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Introduction
The procedures governing the submission and review of insurance claims in the UAE are primarily set out in Federal Decree-Law No. (48) of 2023 Regulating Insurance Activities (“Insurance Activities Law”) along with Insurance Authority Board Resolution No. (33) of 2019 Concerning the Regulation of the Committees for the Settlement and Resolution of Insurance Disputes amended by Insurance Authority Board of Directors’ Resolution No. (9) of 2020 (“Regulation of the Committees for the Settlement and Resolution of Insurance Disputes”). These frameworks operate in parallel with the general administrative procedures followed across UAE tax laws.
The insurance claim pathway consists of several administrative and judicial stages, involving the Insurance Company, SANADAK, and ultimately the UAE Courts. A clear understanding of these steps is crucial for both individuals and businesses to protect their rights and prevent unnecessary delays or rejections during the claims process.
In recent years, the UAE insurance dispute landscape has been significantly reshaped by the establishment of SANADAK, the country’s first Financial & Insurance Ombudsman Unit. Effective from March 2024, SANADAK introduced a more efficient, transparent, and consumer‑friendly mechanism for resolving insurance complaints, substantially reducing the need for conventional court intervention.
SANADAK now functions as the UAE’s first legally established, fully independent ombudsman body dedicated to safeguarding consumer rights and addressing disputes arising from interactions with Licensed Financial Institutions and Insurance Companies. It has also assumed all responsibilities previously held by the Central Bank’s Consumer Protection Department and the Insurance Dispute Resolution Committee, providing a unified and streamlined platform for complaint resolution.
Key Procedures for filing an Insurance Claim:
Procedures before the Insurance Company:
- Any stakeholder entitled to benefits under an insurance policy must first submit their Insurance Claim directly to the Insurance Company.
- The Insurance Company shall handle Insurance Claims in accordance with the terms of the policy and applicable UAE legislation. This includes adhering to the following procedures:
- Issuing a Decision on the Claim: The Insurance Company must issue a decision regarding the Insurance Claim in line with the rules of professional conduct and ethics set out in the relevant regulatory instructions.
- Providing Written Reasons for Rejection: If the Insurance Claim is rejected, whether fully or partially, the Insurance Company is required to clearly state the reasons for its decision in writing.
- If a dispute arises regarding an insurance claim, or if the stakeholder disputes the clarifications provided by the Insurance Company, the stakeholder may file a complaint with the Insurance Authority (“SANADAK”).
- Complaints shall be submitted in accordance with SANADAK’s procedural requirements. Upon receipt, the Authority will request clarifications from the Insurance Company (the “Defendant”) through its electronic system. The Defendant shall provide these clarifications within five (5) working days.
- The Complainant may dispute the Defendant’s clarifications and request that the matter be referred to the Committee for the Settlement and Resolution of Insurance Disputes. The Committee is chaired by a judge, with one or more judges appointed by the Central Bank of the UAE (CBUAE) as members.
- If the Committee is unable to resolve the insurance dispute through reconciliation, it will proceed with formal dispute resolution procedures.
- The Committee shall study and decide on the Insurance Disputes referred to it - including all submitted documents, details, and supporting information - within twenty (20) working days from the date it receives all required materials. When necessary, this period may be extended for similar additional durations.
- The parties will be notified of the Committee's Order by registered mail, through a licensed courier company, by email, or via remote communication technology. The Committee's Order carries the force of a Writ of Execution in accordance with applicable UAE laws.
- The Committee's Order in disputes valued at AED 50,000 or less is final and cannot be appealed. Such decisions become immediately enforceable upon issuance.
- Either party - the stakeholder or the Insurance Company - may challenge the Committee’s Order by filing an appeal before the Hon’ble Court of Appeal, provided the dispute value exceeds AED 50,000. The Appeal shall be filed within thirty (30) days from the date the Oreder was issued or from the date the party became aware of it. Failure to comply with this timeframe renders the appeal inadmissible.
- Judgments issued by the Hon’ble Court of Appeal are final and binding for disputes where the value does not exceed AED 500,000.
- For disputes exceeding AED 500,000, either party may file a second appeal before the Hon’ble Court of Cassation within thirty (30) days from the date the Court of Appeal issued its judgment.
Conclusion
- Filing an insurance claim in the UAE is a structured process that requires timely action and strict adherence to the procedural requirements set out in the Insurance Activities Law. A clear understanding of these steps is essential to ensure fairness and avoid procedural pitfalls.
- With BDO’s specialized expertise in insurance and dispute‑resolution matters, we provide clients with comprehensive guidance and representation at every stage of the process, delivering clarity, confidence, and continuity from initiation to conclusion.