Every time you hand over your biometrics in the UAE — whether it’s a face scan, fingerprint, or voice imprint — you’re triggering a high-stakes data-processing workflow governed by the PDPL, and it’s anything but casual. The moment that scan is captured, it becomes sensitive personal data, meaning the organisation collecting it must lock into a rigid compliance track: they must justify why they need it, secure explicit consent, document the purpose, lock it behind elevated security controls, restrict who touches it, and prove that no less-intrusive method could have done the job. Your biometric record is stored, encrypted, audited, and monitored under a regulatory regime that expects zero complacency — and you retain the right to pull the plug at any time. In short, a simple face scan kicks off a full-scale governance chain, because in the UAE, biometrics aren’t just data; they’re a regulated identity asset that companies can’t afford to mishandle.

What’s PDPL?

PDPL is the UAE’s Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data — essentially the country’s data-protection backbone. Think of it as the UAE’s answer to GDPR, built to regulate how organisations collect, process, store, transfer, and secure personal data across both public and private sectors. It sets the ground rules: what data you can take, why you can take it, how long you can keep it, who you can share it with, and what rights individuals have over it. It also puts sensitive categories — like biometrics — under a regulatory microscope and forces companies to upgrade from casual privacy practice to high-assurance compliance. If you’re working with identity systems, onboarding flows, AI verification, or anything tied to personal data in the UAE, PDPL isn’t optional; it’s the baseline operating standard.

Free UAE Biometrics Compliance Assessment Tool

1.1 Core PDPL Principles Relevant to Facial Recognition

Biometric data sits at the very top of the UAE PDPL’s risk hierarchy because it is expressly classified as sensitive personal data, meaning any organisation handling it is expected to operate with far stricter safeguards and a far higher standard of accountability. Processing this category of data requires explicit, informed, and unambiguous consent, not the vague, catch-all permissions most companies rely on. Individuals must be clearly told what biometric attributes are being collected, why they’re needed, how long they will be stored, who they may be shared with, and under what security controls they will be protected.

The purpose for collecting biometric data must be lawful, necessary, and proportionate, and organisations must be able to show that no less intrusive method could achieve the same result.

Because biometric identifiers, once compromised, cannot be changed, the law demands robust, risk-aligned security measures, including encryption, strict access controls, audit logs, and incident-response capabilities tailored to the sensitivity of the data. Finally, PDPL makes consent a living right: individuals must be able to withdraw their consent at any time, triggering immediate cessation of processing, deletion where applicable, and downstream notification to any processors or integrated systems. In short, the UAE treats biometric data as a high-risk asset, and any organisation using it must operate with full transparency, tight governance, and uncompromising security.

• Processing requires:
  • Explicit, clear, unambiguous consent.
  • Transparency regarding intended use, storage, and disclosure.
  • Lawful purpose and adherence to necessity and proportionality.
  • Security measures proportionate to the sensitivity of biometric data.
    
• Individuals must be able to withdraw consent at any time, triggering immediate cessation of processing.

1.2 PDPL Interaction With the GDPR

The PDPL largely mirrors GDPR structure but lacks the granular guidance found in EU practice.

Area	GDPR	PDPL
Consent conditions	Detailed, strict; “freely given,” “specific,” “unambiguous,” “affirmative action.”	Similar high-level standard; specifics pending Executive Regulations.
DPIA	Mandatory where high-risk processing occurs; formal criteria published.	High-level duty under Article 21; no criteria published yet.
Biometric safeguards	Explicit rules + EDPB guidance.	General principles; biometric-specific rules expected in Executive Regulations.
Enforcement	Active regulators; clear penalty ceilings.	Enforcement framework unclear pending Executive Regulations.

Regulated entities must adopt GDPR-level rigour to avoid future non-compliance shocks when PDPL enforcement becomes active.

https://www.europarl.europa.eu/RegData/etudes/STUD/2020/641530/EPRS_STU(2020)641530_EN.pdf

2. Consent Requirements for Facial Recognition Under UAE Law

**2.1 Explicit Consent

The PDPL treats biometric data as high-risk, and it doesn’t let organisations collect or process it unless they secure explicit, affirmative consent. That consent can’t be buried in a generic privacy policy or sneaked in through pre-ticked boxes — it must be a clear, intentional action by the individual. To be valid, the consent has to be specific to the exact purpose of the biometric processing, not a broad “permission to use your data.”

The individual must be fully informed, which means the organisation has to openly disclose why the biometric data is being captured, how the facial or voice scan is performed, how long the data will be stored, whether it will be transferred outside the UAE, and what rights the individual has to challenge, restrict, or revoke the processing. Anything less than full transparency is non-compliant. Consent must also be unambiguous, meaning the individual must take a clear action — such as clicking “I agree” or completing a verification step — after reading an explicit explanation of the biometric use.

What the PDPL Enforces for Biometric authentications?

• Specific to the processing purpose.
• Informed, requiring clear disclosure of:
  • Purpose and method of facial capture
  • Storage period
  • Cross-border transfers
  • Rights of withdrawal
• Unambiguous, meaning no pre-ticked boxes or implicit consent.

2.2 Withdrawal of Consent

The PDPL also reinforces the individual’s power by guaranteeing the right to withdraw consent at any time, and the withdrawal process must be simple, accessible, and friction-free. Once a person revokes their consent, the organisation must immediately stop all processing of that biometric data, assess whether deletion is required, and ensure that any downstream systems or third-party processors also cease handling it. Importantly, the individual cannot be penalised for withdrawing — no degraded service, no pressure, no denial of unrelated benefits. Controllers are further obligated to maintain internal logs documenting each withdrawal request and their corresponding actions, creating a traceable compliance trail that regulators can audit. These requirements closely mirror GDPR standards, and even though the Executive Regulations are pending, organisations in the UAE are expected to treat these obligations as fully enforceable operational rules.

In short:

• Individuals must be able to revoke consent easily.
• Processing must stop immediately upon withdrawal.
• Withdrawal cannot be penalised.
• Controllers must maintain internal logs documenting revocation and cessation actions.

This mirrors GDPR standards and should be treated as a binding operational requirement despite pending Executive Regulations.

3. Storage, Security and Minimisation Duties

3.1 Secure Storage

The PDPL requires “appropriate technical and organisational measures” to secure biometric data, and in the absence of Executive Regulations, the burden shifts squarely onto organisations to operate at GDPR-level maturity and NIST-aligned security posture. That means encryption isn’t optional — biometric identifiers must be locked down both at rest and in transit, with keys handled under strict governance. Storage can’t be casual either; biometric records belong in segregated, tightly controlled repositories, not dumped into general-purpose databases where lateral movement is a free-for-all. Access must be treated as a high-risk privilege, requiring privileged-access controls, audit-ready logging, behavioural monitoring, and strict role separation to prevent insider misuse. And the network architecture has to step up as well: a zero-trust segmentation model that isolates biometric systems from the rest of the environment is the baseline, not the ambition. In short, if an organisation is handling biometrics in the UAE, it needs to operate like a security-first enterprise — anything less is a regulatory and reputational liability waiting to detonate.

Storage Guidelines for PDPL adherence

• Encryption at rest and in transit
• Segregated biometric repositories
• Access logging and privileged-access restrictions
• Zero-trust network segmentation

3.2 Data Minimisation

The PDPL hard-codes data minimisation into its compliance DNA, and organisations handling biometrics don’t get any wiggle room. You’re expected to collect only what is strictly necessary for the stated purpose — no “nice to have,” no “just in case,” and absolutely no broad-spectrum harvesting disguised as onboarding. Once you have the data, you retain it only for the precise duration required to fulfil the purpose you disclosed to the individual; anything beyond that becomes unlawful storage and a glaring governance failure. And when that purpose ends, the PDPL expects you to delete the biometric data securely and irreversibly, with documented evidence that the erasure actually occurred. In other words, minimisation isn’t a guideline — it’s an operational mandate designed to stop organisations from hoarding identity-level data they have no business keeping.

**3.3 Absence of Detailed Technical Measures

Pending Executive Regulations are expected to define minimum technical standards. Until then, businesses deploying facial recognition must adopt the strictest available standard—GDPR-equivalent or higher—to avoid predictable enforcement gaps.

4. Cross-Border Transfer Restrictions

4.1 Adequacy Standard

Under Article 22, personal data—including biometrics—may only be transferred outside the UAE if the recipient jurisdiction:

• Has adequate protection, and
• Maintains enforceable safeguards similar to UAE standards.

Adequacy is not defined, requiring conservative interpretation.

4.2 Contractual Mechanisms

Article 23 anticipates contractual arrangements for cross-border transfers but does not yet define:

• Approved contractual clauses
• Binding corporate rules
• Mandatory contractual terms

Until Executive Regulations are issued, businesses must rely on:

• GDPR-style SCCs (as a model, not a recognised UAE instrument)
• Internal risk assessments documenting equivalent protection
• Restricted transfers to low-risk jurisdictions only

**4.3 Enforcement Uncertainty

UAE regulators will likely treat biometric transfers as high-risk. Businesses should assume that non-adequate transfers will be prohibited until Executive Regulations clarify mechanisms.**

5. DPIA (Data Protection Impact Assessment) for Facial Recognition

Facial recognition is inherently high-risk. Under PDPL Article 21:

• Controllers must conduct a risk assessment before processing sensitive data.
• Measures must be implemented to mitigate those risks.

Though criteria are not yet published, entities should adopt GDPR models:

• Map data flows
• Identify risks to individual rights
• Evaluate processing necessity
• Document mitigations such as encryption, minimisation and access controls
• Maintain a register for audit readiness

This becomes mandatory for:

• Customer-facing recognition systems
• Attendance/verification systems
• Access-control devices
• Surveillance integrated with biometric matching

6. Licensing Barriers for Facial Recognition Businesses in the UAE

**6.1 Licensing Activities Are Restrictive

Private businesses in the UAE don’t get a free pass to “collect biometric data” just because the technology exists. Biometric processing is a regulated economic activity, and whether you can legally engage in it depends entirely on the jurisdiction and licensing framework you operate under. Mainland entities cannot simply run facial-recognition systems, operate verification platforms, or store biometric identifiers without explicit authorisation. Only specific free zones and regulatory authorities offer business activities that align with biometric capture, identity verification, or advanced data processing. Even then, the licensing is tightly scoped — often restricted to digital identity services, cybersecurity functions, or AI/analytics categories that explicitly permit biometric handling.

This creates a hard compliance boundary: if your licence doesn’t expressly cover biometric processing, you’re not legally allowed to collect or store biometric data, regardless of your business model. The UAE treats biometric data as a high-sensitivity asset, and regulators expect businesses to operate strictly within authorised activity codes, backed by PDPL-aligned governance, security, and purpose limitation. In practice, this means any organisation considering biometric workflows must first secure the correct economic-zone approval before writing a single line of code or onboarding a single user.

**6.2 Government-Controlled Domain

Facial recognition in the UAE is heavily used by:

• Government entities
• Semi-government bodies
• Critical infrastructure operators

Private-sector deployment requires:

• Alignment with the approved licensing activity
• Compliance with national security restrictions
• Technical vetting where applicable

Businesses seeking to build or commercialise facial recognition systems must obtain:

• Sector-appropriate licensing
• Activity-specific approvals where required
• Data protection compliance framework aligned with PDPL

Failure to obtain a matching licensing activity may result in:

• Rejection of commercial licence applications
• Inability to import or deploy biometric systems
• Interference by regulators if unauthorised collection occurs

7. Additional Legal Constraints: Copyright Law

Under Federal Decree-Law No. 38 of 2021 (Copyright Law):

• Photographing or recording individuals without explicit consent is prohibited.
• This applies even outside of PDPL, meaning:
  • Retailers
  • Event organisers
  • Technology providers
  • Real-estate operators

must obtain dual compliance:

1. Consent for image capture (Copyright Law)
2. Consent for biometric processing (PDPL)

This dual-layer regime creates high exposure for unregulated camera systems.

8. Corporate Risk Exposure

8.1 High-Risk Areas

• Collecting facial recognition data without explicit consent
• Using facial recognition for marketing, analytics or profiling
• Storing biometric data without encryption
• Deploying third-party AI tools outside the UAE without adequacy assurance
• Failing to document DPIAs
• Ignoring withdrawal-of-consent requests
• Integrating surveillance with biometric profiling
• Allowing vendors to export biometric data

**8.2 Penalties and Enforcement

Penalty tiers and enforcement procedures are pending Executive Regulations. However, the PDPL framework anticipates:**

• Administrative penalties
• Directions to suspend or delete data
• Restrictions on processing activities
• Civil liability for damages

Businesses should treat this as a future GDPR-equivalent penalty regime.

Operational Step-by-Step Workflow for Facial Recognition Compliance

Step 1 — Confirm Licensing Eligibility

1. Identify the economic zone.
2. Verify if the zone offers a biometric-collection activity.
3. Obtain approvals before processing begins.
4. [verify: activity codes; zone-specific requirements]

Step 2 — Conduct a DPIA

1. Map data sources and flows.
2. Identify risks to individual rights.
3. Define mitigation controls.
4. Prepare a DPIA report.
5. Obtain internal sign-off.

Step 3 — Establish a Consent Framework

1. Draft consent notices.
2. Require affirmative action (no pre-ticks).
3. Provide opt-out and withdrawal mechanisms.
4. Log all consents and withdrawals.

Step 4 — Build Data Minimisation Controls

1. Limit collection to explicitly declared purposes.
2. Restrict retention periods.
3. Enforce secure deletion upon expiry.

Step 5 — Implement Security Measures

1. Encryption at rest and in transit.
2. Privileged-access segmentation.
3. Logging and monitoring.
4. Incident-response plan for biometric data.

Step 6 — Review Cross-Border Transfers

1. Assess adequacy of the destination country.
2. Adopt contractual safeguards.
3. Document all assessments.
4. Block transfers if adequacy cannot be demonstrated.

Step 7 — Appoint a Data Protection Officer (DPO)

1. Assign oversight for biometric processing.
2. Conduct regular compliance audits.
3. Act as liaison with regulators.

Step 8 — Maintain a Compliance Register

1. DPIA reports
2. Consent logs
3. Data-retention schedules
4. Access-control records
5. Vendor assessments

Documents Required

• DPIA
• Consent forms
• Privacy notices
• Cross-border transfer assessments
• Internal policies (security, retention, access)
• Vendor due-diligence records
• Licensing documents
• Biometric system specifications

Authorities

• UAE Data Office (federal PDPL regulator)
• Sector regulators (as applicable)
• Free-zone DP authorities (DIFC, ADGM)
• Law-enforcement for copyright violations

Practical Compliance Checklist

• □ Confirm licensing activity permits biometric collection
• □ Conduct DPIA before deployment
• □ Implement explicit-consent workflow
• □ Deploy encryption and access controls
• □ Restrict retention periods
• □ Document withdrawal-of-consent workflows
• □ Prohibit non-adequate transfers
• □ Execute vendor agreements with DP clauses
• □ Maintain audit-ready documentation

Template: Biometric Consent Clause (Example)

“By providing affirmative consent, the Individual acknowledges and agrees that the Controller may collect, store, and process the Individual’s biometric identifiers, including facial-recognition data, solely for the Purpose described in this Notice. The Individual may withdraw consent at any time, upon which all biometric processing will cease, and the Controller will delete the data unless retention is required by applicable law. No biometric data will be transferred outside the UAE without ensuring adequate protection in accordance with applicable UAE data-protection legislation.”

Frequently Asked Questions