On 31 July 2021, the Dubai Health Authority (DHA) issued a circular (Circular) stating that DHA licensed health facilities cannot offer PCR swabs and vaccination services for COVID-19 in Dubai through third party digital platforms that are not approved by DHA.

Based on the Circular, all e-commerce aggregators and marketplaces must register themselves under DHA’s e-services portal called the Sheryan portal.  In relation to the steps, aggregators will have to apply for a new “facility license” and opt for “Tele-health”, under which they may select “aggregator/online booking”.

The above Circular provides a helpful clarification because previously, it was not apparent whether e-commerce aggregators were required to obtain the approval of the DHA for being an intermediary between DHA licensed entities and the general public.  Furthermore, the DHA e-services website appeared to provide a registration mechanism only for healthcare companies.  As such, it was understood that the DHA licensed entity would have to procure the relevant approvals to list their products or services on a third-party aggregator.  The Circular now clarifies that third-party aggregators must also obtain a license from the DHA to facilitate the provision of healthcare services.

The DHA Circular may be accessed here.

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This article is for general information purposes only and does not constitute legal or professional advice. It should not be used as a substitute for legal advice relating to your particular circumstances. Please note that the law may have changed since the date of this article.