For anyone whose bank or insurer has closed a complaint without fixing it: how Sanadak works, the waiting period you must serve before it will look at your file, the three-year and two-year time limits, what a determination can order, and the one point in the process that costs money.

Sanadak is the independent Ombudsman Unit established by the Central Bank of the UAE to resolve complaints against licensed financial institutions and insurance companies. It is free for consumers, sole proprietors, and small and medium enterprises. Before it will accept a complaint, you must have raised the matter with the bank or insurer and given it the response time set by the Central Bank, which the establishing regulation sets at 30 complete business days. A complaint must be filed within three years of the conduct complained of, or two years from the date you became aware of it, whichever expires last. Where a complaint is upheld, Sanadak can direct the institution to rectify the conduct, change a practice, or pay a reasonable amount for actual loss.

This guide covers eligibility, the six grounds on which a complaint can be rejected, the review procedure and its deadlines, what a determination can and cannot deliver, the appeal route and its fee, and how a determination is enforced. If your issue is a specific overcharge rather than a general complaint, check it against the fee ceilings first in our guide to the Central Bank’s retail bank fee caps, because a charge above a cap is a straightforward breach to cite.

What Sanadak Is and What It Covers

Sanadak was created by Regulation N 1659/2023 on the Establishment of an Ombudsman Unit for the United Arab Emirates, effective 15 March 2023. It has independent legal personality and is financially and administratively independent, funded by an annual levy and case fees charged to the institutions rather than by complainants.

Its jurisdiction spans both sides of the Central Bank’s remit. It covers licensed financial institutions, meaning banks and other financial institutions licensed under Decretal Federal Law No. 14 of 2018, including Islamic banks and institutions operating branches, subsidiaries, or representative offices in the UAE. It also covers insurance companies as defined in Federal Law No. 6 of 2007, including takaful companies and foreign insurers operating through a branch or an insurance agent, because the Central Bank absorbed the Insurance Authority’s functions. All the powers the Central Bank held over the Insurance Dispute Resolution Committee are delegated to Sanadak by the Regulation.

Institutions are required to tell you this route exists. Article 4.3.7 obliges licensed financial institutions and insurance companies to inform consumers in writing of their legal right to go to the Ombudsman Unit, and to provide the Unit’s detailed contact information.

Who Can Complain to Sanadak?

Any natural person, sole proprietor, or small to medium enterprise that obtains or may obtain services from a licensed financial institution or insurance company. Actual or potential beneficiaries and representatives acting for a consumer, including legal representatives, guardians, trustees, and executors, may also file. Access is free of charge for complainants.

The SME Thresholds That Decide Business Eligibility

Business access to Sanadak is not open-ended. The Regulation defines an eligible SME by reference to Federal Cabinet Resolution No. 22 of 2016, and a company that exceeds those thresholds is outside the free complaint route entirely and must use the courts.

Category Trading sector Manufacturing sector Service sector
Micro Under 5 employees, or under AED 3 million revenue Under 9 employees, or under AED 3 million revenue Under 5 employees, or under AED 2 million revenue
Small 6 to 50 employees, or under AED 50 million revenue 10 to 100 employees, or under AED 50 million revenue 6 to 50 employees, or under AED 20 million revenue
Medium 51 to 200 employees, or under AED 250 million revenue 101 to 250 employees, or under AED 250 million revenue 51 to 200 employees, or under AED 200 million revenue

A corporate banking dispute at a company above the medium threshold does not go to Sanadak. That is worth knowing before spending weeks on an internal escalation on the assumption that the ombudsman is the backstop.

The Three Grounds a Complaint Can Rest On

Article 4.1.1 sets out what Sanadak may accept a complaint about. It is narrower than general dissatisfaction, and framing your complaint inside one of the three categories matters.

  • Provision of a service or product, or an offer to provide one, by the institution.
  • Failure to provide a particular service or product you requested, for reasons that discriminate on the grounds of family or socio-economic status, gender, or being a member of a minority group.
  • Alleged financial loss or harm through deceptive, misleading, fraudulent, or unfair conduct by or on behalf of the institution.

The second ground is the narrowest and most misread. A refusal to open an account or grant a facility is only a Sanadak matter where the refusal was discriminatory on one of the listed grounds. An ordinary commercial decline on credit criteria is not within it. Account refusals and closures for compliance reasons follow a different path, described in our guide to a frozen UAE bank account and how to get it released.

The Six Rejection Grounds, Including the Waiting Period

Article 4.1.2 lists when Sanadak can reject a complaint outright. The third of these is the one that sends most first-time complainants away.

Rejection ground What it means for you
The conduct is or has been the subject of court proceedings in the UAE Choose one forum. Filing in court closes the ombudsman route on the same conduct
The complaint was not raised or properly communicated to the institution You must complain to the bank or insurer first, in a form it received
You have not given at least 30 complete business days for a final written response, or such other time limit as the Central Bank prescribes Serve the waiting period before escalating, and keep the date you complained
The matter occurred outside the time limits in Article 4.4 Three years from the conduct, or two years from awareness, whichever is later
The complaint materially relates to the institution’s risk management, internal pricing policy, or anti-money laundering policies and practices Pricing strategy and AML decisions are outside the remit, even when they affect you
The complaint has already been settled between you and the institution Accepting a settlement closes the route on that matter

Note the wording on the waiting period: it is 30 complete business days in the Regulation, “or such other time limit as may be prescribed by the Central Bank.” Sanadak publishes its own current service standards, and those published turnaround times have been shortened since the Regulation was issued, so check the figure on Sanadak’s own site before counting. The Regulation is the legal floor, not necessarily the operational number in force today.

Sanadak can also refuse or discontinue a review on separate discretionary grounds in Article 4.1.6, including where the complaint is frivolous, vexatious, or not made in good faith, where you have no or insufficient interest in the conduct, where the subject matter is so complex or so much about legitimate commercial judgment that a court is the more appropriate forum, where it was previously considered and no material new evidence has emerged, or where the institution is already offering a reasonable amount for the actual loss suffered.

The Time Limits

Article 4.4.1 gives a complaint two clocks, and you get the benefit of whichever expires last: three years from the date of the conduct giving rise to the complaint, or two years from the date you became aware of that conduct.

Two supporting rules decide when the clock starts. Conduct of a continuing nature is taken to have occurred when it stopped, and conduct consisting of a series of acts or omissions is taken to have occurred when the last of them occurred. A single act or omission is taken to have occurred on its own date. A recurring monthly charge is therefore treated as running until the last one, not from the first.

Sanadak may still review a late complaint where it considers it fair to do so, and Article 4.4.3 lists what it weighs: whether and how the institution notified you of the right to complain to the Ombudsman Unit and whether any written notice sufficiently specified the deadlines, the extent to which you and the institution were occupied with settlement negotiations during the period, and whether you were subject to extraordinary circumstances. The first of those is significant, because Article 4.3.7 already obliges institutions to tell you the route exists.

How the Review Runs

Sanadak may make preliminary inquiries before deciding whether to review, and may ask either party for further particulars in writing within a period not exceeding 10 business days. If it decides not to review or discontinues a review, it must tell you, the institution, and the insurer in writing within five business days, with the reasons.

Where it decides to review, it gives written notice specifying a summary of the complaint and the scope of the review, the name and contact details of the appointed staff reviewer, the information or documents required, the date they must be filed by, and the place of attendance if any is required. All parties then get an opportunity to make an initial written submission within a period not exceeding 10 business days, addressing the scope of the review, the alleged conduct, and any rebuttal.

The reviewer may request additional information at any time, require an illegible document to be reproduced legibly, and carry out interviews with people who may have knowledge of the circumstances. Sanadak communicates in English or Arabic, as the complainant prefers.

The obligations on the institution during this stage are worth knowing, because they are enforceable. Under Article 4.3.3 an institution must not obstruct, hinder, or delay providing requested information, must not fail to comply with a request from Sanadak or the appeal committees, must not provide false, incomplete, or misleading information, must not withhold relevant information it knows about merely because it was not specifically requested, and must not attempt to recover from you any costs it incurs in the complaint process. Where an institution fails to cooperate, Article 4.3.5 requires Sanadak to escalate the matter to the Central Bank for enforcement action.

What a Determination Can Order

On completing a review, Sanadak makes a written determination that the complaint is upheld, partially upheld, or rejected. A complaint may be upheld on one or more of six grounds: the conduct was contrary to applicable Central Bank Regulations; it was deceptive, misleading, fraudulent, or unfair in its application to you; it was based wholly or partly on an improper motive, an irrelevant ground, or an irrelevant consideration; it was not given a satisfactory explanation by the institution; it was previously found unlawful by a court or authorized regulatory body; or it was otherwise contrary to the principles of the Consumer Protection Regulation.

Where a complaint is upheld or partially upheld, Article 4.10.1 allows a direction that the institution do one or more of the following: review, rectify, mitigate, or change the conduct or its consequences; provide reasons or explanations for it; change a practice relating to it; or “recommend to pay a reasonable amount for any actual loss or harm that occurred as a result of the conduct complained of.”

That last item deserves a plain reading. The compensation limb is framed as a recommendation to pay a reasonable amount for actual loss. It is not a general damages jurisdiction, there is no award for inconvenience or distress as a separate head, and you will need to be able to evidence a quantified loss. For an unrefunded fraudulent transaction or a fee charged above a cap, the number is easy. For a complaint about how you were treated, it is not.

The institution must comply with the direction within the period specified, or an extended period Sanadak allows, and must notify Sanadak in writing of the action taken no later than 14 business days after the end of that period.

Can Sanadak Force My Bank to Refund Me?

Where a complaint is upheld, Sanadak can direct the institution to rectify the conduct and can recommend payment of a reasonable amount for actual loss or harm. The institution must comply within the period specified and confirm in writing within 14 business days after it. Non-compliance is reported to the Central Bank for enforcement action.

Appeals, and the Only Fee in the Process

Either party may refer a determination for further review: to the Appeals Committee for complaints against licensed financial institutions, or to the Insurance Dispute Resolution Committee for complaints against insurance companies.

The deadline is strict. Article 4.8.2 requires the request for appeal within 30 complete business days from the issue of the determination, “failing which the Determination shall be considered final and enforceable.” Miss it and the determination stands.

The appeal is where a cost appears. The Regulation defines an appeals fee levied on the appellant, which may at Sanadak’s discretion be refunded where the determination is in the appellant’s favor. Sanadak publishes the current amount, so confirm it before filing rather than relying on a figure quoted second hand. Filing the initial complaint remains free, and the Chief Ombudsman has power under Article 4.2.2 to waive all fees where a complainant has little or no means.

The Appeals Committee decides on a slightly narrower set of grounds than Sanadak itself: that the conduct was contrary to applicable Central Bank Regulations, that it was not given a satisfactory explanation by the institution, or that it was otherwise contrary to the principles of the Consumer Protection Regulation and its accompanying Standards.

Enforcement, and Where the Process Stops

Sanadak does not enforce its own determinations against a refusing institution. Article 4.11.1 provides that where an institution fails or refuses to comply with a request or a determination within the period stipulated, Sanadak or the Appeals Committee reports the case to the Central Bank for inquiry and necessary enforcement action.

That is a supervisory route, not a court execution. The pressure on the institution is regulatory rather than a judgment you can enforce directly, which is a real limitation for a complainant who wants a specific sum by a specific date.

Two further boundaries are worth stating honestly. Sanadak may assist you in understanding the complaint process but, under Article 2.2.3, “shall not advocate on their behalf,” so it is a neutral adjudicator and not a consumer champion arguing your case. And its decision on its own jurisdiction and on acceptance of complaints is final under Article 4.1.7, so a refusal to take the complaint is not itself appealable within the system.

Where the subject matter is a fraudulent card transaction, the bank’s own chargeback obligations run in parallel and on faster timelines, and those are set out in our guide to card fraud, chargebacks, and the Central Bank dispute process. Where the complaint is about an insurer refusing a claim, the sector rules that apply before you reach the ombudsman are covered in our guides to appealing a rejected health insurance claim and a rejected motor insurance claim in the UAE.

What to Do Before You File

Three things decide most outcomes, and all of them happen before Sanadak sees the file.

Complain to the institution properly and date it. The rejection ground in Article 4.1.2(b) is that the complaint was not raised or properly communicated. Use the bank’s or insurer’s official complaint channel, get a reference number, and keep the acknowledgment. The date on that acknowledgment starts the waiting period.

Do not settle if you intend to escalate. A complaint already settled between you and the institution is a rejection ground, and an institution offering a reasonable amount for the actual loss is a discretionary ground for Sanadak to decline the review. Accepting a partial goodwill payment can close the route.

Quantify the loss. The compensation limb is tied to actual loss or harm. Assemble statements, the charge lines, correspondence, and any evidence of a rule the institution breached, such as a fee above a published cap or a notice period not served. If your complaint is about a change to your terms made without proper notice, the applicable periods are set out in our guide to when a UAE bank can change your fees, rate, or terms.

Frequently Asked Questions

What is Sanadak?

Sanadak is the independent Ombudsman Unit established by the Central Bank of the UAE under Regulation N 1659/2023, effective 15 March 2023. It has independent legal personality and resolves complaints by consumers, sole proprietors, and SMEs against licensed financial institutions and insurance companies, including takaful providers. It is funded by levies on those institutions, not by complainants.

How long must I wait before escalating to Sanadak?

The establishing Regulation allows Sanadak to reject a complaint where the complainant has not given the institution at least 30 complete business days to provide a final written response, or such other time limit as the Central Bank prescribes. Sanadak publishes its own current service standards, which have been shortened since the Regulation was issued, so check the figure it publishes before counting.

Does it cost anything to complain to Sanadak?

Filing a complaint is free for consumers, sole proprietors, and SMEs. A fee applies only if a party appeals a determination to the Appeals Committee or the Insurance Dispute Resolution Committee, and that fee may be refunded at Sanadak’s discretion where the determination goes in the appellant’s favor. The Chief Ombudsman can waive all fees where a complainant has little or no means.

What is the deadline to file a complaint with Sanadak?

Three years from the date of the conduct giving rise to the complaint, or two years from the date you became aware of it, whichever expires last. Continuing conduct is treated as occurring when it stopped, and a series of acts as occurring at the last of them. Sanadak may still review a late complaint where it considers it fair, weighing how well the institution notified you of your right to complain.

Can I go to Sanadak if I have already started a court case?

No. Article 4.1.2(a) allows rejection where the conduct giving rise to the complaint is or has been the subject of legal proceedings before a UAE court. Sanadak may also decline where the subject matter is so complex, or so much about legitimate commercial judgment, that the courts are the more appropriate forum.

Does Sanadak handle insurance complaints as well as banking?

Yes. The Regulation covers insurance companies as defined in Federal Law No. 6 of 2007, including takaful companies and foreign insurers operating through a branch or agent, because the Central Bank took over the Insurance Authority’s functions. Appeals on insurance complaints go to the Insurance Dispute Resolution Committee rather than the Appeals Committee.

Can my business complain to Sanadak?

Only if it meets the SME thresholds in Federal Cabinet Resolution No. 22 of 2016 as applied by the Regulation. In the service sector, for example, medium enterprises are 51 to 200 employees or under AED 200 million in annual revenue. A company above the medium thresholds falls outside the free complaint route and must use the courts.

How long do I have to appeal a Sanadak determination?

Thirty complete business days from the issue of the determination. Article 4.8.2 provides that failing to appeal within that period makes the determination final and enforceable. Either party to the complaint may appeal, so an institution can appeal a determination made in your favor within the same window.

What happens if my bank ignores the Sanadak decision?

The institution must comply within the specified period and notify Sanadak in writing of the action taken no later than 14 business days after it. Where it fails or refuses, Sanadak or the Appeals Committee reports the case to the Central Bank for inquiry and enforcement action. Sanadak does not itself execute determinations against a refusing institution.

Are complaints about interest rates or account closures for AML reasons accepted?

Generally no. Article 4.1.2(e) allows rejection where the complaint materially relates to the institution’s risk management, internal pricing policy, or anti-money laundering policies and practices. A complaint that a specific published fee exceeded a Central Bank cap is different, because that is a breach of a regulation rather than a challenge to pricing strategy.

Official Sources

This article references information from the following UAE government authorities and legal sources:

This guide is for informational purposes only and is not financial or legal advice. Information is current as of August 2026. Article references are to Regulation N 1659/2023 as published in the CBUAE Rulebook, and the official Arabic text prevails in any conflict of interpretation. Sanadak publishes its own service standards, turnaround times, and appeal fee, and those operational figures are updated independently of the Regulation, so confirm them on Sanadak’s site before relying on a number. Eligibility, jurisdiction, and acceptance of any individual complaint are decided by the Ombudsman Unit, whose decision on those points is final.