Bribery in the UAE is not confined to government officials. Article 278 of Federal Decree-Law No. 31 of 2021, the Crimes and Penalties Law, makes it a criminal offence punishable by up to five years’ imprisonment for anyone managing or working in any capacity for a private sector business to request or accept an unentitled gift in return for performing or omitting an act within their job duties.

Two features of the UAE regime are harsher than most business people expect. Article 286 provides that the criminal case never expires: there is no limitation period, and the penalty is not forfeited by the passage of time. And Article 283 sets the fine at an amount equivalent to whatever was requested, offered or accepted, with a floor of AED 5,000, on top of imprisonment. This guide covers who counts as a public servant, the private-sector offence most compliance policies miss, the treatment of gifts and hospitality, trading in influence, the self-reporting exemption, and the extraterritorial reach.

The Public Sector Offence

Article 275 imposes temporary imprisonment on any public servant, person entrusted with a public service, foreign public servant or employee of an international organization who, directly or indirectly, requests, accepts, takes or promises an unentitled gift, privilege or grant, whether for themselves or for another person, entity or establishment, in return for performing or omitting an act within their job duties or for violating those duties.

Three extensions inside that single article do most of the work, and each closes a defence people commonly assume exists:

  • “Directly or indirectly.” Routing a payment through a consultant, an agent or a family member does not change the analysis.
  • “Even if he has intended not to perform or omit such act.” Taking the money with no intention of delivering is still bribery. There is no defence in never having provided the favour.
  • “Or if such request, acceptance or taking occurs after performing or omitting the act.” A reward paid afterwards, with nothing agreed in advance, is caught. The gratitude payment is the offence.

Article 276 goes further again. The same penalty applies where the official takes a payment for an act that is only wrongly believed, or claimed by him, to be among his job duties. Whether he actually had the power to help is irrelevant.

Who counts as a public servant

The category is broader than a government payroll. Article 275 expressly names foreign public servants and employees of international organizations alongside UAE officials, so bribing an official of another country from the UAE is an offence here. Article 277 adds a category most commercial parties would never think of: arbitrators, experts and fact-finders are treated as public servants within the limits of the work assigned to them.

That has direct consequences for anyone involved in dispute resolution. An improper payment to a tribunal-appointed expert, or to an arbitrator, is prosecuted as public-sector bribery, not as a private commercial matter. It sits alongside the separate integrity conditions the arbitration law imposes on tribunal members, covered in our guide to arbitration in the UAE.

Private Sector Bribery: The Offence Compliance Policies Miss

Article 278 imposes temporary imprisonment of up to five years on anyone who manages a private sector entity or establishment, or works for it in any capacity, who directly or indirectly requests, accepts, takes or promises an unentitled gift, privilege or grant, for themselves or another, in return for performing or omitting an act within their job duties or in violation of them.

Article 279 completes the pair by punishing the giver with the same maximum: anyone who directly or indirectly promises, offers or grants such a gift to a person managing a private sector entity or establishment.

Read together, these two articles criminalize ordinary commercial kickbacks entirely within the private sector. A procurement manager taking a payment to award a contract, a purchasing officer accepting a personal commission from a supplier, a broker paid privately to steer a deal: none of these involves government, and all of them are covered. The words “or works therefor in any capacity” mean the offence is not limited to directors or managers.

This is the gap in most locally drafted compliance policies, which are written around public officials and government interaction. In the UAE the criminal exposure for commercial bribery between two private companies is real and carries the same five-year ceiling as bribing the giver of a public service.

Gifts, Hospitality and the “Unentitled” Test

The statutory language is an unentitled gift, privilege or grant. The offence turns on the linkage between the benefit and the recipient’s job duties, not on the size of the benefit or the label attached to it. Nothing in the chapter sets a value threshold below which a gift is safe.

Several practical implications follow directly from the wording:

  • There is no de minimis in the statute. Corporate gift registers with a value ceiling are a governance tool, not a legal safe harbour.
  • The benefit does not have to go to the recipient. Articles 275 and 278 both cover a gift in favour of “another person, entity or establishment,” which reaches donations to a nominated charity, payments to a relative’s company, and benefits directed to a connected business.
  • Timing does not save it. Post-completion gifts are expressly caught by Article 275, and Article 278 covers a request, acceptance or promise occurring after the act.
  • An attempt is punished as the completed offence. Article 287 provides that an attempt to commit any crime in the chapter carries the same penalty as the consummated crime, so an offer that is refused is still fully punishable.

Trading in Influence

Article 281 creates a separate offence for selling access. Anyone who requests, accepts or takes a promise or gift, for themselves or others, to use real or alleged influence to obtain or attempt to obtain a grant, service, benefit or any unentitled privilege of any kind from a public department, authority or an entity subject to its supervision, faces imprisonment of not less than one year and/or a fine of not less than AED 20,000.

Two things make this provision wider than the core bribery offences. The influence may be alleged rather than real, so the fixer who has no genuine connections commits the same offence as one who does. And the recipient of the payment need not be an official at all. Where the perpetrator is a public servant, a person entrusted with a public service, a foreign public servant or an employee of an international organization, the penalty rises to imprisonment of up to five years.

Article 282 catches the middleman separately: anyone who intercedes to influence the briber or the bribed to offer, request, accept, receive or promise a bribe faces temporary imprisonment of up to five years. The intermediary is not a lesser participant in UAE law.

This is the provision to have in mind when engaging a local consultant or facilitator to expedite a government approval. Where the arrangement is presented as buying access or influence rather than performing genuine, documented professional work, it moves into Article 281 territory. The legitimate alternatives, and how licensed intermediaries actually operate, are covered in our guides to PRO services in the UAE and verifying a service provider before you pay.

The Penalties

Conduct Penalty
Public servant, person entrusted with a public service, foreign public servant or international organization employee taking a bribe (Arts. 275, 276) Temporary imprisonment
Offering a bribe to any of the above (Art. 280) Temporary imprisonment up to 5 years
Private sector bribery, taking (Art. 278) or giving (Art. 279) Temporary imprisonment up to 5 years
Trading in influence (Art. 281) Imprisonment not less than 1 year and/or fine not less than AED 20,000; up to 5 years if the perpetrator is an official
Acting as intermediary (Art. 282) Temporary imprisonment up to 5 years
Fine in every case above (Art. 283) A fine equivalent to what was requested, offered or accepted, minimum AED 5,000, plus confiscation of the gift

Article 283 is worth reading twice. The fine is not a fixed tariff; it tracks the value of the bribe itself, so a large improper payment produces a large fine automatically, and the gift is confiscated on top. The article applies to “the perpetrator in all cases stated in the preceding Articles of this Chapter,” so it attaches across the whole chapter rather than to one offence.

Two Rules With No Real Equivalent Elsewhere

There is no limitation period

Article 286 provides that the criminal lawsuit does not expire on the lapse of time for any crime in this chapter, that the adjudged penalty is not forfeited, and that civil lawsuits arising from or connected to it do not expire either.

Ordinary UAE criminal procedure applies limitation periods measured in years. Bribery is carved out of that entirely. Conduct from a decade or more ago remains prosecutable, a sentence already imposed does not lapse, and the connected civil claim for the money survives alongside it. For anyone conducting due diligence on a UAE business, this means historic conduct is not time-barred simply because it is old.

Self-reporting exempts the giver

Article 284 provides that the briber or the intermediary is exempted from the penalty if he informs the judicial or administrative authorities of the crime before it is discovered.

This is a genuine exemption from punishment, not a discretionary mitigation, and it is available to the person who paid and to the intermediary, but not to the official who took the bribe. The condition is timing: the report must come before the crime is discovered. Once an investigation is under way, the route is closed.

The practical consequence for a business that finds a problem in its own operations is that the value of self-reporting decays rapidly and disappears the moment anyone else finds out. It is also why an internal investigation that sits unreported for months can destroy the one protection available.

The Law Follows You Abroad

Article 285 applies the chapter to anyone who commits one of these crimes outside the UAE, in three situations: where the perpetrator or the victim is a UAE citizen, where the crime is committed by an employee of the public or private sector of the State, or where it affects public funds.

The second limb is the significant one for expatriate business people. It reaches conduct abroad by an employee of a private sector UAE business, not only by government employees. A UAE-based company whose overseas sales team pays a bribe in another country is exposed under UAE law as well as under the law of the country where it happened.

What This Means for a Business Operating Here

  • Write the policy around Article 278, not only around officials. Private-sector commercial bribery carries the same five-year ceiling and is the more likely exposure for most companies.
  • Cover everyone, not just managers. Article 278 reaches anyone who works for the entity “in any capacity.”
  • Do not rely on a gift value threshold as a legal defence. The statute sets none. A register and an approval process are governance, and useful evidence of intent, but they are not a safe harbour.
  • Watch payments to third parties. Benefits directed to another person, entity or establishment are expressly covered, which is what makes charitable donations and payments to connected companies a compliance risk rather than a workaround.
  • Diligence intermediaries properly. Article 282 makes the middleman fully liable, and Article 281 catches arrangements sold as influence. Documented, genuine, invoiced professional services are the distinction that matters.
  • Treat historic conduct as live. Article 286 removes the limitation period, so an acquisition target’s past cannot be discounted for age. This belongs in any share purchase diligence alongside the corporate checks in our guide to shareholder rights and company records.
  • Integrate it with the other compliance perimeters. Corrupt payments frequently surface as money laundering and reporting failures first, covered in our guide to UAE anti-money laundering obligations, and bid-rigging or collusive tendering carries its own separate prohibition under UAE competition law.

If you are facing an allegation rather than designing a policy, the procedural route, the detention rules and the complaint mechanics are set out in our guides to filing a criminal complaint in the UAE and hiring a lawyer.

Frequently Asked Questions

Is private sector bribery a crime in the UAE?

Yes. Article 278 of Federal Decree-Law No. 31 of 2021 imposes temporary imprisonment of up to five years on anyone who manages a private sector entity or establishment, or works for it in any capacity, who directly or indirectly requests, accepts, takes or promises an unentitled gift, privilege or grant in return for performing or omitting an act within their job duties or in violation of them. Article 279 punishes the giver with the same maximum. No government involvement is required.

What is the penalty for bribery in the UAE?

Temporary imprisonment for the core offences, capped at five years for private sector bribery, for offering a bribe to an official, and for acting as an intermediary. On top of any imprisonment, Article 283 imposes a fine equivalent to whatever was requested, offered or accepted, with a minimum of AED 5,000, and requires confiscation of the gift. Trading in influence under Article 281 carries imprisonment of not less than one year and/or a fine of not less than AED 20,000.

Is there a limitation period for bribery in the UAE?

No. Article 286 provides that the criminal lawsuit does not expire on the lapse of time for any crime in the bribery chapter, that the adjudged penalty is not forfeited, and that civil lawsuits arising from or connected to it do not expire either. Historic conduct therefore remains prosecutable regardless of how long ago it occurred, which matters for due diligence on a UAE business.

Can I be prosecuted in the UAE for bribery committed abroad?

Yes, in three situations set out in Article 285: where the perpetrator or the victim is a UAE citizen, where the crime is committed by an employee of the public or private sector of the State, or where it affects public funds. The second limb reaches conduct abroad by employees of private UAE businesses, not only government employees.

Are gifts to officials allowed in the UAE if they are small?

The statute sets no value threshold. Articles 275 and 278 refer to an unentitled gift, privilege or grant, and the offence turns on the link between the benefit and the recipient’s job duties rather than on the amount. Corporate gift registers with value limits are a governance control and evidence of intent, not a legal safe harbour.

Is it still bribery if the official never does the favour?

Yes. Article 275 applies even where the official intended not to perform or omit the act, and Article 276 applies the same penalty where the act was only wrongly believed or claimed to be within his duties. Article 287 separately provides that an attempt to commit any crime in the chapter carries the same penalty as the completed crime, so a refused offer is still fully punishable.

Is a gift given after the favour still bribery in the UAE?

Yes. Article 275 expressly covers a request, acceptance or taking that occurs after performing or omitting the act or violating the job duties, and Article 278 does the same for the private sector. A reward paid afterwards, with nothing agreed in advance, falls within the offence.

What is trading in influence under UAE law?

Article 281 makes it an offence to request, accept or take a promise or gift, for yourself or others, to use real or alleged influence to obtain or attempt to obtain a grant, service, benefit or any unentitled privilege from a public department, authority or an entity subject to its supervision. The influence may be alleged rather than real, and the recipient need not be an official. The penalty is imprisonment of not less than one year and/or a fine of not less than AED 20,000, rising to five years where the perpetrator is an official.

Can I avoid punishment by reporting a bribe in the UAE?

The giver and the intermediary can. Article 284 exempts the briber or the intermediary from the penalty if he informs the judicial or administrative authorities of the crime before it is discovered. The exemption is not available to the official who accepted the bribe, and it is conditional on the report coming before discovery, so it disappears once an investigation is under way.

Are arbitrators and experts treated as officials in UAE bribery law?

Yes. Article 277 provides that in applying Articles 275 and 280, arbitrators, experts and fact-finders are treated as public servants within the limits of the work assigned to them. An improper payment to a tribunal-appointed expert or to an arbitrator is therefore prosecuted as public-sector bribery rather than as a private commercial matter.

Official Sources

Information is current as of August 2026. Every article number, offence and penalty above was read from the official English text of Federal Decree-Law No. 31 of 2021 promulgating the Crimes and Penalties Law, Section Two, Chapter One on Bribery, which entered into force on 2 January 2022. Four limitations are stated rather than smoothed over. The decree-law uses the term “temporary imprisonment” for several of these offences without stating a maximum in the bribery chapter itself; the general sentencing provisions of the Penal Code define that term, and this guide quotes the five-year ceilings only where the article states them expressly. Separate anti-corruption obligations sit outside the Penal Code, including the anti-money laundering framework and sector-specific integrity rules, and are not covered here. Federal government employees are additionally subject to their own disciplinary regime, which operates alongside the criminal law rather than in place of it. And the DIFC and ADGM apply their own regulatory codes to firms operating in those centres on top of the federal criminal law. The Arabic text of UAE legislation prevails in case of any conflict with an English translation. This is general information, not legal advice.