbid a penalty without hearing your statements and defence. If you fail to attend without an acceptable excuse, the authority can decide without you. Medical Liability Committees also call the parties and witnesses through the Rapporteur.

What is the difference between an administrative complaint and a medical complaint?

MOHAP separates the two. An administrative complaint goes to the facility for a response and can lead to inspection and the Health Practices Control Committee. A medical complaint alleges a medical error and goes to the Medical Liability Committee. Financial and insurance complaints are redirected elsewhere.

Can I keep working while a complaint against me is investigated?

Usually yes, unless the authority suspends you. Under the Medical Liability Decree-Law a licence can be suspended for up to 30 days at a time, renewable, while a medical-error report is pending. In Dubai a precautionary suspension can last up to three months and be extended once. Your employer may also apply its own policies.

Does an open investigation appear on my good standing certificate?

It can. The DHA issues a Current Status Certificate instead of a Good Standing Certificate while an investigation or appeal is in progress, and the DOH states current investigations on its certificate. The national PQR requires the certificate to show no pending disciplinary orders, which matters if you apply to another emirate.

Is there a fitness to practise process in the UAE?

Not as a single procedure. Concerns run through the Medical Liability Committees and the licensing authorities' disciplinary processes. The DHA has a Fitness to Practice Policy (2025) describing when it may suspend, restrict or revoke a licence, and the DHCC regulation provides for a Fitness to Practice Panel, but most cases use the terms medical error, complaint, violation and disciplinary penalty.

Can I apply for a licence again after it has been revoked?

Often, yes, with conditions. Federally, a new licence may be granted once the grounds for revocation no longer exist, and for nurses and allied professionals the authority can require training, reassessment, a restricted scope or supervision. In Dubai a revoked licence can be reissued only after two years, on Medical Practices Committee review, at the same title.

Should I tell my malpractice insurer about a complaint?

Yes, early. Liability insurance is compulsory in the UAE and the insurer steps into the rights and obligations of the insured. No official text we found sets a deadline for notifying the insurer, but most policies have notification terms, so read yours and ask your facility who manages claims before you respond to the authority.

Official sources

Checked 6 October 2026. Rules and processes change, so confirm the current position with the official source. This page is general information, not legal advice.

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