The following is the first of a two-part guest post on Artificial Intelligence (AI) regulations in the Gulf Cooperation Council (GCC) by Muneera Al-Khalifa, legal research fellow, working with Foreign Law Specialist George Sadek at the Global Legal Research Directorate of the Law Library of Congress. This post is part of our Frequently Asked Legal Questions (FALQs) series. Muneera has previously written a FALQ post on Anti-Domestic Violence Legislation in Bahrain.
Artificial Intelligence is reshaping economies and societies worldwide, and the Arab world is no exception. For example, Gulf Cooperation Council (GCC) member states are actively working to become leaders in this rapidly evolving technological landscape. This blog describes AI-specific laws, policies, and regulations within the six GCC member states. This two-part blog post covers three countries at a time: the United Arab Emirates, Saudi Arabia, and Bahrain in the first blog post and Qatar, Kuwait, and Oman in the second part.
1. How is AI regulated in The United Arab Emirates?
The United Arab Emirates (UAE) has developed a comprehensive policy framework to regulate AI. In October 2017, the UAE launched its National Strategy for AI 2031. This strategy aims to achieve the objectives of the UAE Centennial 2071 plan and to position the UAE as a global leader in AI. In 2017, the UAE became the first country to appoint a Minister of State for AI and the first to create a dedicated AI Ministry, referred to as the Artificial Intelligence, Digital Economy, and Remote Work Applications Office.
The UAE’s National Strategy for AI 2031 emphasizes the importance of robust governance and effective regulation to ensure the responsible development and deployment of AI. Among its eight strategic objectives is the goal to “Ensure Strong Governance and Effective Regulation,” reflecting that the UAE is committed to establishing legal frameworks for overseeing AI technologies responsibly. In alignment with this objective, the UAE has introduced several initiatives, including:
- AI Ethics Principles and Guidelines: In December 2022, the UAE introduced its these non-binding guidelines. They were designed to promote the ethical use, development, and deployment of AI systems across both the public and private sectors. Also, the guidelines focus on transparency, accountability, and fairness.
- The UAE Charter for the Development and Use of AI: In June 2024, the UAE adopted the non-binding Charter for the Development and Use of AI to support the strategic goals of the UAE’s National Strategy for AI 2031. The charter outlines 12 principles to guide the ethical and inclusive implementation of AI technologies, ensuring compliance with existing laws and agreements governing AI in the UAE. It aims to create a thriving environment that prioritizes the highest standards of safety and privacy while emphasizing the importance of transparency, governance, and accountability. The charter also addresses the challenges posed by AI algorithms and the importance of tackling algorithmic bias to foster a fair and equitable environment for all community members.
- International Policy on AI: In September 2024, the UAE Cabinet introduced a public policy document outlining its international stance on AI Policy to prevent the misuse of AI technologies. The policy seeks to foster an ecosystem that promotes innovation while preparing the UAE to address future challenges and capitalize on emerging opportunities in the rapidly evolving AI sector. This policy is grounded in six key principles that reflect its priorities and values— “progress, collaboration, community, ethics, sustainability, and safety—ensuring that AI development aligns with ethical, social, and environmental considerations. ” Additionally, this policy expands on the UAE Charter for the Use and Development of AI, providing a strategic framework that harmonizes national AI objectives with international best practices.
In 2018, the UAE enacted Federal Decree Law No. (25) of 2018 on the Projects of a Future Nature. The law authorizes the Cabinet to grant interim licenses for innovative projects utilizing modern or AI-based technologies if there is no legislation in the state to regulate them. The Cabinet may establish conditions and procedures for these projects and may temporarily exempt them from any federal legislation as needed for their implementation.
In 2024, the Government of the Emirate of Abu Dhabi enacted Law No. (3) of 2024, to establish the Artificial Intelligence and Advanced Technology Council (AIATC). The Council is responsible for regulating projects, investments, and research associated with AI and advanced technologies within Abu Dhabi.
2. How is AI regulated in Saudi Arabia?
Saudi Arabia is actively developing frameworks to regulate AI. In August 2019, the Saudi Data and Artificial Intelligence Authority (SDAIA) was established by Royal Order No. (A/471). SDAIA’s mission is to advance the goals of Vision 2030, a comprehensive strategic framework launched in 2016 with the primary goal of reducing the Kingdom’s dependence on oil and diversifying its economy. SDAI aims to unlock Saudi Arabia’s full potential in alignment with the National Strategy for Data and Artificial Intelligence, which SDAIA launched in 2020.
SDAIA is at the forefront of these efforts by developing policies and guidelines to ensure the responsible development and deployment of AI. The Saudi Council of Minters Resolution No. (292) of December 24, 2019, defines SDAIA’s organizational mandates. This resolution tasks SDAIA with establishing governance frameworks, policies, and standards for data and AI, as well as overseeing their implementation in coordination with relevant government entities. SDAIA exercises all the powers and authorities necessary to achieve its objectives. Additionally, it holds primary jurisdiction over all matters related to the operation, research, and innovation in the data and AI sectors. SDAIA also governs data and AI technologies to mitigate potential negative implications.
In September of 2023, SDAIA issued a document titled Principles of AI Ethics to guide the ethical development and deployment of AI technologies within Saudi Arabia. SDAIA actively reviews and updates the Principles of AI Ethics and monitors compliance with them. It also develops national guides, standards, and directives to promote effective management and dissemination of AI ethics across various sectors. Additionally, SDAIA is responsible for:
- AI Ethics Compliance Measurement: Regularly assessing and measuring the compliance of adopting entities based on established mechanisms, either directly or in collaboration with sector regulators. This includes auditing AI ethics activities when necessary.
- AI Ethics Compliance Monitoring: Conducting investigations and audits to ensure adherence to these principles, with the support of national regulatory authorities. These authorities are tasked with regulating AI activities within specific sectors in Saudi Arabia. SDAIA collaborates with these entities to ensure that AI applications comply with established ethical standards and regulations.
In January 2024, SDAIA issued two Generative AI Guidelines related to the adoption and use of generative AI systems, namely:
- Generative AI Guidelines for the Government: The first guideline provides regulatory guidance for government employees on the use and processing of government data in generative AI. These guidelines were developed to promote the responsible and effective use of generative AI tools and services in government transactions. They emphasize the importance of handling government data in compliance with the applicable laws and regulations of the Kingdom of Saudi Arabia
- Generative AI Guidelines for the Public: The second guideline is aimed at educating and guiding individuals on the responsible use of generative AI technologies. It applies to all stakeholders engaged in the design, development, deployment, implementation, or use of generative AI systems within Saudi Arabia.
In September of 2024, SDAIA introduced the AI Adoption Framework, a comprehensive guide designed to facilitate AI adoption across all sectors. The framework defines strategic directions and priorities for establishing an AI unit, provides guidelines, and outlines essential steps for AI adoption in alignment with best practices. It also evaluates compliance with current regulations and policies. It assesses the maturity of internal processes governing the use of AI technologies and applications, ensuring responsible and effective AI implementation.
Furthermore, in April 2023, the Saudi Authority for Intellectual Property released a Draft Intellectual Property Legislation for public consultation from April 5, 2023, to May 4, 2023. The draft addresses provisions related to intellectual property generated by AI. Chapter three of the draft legislation regulates AI and emerging technologies, including initiatives aimed at promoting and fostering their development. It further stipulates that intellectual property generated by AI will be deemed part of the public domain in cases where there is no evident contribution from a natural person. Similarly, the work of an AI could be part of the public domain where innovation is independently achieved by AI without any human involvement.
3. How is AI regulated in Bahrain?
The third country that I would like to highlight in this blog is the Kingdom of Bahrain. In line with Bahrain’s Economic Vision 2030, the Government Plan 2019-2022, and the Digital Government Strategy 2022, the Kingdom of Bahrain has taken significant steps toward regulating AI by enacting the region’s first comprehensive AI law. On April 28, 2024, the Shura Council, the Upper House of the National Assembly (Bahrain’s Parliament), unanimously approved a standalone AI Regulation Law, comprising seven chapters and a total of 38 articles.
Following extensive consultations with various ministries and organizations, the bill was forwarded to the government for formal drafting and subsequent presentation to the parliament. The new AI Regulation Law is designed to govern the development and deployment of AI within Bahrain. Key provisions include:
- Duties and Prohibitions: The law emphasizes the importance of regulating AI technologies and their applications in surgical operations, radiology, early disease prediction, examination, diagnosis, and treatment, as well as in educational, engineering, tourism, sports, media, judicial, scientific, and other sectors. The law requires ministers to establish regulations governing the use of AI within their respective sectors. (Art. 8.) The law strictly prohibits:
- Uploading or installing personal images that damage an individual’s reputation or dignity. (Art. 9(1).)
- Manipulating or altering speeches, official statements, or written communication. (Art. 9(2).)
- Modifying, editing, or tampering with textual, audio, or visual content related to individuals without their explicit consent. (Art. 9(3).)
- Making decisions regarding human life, restricting human freedom, or affecting bodily integrity based solely on AI systems (Art 12.)
- Establishment of an AI Unit: To oversee and monitor compliance with the provisions of this law, establish and enforce sustainable rules and regulations to ensure the security and safety of AI systems and their use, and impose penalties for violations of this law. (Art. 15.)
- Licensing and Appeals: Entities are required to obtain a license from the AI Unit to program, process, develop, or sell AI systems. The law also outlines the procedures for applicants to exercise their right to appeal a rejection decision. (Arts. 18, 19, 20.).
- Civil Liability: Anyone who incurs damage as a result of programming, processing, or development activities related to AI technologies may seek compensation from the programmer, processor, or developer. In the event of damage caused by a robot or an electronically programmed machine, the owner of the robot or machine shall be held liable, unless the harm results from an external cause beyond their control. (Arts. 21, 22.)
- Administrative Penalties and Sanctions: The law establishes penalties for violations of its provisions, as well as any related regulations or decisions issued for its implementation. These administrative penalties include:
- Warnings: Issuance of a warning requiring the violator to cease the violation within a specified timeframe.
- License Revocation: Revocation of the license issued by the AI Unit for programming, processing, developing, or selling AI systems.
- Daily Administrative Fines: Imposition of administrative fines calculated daily to compel the violator to cease the violation. These fines are capped at BHD 100 (approx. USD$266) per day for a first-time violation and BHD 200 (approx. USD$532) per day for repeat violations committed within three years of the previous violation. In all cases, total administrative fines may not exceed BHD 10,000 (approx. USD$26,500).
Sanctions include imprisonment for up to three years and fines ranging from BHD 1,000 (approx. USD$2,660) to BHD 20,000 (approx. USD$53,200), depending on the severity of the offense. (Arts. 23 to 29.) Additionally, an attempt to commit any of the crimes outlined in this law is punishable by a penalty of up to half the maximum penalty prescribed for the completed offense. (Art. 31.)
Without prejudice to the rights of bona fide third parties, the court may, upon conviction, order the confiscation of any devices, programs, tools, or systems used in committing the crimes stipulated under this law. Furthermore, in addition to fines imposed on natural persons, corporate entities may be subject to double the fines prescribed for the crime if any offense stipulated in this law is committed in their name, on their behalf, or for their benefit, provided the offense results from an act, omission, consent, concealment, or gross negligence of their employees. In cases of recidivism, the court may also order the dissolution of the corporate entity or the temporary or permanent closure of its headquarters, as deemed appropriate. (Arts. 32, 33.)
In 2019, Bahrain became one of the first countries in the world to pilot the World Economic Forum’s new AI Procurement Rules for the public sector. These guidelines were designed to assist governments in adopting AI technologies responsibly and sustainably. The guidelines were piloted with government departments and agencies worldwide, starting with Bahrain, the United Kingdom, and the Dubai Electricity and Water Authority in the UAE.
The Kingdom of Bahrain has also developed a set of Principles to Guide the Ethical Use of AI, ensuring that the development and deployment of AI technologies align with societal values and human rights. These principles emphasize responsible AI governance, in particular transparency, accountability, inclusivity, and the protection of privacy and personal freedoms. Additionally, Bahrain introduced a GCC AI Ethics Guideline Initiative during the Global AI Summit 2024 in Riyadh, an event organized by SDAIA in collaboration with UNESCO. This initiative aims to facilitate the implementation of a unified AI ethics guideline across the GCC region.
4. Where can I find additional resources?
For additional legal developments in the above-mentioned jurisdictions, visit the Law Library resource, the Global Legal Monitor.
- Global Legal Monitor: Bahrain
- Global Legal Monitor: Saudi Arabia
- Global Legal Monitor: United Arab Emirates
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