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Dubai International Financial Centre (DIFC) has rolled out amendments to its Data Protection Law ("Law") that came into effect in July 2025 following a consultation earlier in the year. The updates bring the law into greater alignment with the GDPR's approach to enforcement, providing additional protections for data subjects.
The amendments introduced to the Law are as follows:
The revisions were enacted by way of an amending law issued on 8 July 2025 (DIFC Amendment Law No. 1 of 2025) and came into effect on 15 July 2025.
These amendments bring some practical relief to controllers with respect to data sharing with government authorities, but also represent a shift in favour of data subjects with the introduction of a private right of action. The new and increased fines reflect the Commissioner's intention to continue with robust enforcement of the Law as part of efforts to ensure that DIFC legislation and practices remain in line with international standards.
Organisations that operate in the DIFC should review existing DPIA/annual assessment processes and data sharing procedures, and conduct thorough assessments of compliance with the Law in light of the increased litigation risk posed by the new private right of action under the Law.
If you would like to discuss your approach to compliance with the Law, please reach out to our team of Middle East data protection specialists.
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