UAE lawyers say that a review can cross the legal threshold when it moves beyond commenting on a service and begins attacking an individual’s character.
In the UAE, a negative review can potentially be treated as a criminal offence depending on a key distinction — whether it amounts to legitimate consumer feedback or an unlawful personal attack.
Ahmed Khalil, associate at BSA LAW, explained that legitimate consumer feedback typically involves “expressing an honest and objective opinion about a product, service or customer experience, even if the opinion is negative, provided that it is based on actual facts and does not contain personal insults or defamatory allegations.”
Earlier this month, a social media influencer was fined Dh81,000 after the Abu Dhabi Judicial Department determined that a video she posted about a well-known restaurant amounted to defamation rather than legitimate criticism.
“Based on the published reports, the Court considered that the video in question targeted the restaurant owner personally rather than constituting a genuine review of the restaurant’s services,” Ahmed said.
Hassan Elhais, a legal consultant, said the distinction depends on the purpose, content and manner of the publication. “Legitimate consumer feedback focuses on sharing a genuine experience with a product or service in an objective and factual manner,” he said.
The point at which a review moves beyond the service itself and targets an individual’s character is where it can cross the legal threshold. According to Salam Pappinissery, CEO of YAB Legal Services, the difference lies between an “objective, service-oriented assessment and subjective personal attack”.
Under UAE law, criticism must remain focused on the product or service. When it begins attacking a person’s honour, dignity or moral character, it can move from a review into a criminal matter.
Criminal and civil consequences
In the recent case, the influencer received a criminal penalty of a Dh30,000 fine, was ordered to remove the video, and had the mobile phone used to record and publish the content confiscated. The court also ordered the defendant to pay Dh51,000 in temporary civil compensation.
“The criminal fine represents the punishment imposed by the criminal court for committing an offence under the UAE Penal Code and is payable to the State,” Ahmed explained. “Civil compensation serves a different purpose. It is intended to compensate the injured party for the harm suffered as a result of the defamatory publication.”
Salam described the process as a two-step sequence: a criminal case resulting in a guilty verdict and criminal fine paid to the state, followed by a civil claim for damages and compensation paid to the affected party.
Beyond financial penalties, consequences can include imprisonment of up to two years, confiscation of devices used to publish unlawful content, and possible judicial deportation for expatriate influencers. Under the UAE Cybercrime Law, digital defamation can carry fines ranging from Dh250,000 to Dh500,000, along with potential imprisonment.
A thin line
Lawyers said influencers and consumers should keep a few key principles in mind when posting reviews.
Salam advised focusing only on the product or service and avoiding personal remarks. “Keep reviews strictly tied to measurable consumer touchpoints like flavour, price, delivery and comfort,” he said. “Never make remarks regarding the owner’s character, intentions, integrity or private life.”
Ahmed stressed the importance of ensuring that factual claims are accurate, verifiable and based on genuine experiences, while avoiding false, misleading or unverified allegations.
Elhais said freedom of expression is recognised under UAE law but is not unlimited. “Consumers and influencers have the right to share honest experiences, provided they do so responsibly, truthfully, and without unlawfully harming the reputation or dignity of others.”
He noted that comments such as “the service was slow” or “I did not like the quality of the food” would generally be considered legitimate consumer opinions. However, statements accusing a business of being a “scam” or alleging fraud without evidence could expose the person making the claim to legal liability.
