Non-Muslim places of worship have 15 days to respond to violation notices, with failure to do so potentially treated as evidence of a breach.
The UAE has introduced new administrative penalties for non-Muslim places of worship that breach regulations governing their operations.
The rules apply to violations of Federal Law No. 9 of 2023 on the Regulation of Places of Worship for Non-Muslims, its Executive Regulations and related decisions.
Penalties range from warnings and fines starting at Dh5,000 to temporary suspension of activities. Fines increase for repeat offences, with some violations attracting penalties of up to Dh750,000 by the third breach. Temporary suspensions of up to three months may also be imposed and extended for similar periods.
The violations and corresponding penalties include:
1. Operating without renewing a licence
Non-Muslim places of worship that continue operating without renewing their licence will receive a warning for the first violation, followed by fines of Dh25,000 for the second and Dh50,000 for the third. A fourth violation may result in a temporary suspension of activities for up to three months.
2. Operating without an appointed supervisor
Places of worship operating without a supervisor appointed by the competent council will receive a warning for the first violation, followed by fines of Dh5,000 and Dh10,000 for subsequent breaches. Further violations may lead to a temporary suspension of activities for up to three months.
3. Failing to hold an annual meeting
Failure to hold the annual meeting within the prescribed timeframe carries a warning for the first violation, followed by fines of Dh15,000 for the second and Dh30,000 for the third. Further breaches may result in a temporary suspension of activities for up to three months.
4. Receiving donations from outside the UAE
Collecting or receiving donations, gifts, aid, bequests or grants from individuals or organisations outside the UAE carries fines of Dh100,000 for the first violation, Dh250,000 for the second and Dh500,000 for the third. Further breaches may lead to a temporary suspension of activities for up to three months.
5. Transferring funds abroad without approval
Transferring donations, financial support or other funds outside the UAE without prior approval from the competent authority carries fines of Dh50,000 for the first violation, Dh100,000 for the second and Dh250,000 for the third. Further violations may result in a temporary suspension of activities for up to three months.
6. Operating without a local bank account
Places of worship are required to maintain an account with a national bank operating in the UAE. Operating without one attracts a warning for the first violation, followed by fines of Dh10,000 and Dh20,000 for subsequent breaches. Further violations may lead to a temporary suspension of activities for up to three months.
7. Spending cash before depositing it into an approved bank account
Using cash before depositing it into the place of worship’s approved bank account is also classified as a violation. The corresponding penalties were not included in the supplied details.
8. Failing to report bank account details
Places of worship must submit their bank account details to the competent authority within 10 days of opening an account. They must also report any changes to the bank holding their funds.
Failure to comply carries a warning for the first violation, followed by fines of Dh5,000 and Dh10,000 for subsequent breaches. Further violations may result in a 10-day suspension of activities.
9. Failing to maintain financial and administrative records
Places of worship must maintain records, books and electronic systems relating to their activities at their premises.
Failure to comply carries a fine of Dh50,000 for the second violation and Dh100,000 for the third. Further breaches may result in a temporary suspension of activities for up to three months.
10. Destroying records without approval
Destroying records or books without prior approval from the competent authority carries fines of Dh25,000 for the first violation, Dh50,000 for the second and Dh100,000 for the third. Further breaches may result in a temporary suspension of activities for up to three months.
11. Spending funds on unrelated purposes
Places of worship must use their funds only for the purposes for which they were established. Breaching this requirement carries fines of Dh25,000 for the first violation, Dh50,000 for the second and Dh150,000 for the third. Further violations may lead to a temporary suspension of activities for up to three months.
12. Using premises for unauthorised purposes
Using a place of worship for purposes not specified in its constitution carries fines of Dh100,000 for the first violation, Dh200,000 for the second and Dh400,000 for the third. Further breaches may result in a temporary suspension of activities for up to three months.
13. Amending the constitution without approval
Amending a place of worship’s constitution without prior approval from the competent authority carries a warning for the first violation, followed by fines of Dh10,000 for the second and Dh25,000 for the third. Further violations may lead to a temporary suspension of activities for up to three months.
14. Changing board members without approval
Changing the chairperson or membership of a place of worship’s board without approval carries fines of Dh25,000 for the first violation, Dh50,000 for the second and Dh100,000 for the third. Further breaches may result in a temporary suspension of activities for up to three months.
15. Changing the appointed supervisor without approval
Changing a place of worship’s appointed supervisor without approval from the competent authority carries a warning for the first violation, followed by fines of Dh5,000 for the second and Dh10,000 for the third. Further breaches may lead to a temporary suspension of activities for up to three months.
16. Failing to provide requested information
Places of worship that fail to provide data or information requested by the competent authority about their operations face fines of Dh25,000 for the first violation, Dh50,000 for the second and Dh100,000 for the third. Further breaches may result in a temporary suspension of activities for up to three months.
17. Failing to cooperate with authorities
Refusing to cooperate with officials, withholding requested information or documents, or preventing them from entering the premises to perform their duties carries fines of Dh50,000 for the first violation, Dh100,000 for the second and Dh250,000 for the third. Further violations may lead to a temporary suspension of activities for up to three months.
18. Failing to submit annual budgets and financial statements
Places of worship must submit their annual budgets and financial statements to the competent authority within three months of the end of their financial year.
Failure to meet this deadline carries a warning for the first violation, followed by fines of Dh10,000 for the second and Dh25,000 for the third.
19. Conducting religious activities outside the premises
Holding prayers, rituals or religious ceremonies outside a place of worship’s premises carries fines of Dh100,000 for the first violation, Dh200,000 for the second and Dh400,000 for the third. Further breaches may result in a temporary suspension of activities for up to three months.
20. Holding events without approval
Organising conferences, seminars, gatherings or other events inside a place of worship without approval, or exceeding the scope of an approval granted, carries a warning for the first violation, followed by fines of Dh15,000 for the second and Dh30,000 for the third. Further breaches may lead to a temporary suspension of activities for up to three months.
21. Conducting rituals that threaten safety
Practising rituals that involve harming oneself or others, or that threaten the health, safety or security of worshippers or employees, carries a fine of Dh100,000. Further violations may result in a temporary suspension of activities for up to three months.
22. Engaging with foreign religious organisations
Holding meetings or conferences abroad, or joining places of worship, organisations, associations or other entities based outside the UAE, carries fines of Dh250,000 for the first violation, Dh500,000 for the second and Dh750,000 for the third. Further breaches may lead to a temporary suspension of activities for up to three months.
23. Collecting or advertising donations
Collecting donations, allowing others to collect them or promoting fundraising through audio, print, visual or social media channels, or any other means, carries fines of Dh100,000 for the first violation, Dh250,000 for the second and Dh500,000 for the third. Further violations may result in a temporary suspension of activities for up to three months.
24. Establishing ties with foreign diplomatic or official institutions
Establishing formal or informal relations, in any capacity, with diplomatic or official institutions of any country carries fines of Dh250,000 for the first violation, Dh500,000 for the second and Dh750,000 for the third. Further breaches may lead to a temporary suspension of activities for up to three months.
Fines must be paid within 30 days
Administrative fines must be paid within 30 days of the penalty decision receiving final approval.
The resolution also requires competent authorities to maintain a register documenting violations and penalties imposed on non-Muslim places of worship. Local authorities must submit quarterly reports to the Ministry detailing the violations recorded and penalties imposed in their respective jurisdictions.
The Cabinet may also amend the list of administrative violations and penalties by adding, removing or modifying entries.
The resolution will be published in the Official Gazette and will come into effect on the day after its publication.
15 days to respond to violations
The resolution outlines the procedure for dealing with violations. Authorities must first prepare a report detailing the breach and notify the place of worship, giving it 15 days to submit a response.
Failure to respond within this period may be treated as evidence that the violation occurred, unless the place of worship provides evidence to the contrary.
Once the response period has elapsed, the competent authority will review the case and determine the appropriate administrative penalty. The place of worship must be notified of the decision within 15 working days of its issuance.
Activities can be suspended
The resolution also sets out the conditions under which a place of worship’s activities may be temporarily suspended. During the suspension period, the establishment will not be permitted to carry out any activities.
Authorities may also require board members, supervisors, religious officials or employees involved in a violation to attend training courses on the governance, regulation and management of places of worship.
Places of worship can challenge penalties
Places of worship have 15 days from receiving notification of an administrative penalty or measure to file a grievance with the competent authority.
The grievance must set out the reasons for the objection and include relevant supporting documents and information.
Authorities must decide on the grievance within 30 working days of receiving a complete submission. They may uphold the original penalty, replace it with a less severe measure or cancel it.
If no decision is issued within the specified period, the grievance will be deemed to have been rejected.
