Is a cookie banner mandatory in the UAE?

The UAE PDPL, Federal Decree-Law No. 45 of 2021, has no provision written for cookies. But a cookie or tracker that can identify a visitor collects personal data, and processing personal data needs consent unless one of the law's exceptions applies. For analytics and advertising tags, a banner that asks first is the practical way to have that basis.

That means clear categories, a real way to refuse, settings that stay reachable so consent can be withdrawn, and a record of each choice. Until the executive regulations are published, the law’s own consent conditions are the standard to build to.

Companies established in the DIFC or ADGM follow those free zones’ own laws, and the DIFC’s Regulation 9 spells out what a cookie banner must do.