UAE Music Licensing Fees: What Businesses Need to Know

Background music is so common in commercial spaces that many businesses rarely stop to consider the legal rights behind it.

A hotel lobby may play music throughout the day. A restaurant may use playlists to create atmosphere. A gym may play recorded tracks during classes, while a shopping centre, salon or retail store may use music continuously as part of the customer experience.

From a copyright perspective, however, playing music commercially is not necessarily the same as listening to music privately.

The UAE is now moving towards a more formalised system for the collective management and licensing of music rights, with new commercial licensing fees expected to begin being collected from businesses using music from December 2026.

The development is important because it brings public performance rights into the day-to-day compliance responsibilities of a wide range of UAE businesses.

For many venues, the practical question will no longer simply be which music service they subscribe to.

It will be whether they possess the legal right to use that music publicly in a commercial environment.

What Has the UAE Announced?

The Ministry of Economy and Tourism has introduced a new framework governing the collective management of music rights and the fees payable where protected music is used commercially.

The system is intended to provide a structured mechanism through which copyright and neighbouring-rights holders can receive remuneration when their music is played in commercial venues.

Fee collection is expected to begin from December 2026.

Businesses potentially affected include establishments such as:

hotels;
restaurants;
cafes;
shopping malls;
retail stores;
salons;
gyms and fitness centres;
entertainment venues;
event spaces; and
other establishments using music as part of their commercial activities.

The precise amount payable will depend on the applicable licensing framework and the nature and extent of the music use.

The reform builds upon the UAE’s existing Copyright and Neighbouring Rights legislation rather than creating copyright protection for music for the first time.

What is changing is the practical mechanism through which those rights can be collectively licensed and remunerated.

Why Does Playing Music in a Business Involve Copyright?

For musical works, those rights may include control over:

reproduction;
broadcasting;
communication to the public;
public performance; and
other forms of commercial exploitation.

Playing a song privately at home is fundamentally different from playing it to customers in a commercial establishment.

When a restaurant plays recorded music over its speakers, the music contributes to the atmosphere and customer experience of the business.

Likewise, music used in:

a hotel lobby;
fitness class;
nightclub;
shopping centre;
retail outlet; or
public event

is being communicated to an audience within a commercial environment.

That use may therefore engage the economic rights of the people and organisations behind the music.

Buying Music Is Not the Same as Buying Public Performance Rights

This distinction is one of the most important concepts for businesses to understand.

Purchasing a song, album or subscription generally gives the user access to the music under the terms of that particular service.

It does not necessarily grant unrestricted rights to exploit the music commercially.

A person who purchases a song for personal listening does not ordinarily acquire ownership of the copyright.

Similarly, a business subscribing to a consumer music-streaming service should not automatically assume that the subscription provides the right to play the music publicly to customers.

The service gives access to the recording.

The copyright licence governs what the user may legally do with it.

Those are separate concepts.

Is a Spotify or Apple Music Subscription Enough?

Not necessarily.

Consumer streaming subscriptions are generally designed for personal use and are subject to contractual terms defining how the service may be used.

A business should therefore not assume that paying a monthly subscription fee automatically clears all copyright and public performance rights associated with playing music commercially.

There can be several separate layers of rights in a single song.

For example, rights may exist in:

the musical composition;
the lyrics;
the sound recording;
the performance; and
the production of the recording.

Different rights holders may control different parts of that chain.

This is precisely why collective rights-management systems exist.

Rather than requiring every restaurant or hotel to negotiate separately with hundreds or thousands of composers, performers and record companies, a licensed collective management organisation can administer rights on behalf of multiple rights holders.

What Is Collective Rights Management?

Collective rights management allows copyright owners and holders of neighbouring rights to authorise specialised organisations to manage certain economic rights on their behalf.

These organisations can:

license the commercial use of protected music;
collect royalties or licensing fees;
maintain records of licensed users;
represent multiple rights holders;
monitor commercial music use; and
distribute collected revenue to the relevant creators and other rights holders.

The UAE Copyright framework expressly recognises collective management.

An organisation carrying out this function must obtain the necessary permit from the Ministry before operating as a collective rights manager.

The organisation must also maintain appropriate agreements, collection procedures and mechanisms for distributing revenues to the rights holders it represents.

The system is intended to make copyright licensing workable at scale.

Why Is the UAE Formalising the System Now?

The UAE has developed rapidly as a centre for:

hospitality;
tourism;
entertainment;
music;
events;
nightlife;
retail; and
creative industries.

Music is a significant component of those sectors.

At the same time, the UAE has been strengthening the institutional framework through which musicians, composers, performers and other creators can monetise their intellectual property.

Licensed collective management organisations now provide a mechanism through which commercial users can obtain permission while rights holders receive remuneration.

This brings the UAE closer to systems operating in many established international markets where hotels, restaurants, broadcasters, shops and entertainment businesses routinely pay music performance royalties.

The development should therefore be understood as part of the maturation of the UAE’s creative economy rather than simply the introduction of another business fee.

Which Businesses May Be Affected?

The requirement is potentially relevant wherever protected music is communicated publicly as part of commercial activity.

This may include:

Hotels

Music may be used in:

lobbies;
restaurants;
lounges;
swimming pools;
spas;
gyms;
guest entertainment areas;
events; and
other public spaces.

A large hotel may therefore have several different forms of music use within one property.

Restaurants and cafes

Background playlists, live singers, DJs and entertainment nights may all involve music rights.

Shopping malls

Music used across common areas, promotional events and entertainment zones may require appropriate licensing.

Retail stores

Playing music to customers as part of the shopping environment can constitute commercial public use.

Gyms and fitness studios

Music is frequently central to exercise classes and customer experience, potentially making licensing particularly relevant.

Salons and spas

Continuous background music used to create atmosphere may also fall within commercial public performance.

Entertainment venues

Nightclubs, bars, theatres and event venues may use protected music extensively and may face a more significant licensing position.

The legal analysis depends on the actual way music is used rather than simply the category appearing on the establishment’s trade licence.

Background Music Can Still Be Commercial Use

Businesses sometimes distinguish between entertainment and background music.

That distinction can matter when calculating the applicable tariff or determining the type of licence required.

It does not necessarily mean that background music is copyright-free.

A quiet playlist playing in the reception area of a business may still constitute communication or performance of copyright-protected works to the public.

The music does not need to be the primary product being sold.

If it forms part of the commercial environment presented to customers, rights may still be engaged.

This is particularly important for venues that have historically viewed their music as incidental.

Live Music Raises Additional Issues

Live performances may involve different or additional rights from recorded background music.

A venue hosting a singer or band should not assume that paying the performers their appearance fee automatically clears every copyright obligation.

The performer may be paid for performing.

The composition itself may belong to someone else.

If the musician performs songs written by other composers, the public performance of those works may require separate permission or licensing.

The venue should therefore distinguish between:

paying the artist;
hiring the entertainment;
securing event permits; and
obtaining the necessary copyright permissions.

These obligations serve different purposes.

What About DJs?

DJ performances can involve several layers of music rights because they rely heavily on existing sound recordings.

A nightclub or event organiser may pay a DJ to perform while still needing to ensure that the underlying commercial music use is properly licensed.

Contracts with DJs should therefore identify responsibility for:

music licensing;
performance permissions;
recordings used;
event permits;
copyright clearances; and
any additional rights required for livestreaming or recording the event.

Businesses should not assume that the DJ automatically carries responsibility merely because they select the tracks.

The venue itself may be the commercial user presenting the music to the public.

Who Is Responsible for Paying the Licence?

The precise position depends on the licensing framework and the commercial arrangement involved.

In many cases, responsibility will fall primarily on the establishment or operator making the music available to the public.

That may be:

the hotel;
restaurant operator;
mall management company;
retail tenant;
event organiser;
venue operator; or
another commercial user.

Contracts can allocate responsibilities between parties, but contractual allocation does not necessarily remove statutory obligations towards rights holders.

For example, a landlord may require the tenant to obtain all necessary intellectual property licences.

An event venue may instead include music rights within a broader package.

Businesses should determine clearly who is responsible rather than assuming that another participant has dealt with the issue.

What About Events Held Inside Hotels?

Events can create particular complexity.

A hotel may already hold certain licences for normal background music, while a separately organised wedding, corporate event or concert may involve a different scale or type of use.

Relevant questions may include:

Is recorded music being played?
Is there a live band?
Is a DJ performing?
Is the event ticketed?
Is it open to the public?
Is the music merely background entertainment?
Will the performance be recorded?
Will it be livestreamed?
Who organised the event?
Who controls the venue?

The answer may determine whether existing licences are sufficient or whether additional permissions are required.

Event contracts should address this expressly.

Are Weddings and Private Events Different?

A genuinely private gathering may raise different considerations from a public commercial event.

However, the fact that a wedding or private function takes place in a hotel or commercial venue does not automatically mean that copyright issues disappear.

The venue may still be commercially providing music or entertainment services.

The legal analysis may therefore distinguish between the private nature of the audience and the commercial role played by the venue, event organiser or entertainment provider.

Businesses should avoid applying assumptions about personal use to organised events held within commercial premises.

What About Music Played by Television or Radio?

Playing a television or radio broadcast within a business may also involve rights separate from the subscription or broadcast service itself.

The fact that a broadcaster has obtained permission to transmit the music does not necessarily mean that every commercial establishment receiving that broadcast automatically obtains public performance rights.

The same general principle applies:

The right to receive content is not necessarily the same as the right to communicate that content publicly within a commercial establishment.

Businesses should therefore consider all sources through which music reaches their premises, not merely dedicated playlists.

What About Royalty-Free Music?

Some businesses may choose music specifically licensed for commercial use.

Royalty-free music does not necessarily mean that copyright does not exist.

It generally means that the rights holder has provided a licence allowing specified uses without requiring recurring royalties for each individual use.

The business should still review the licence terms.

The licence may restrict:

commercial use;
public performance;
geographic territory;
number of locations;
reproduction;
advertising;
broadcast; or
online use.

Music genuinely released into the public domain may fall outside copyright protection, but businesses should verify that status rather than assuming that older or freely available music can be used without restriction.

How Will Licensing Fees Be Calculated?

Music licensing systems generally seek to reflect the commercial nature and scale of the use.

The applicable UAE guide is expected to distinguish between different types of establishments and forms of music use.

Relevant factors may include:

the category of business;
venue size;
customer capacity;
frequency of music use;
whether music is live or recorded;
whether music forms a central part of the business;
number of locations;
type of event; and
other criteria specified under the licensing framework.

A nightclub whose business depends substantially on music should not necessarily be treated in the same manner as a small office reception area using occasional background music.

Businesses should therefore wait for the applicable tariff classification rather than assuming that every establishment will pay the same amount.

One Business May Need More Than One Type of Licence

Music rights can be fragmented.

A song may involve economic rights belonging to several parties.

Depending on the licensing system and repertoire used, a business may need to consider rights associated with:

songwriters;
composers;
publishers;
performers;
recording producers; and
other neighbouring-rights holders.

Collective management is intended to simplify this process, but businesses should understand exactly which repertoire and categories of rights are covered by the licence they obtain.

A licence from one rights-management organisation should not automatically be assumed to cover every protected song or every relevant economic right.

What If the Venue Plays Only International Music?

International music may also be protected in the UAE through the applicable copyright framework and international arrangements.

Collective management organisations may enter into reciprocal agreements with foreign rights-management bodies, allowing them to administer rights associated with international repertoires.

A business therefore cannot assume that using only American, British, Indian, Arabic or other foreign music removes the licensing requirement.

The relevant question is whether the works and recordings are protected and whether the organisation granting the licence is authorised to manage the relevant rights.

What Happens if a Business Ignores Music Rights?

Unauthorised use of protected copyright material can expose a business to legal consequences.

Depending on the circumstances, rights holders may seek remedies including:

cessation of the unauthorised use;
compensation;
preservation of evidence;
seizure or other measures concerning infringing materials;
judicial orders; and
other remedies available under UAE copyright legislation.

Certain copyright infringements may also attract criminal penalties.

The exact consequence will depend on the nature of the conduct and the rights involved.

For most established businesses, however, the more practical risk may be that routine commercial activity becomes non-compliant once the collective licensing system is actively implemented.

Can a Business Be Liable Without Intending to Infringe Copyright?

Potentially.

Copyright compliance should not depend solely on whether the business consciously intended to deprive an artist of royalties.

A venue may simply have assumed that its streaming subscription was sufficient.

That misunderstanding does not necessarily establish that the use was authorised.

Once a formal licensing framework becomes widely operational, businesses will have stronger reasons to identify and satisfy the relevant requirements.

Good-faith misunderstanding may be relevant to the circumstances of a dispute, but it should not replace appropriate licensing.

Music Licensing Should Become Part of Venue Compliance

Hospitality and retail businesses already manage numerous licensing requirements.

Depending on the business, these may include:

commercial licences;
food safety;
tourism requirements;
entertainment permits;
alcohol licensing;
advertising approvals;
event permissions;
music and media requirements; and
other sector-specific obligations.

Music licensing should increasingly form part of that compliance checklist.

The responsible team may include:

legal;
operations;
procurement;
finance;
marketing;
events;
facilities management; and
entertainment management.

Without central responsibility, different locations or departments may use music independently without anyone understanding the overall licensing exposure.

Businesses Should Audit How They Currently Use Music

Before the new fee collection begins, businesses should identify every way music is currently used.

The audit should consider:

background playlists;
streaming services;
televisions;
radios;
live musicians;
DJs;
fitness classes;
promotional events;
corporate events;
weddings;
recorded advertisements;
social media content;
outdoor speakers; and
entertainment provided by third parties.

Each category may raise different rights questions.

Multi-site businesses should also identify whether one licence can cover several locations or whether individual venue licences will be necessary under the applicable framework.

Existing Supplier Contracts Should Be Reviewed

Many businesses outsource entertainment.

A hotel may engage:

an entertainment company;
DJ;
live band;
event organiser;
background music provider; or
audiovisual contractor.

The agreement should clearly state who is responsible for obtaining the necessary copyright licences.

However, businesses should not rely blindly on a contractual clause saying that the supplier “owns all rights”.

Where thousands of commercial recordings are used, that statement may not accurately describe the supplier’s rights.

The venue should require evidence of the relevant licences where appropriate.

Franchise Businesses Should Pay Particular Attention

Music licensing may also create issues within franchise structures.

A global restaurant or retail brand may maintain a central playlist that is distributed across multiple UAE locations.

The franchisor may control the music selection while individual franchisees operate the premises.

The parties should determine:

who licenses the music;
whether the licence covers the UAE;
whether each outlet is included;
whether public performance rights are covered;
who pays the relevant fees; and
how new outlets are added.

An international licence negotiated by a parent company may not automatically satisfy UAE requirements.

Developers and Mall Operators Should Review Tenant Arrangements

Shopping centres present another layer of complexity.

Music may be played:

in common areas;
inside individual stores;
during mall events;
in food courts;
in entertainment zones; and
through outdoor speaker systems.

The mall operator and tenants may therefore have separate responsibilities.

Lease agreements should clarify whether any central music licence applies only to common areas or also extends to individual occupiers.

Tenants should not assume that because music is already playing in the mall, their own in-store music is automatically covered.

The System Benefits Creators as Well as Businesses

Commercial music licensing is sometimes perceived solely as another cost imposed on venues.

That overlooks the economic purpose of copyright.

Musicians, composers, performers and producers create assets that commercial businesses use to enhance their own customer experience.

A song played repeatedly across hotels, restaurants and retail spaces has commercial value.

Collective rights management provides a mechanism through which part of that value can flow back to the people whose work created it.

A transparent licensing system can also benefit businesses because it provides a clearer route to lawful use rather than requiring individual negotiations with rights holders.

What Businesses Should Do Before December 2026

Businesses using music commercially should begin preparing now.

Key steps include:

Identify every location where music is played.
Include hotels, stores, gyms, restaurants, common areas and event spaces.
Identify how the music is sourced.
Consumer streaming accounts, commercial music providers, DJs, radio and live performers should be considered separately.
Review existing licences and contracts.
Determine what rights are actually covered.
Identify the responsible entity.
Confirm whether the venue operator, tenant, franchisee, event organiser or supplier is responsible.
Review the new tariff framework.
Determine which category applies to each establishment.
Budget for licensing costs.
Music rights should be incorporated into ordinary operating expenditure.
Update contracts.
Event, entertainment and supplier agreements should allocate copyright responsibilities clearly.
Create an internal compliance process.
Businesses with multiple venues should maintain records of licences, renewals and covered locations.

Waiting until a demand or infringement complaint is received is unlikely to be the most efficient approach.

Why the December 2026 Date Matters

The significance of December is that the UAE’s collective music-rights framework is moving from institutional development into direct commercial application.

The legal rights themselves are not new.

The UAE Copyright Law already protects public performance and communication rights and recognises collective management.

What changes for businesses is the practical environment in which those rights are administered.

A licensing infrastructure makes it easier for rights holders to:

identify commercial users;
establish tariffs;
issue licences;
collect fees; and
enforce rights where businesses remain unlicensed.

For venues that historically gave little consideration to music copyright, this represents a material compliance change.

Conclusion

Playing music in a UAE business is no longer something venues should treat as a purely operational choice.

Copyright law gives creators and other rights holders control over the public and commercial use of protected music, and the UAE’s expanding collective management framework is creating a more structured system for licensing that use.

From December 2026, businesses such as hotels, restaurants, cafes, malls, retailers, gyms and entertainment venues should expect commercial music licensing to become an increasingly visible part of their regulatory obligations.

Paying for access to music does not necessarily mean paying for the right to use it publicly.

A streaming subscription, performer contract or event fee may therefore be only one part of the legal picture.

For businesses, the practical response is to identify how music is being used, determine which rights and licences are required, clarify contractual responsibility and address compliance before the new collection regime becomes operational.

For creators, the development represents something equally important: a more formal mechanism for ensuring that commercial use of their work generates remuneration.

Music may create the atmosphere.

Al Kabban & Associates

For businesses seeking guidance, Al Kabban & Associates, with over 30 years of experience in UAE law and recognition by Legal 500, stands ready to help corporations build resilience against legal risks while ensuring compliance with local and international standards. For more information or to schedule a consultation, contact us at +971 4 453 9090 or visit www.alkabban.com. You can also follow us on social media for more updates on everything law related in the UAE: @Alkabban_Law

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