Change in the UAE’s age of legal capacity and what it means for consumer facing businesses

It has been announced that a new law (Federal Decree Law No. 25 of 2025) will be issued amending the UAE’s Civil Transactions Law (Federal Law No. 5/1985). Whilst the law has not yet been officially published, it is reported that it will enter into force on 1 June 2026.

Change in the UAE’s age of legal capacity

One significant highlight of this law is that it will reduce the age of “majority” in the UAE from 21 to 18.

The practical effect of that will be that from the effective date set by the new law, individuals 18+ will generally be treated as having full legal capacity (as adults) for civil and legal purposes (rather than needing to be 21).

This aligns legal capacity with common international benchmarks, and will reduce the requirements for parental/guardian consent for many legal acts that previously assumed 21 as the threshold - for example, entering into valid contracts.

Implications for consumer-facing businesses 

1. Contract enforceability

For consumer businesses, the biggest impact will be the lower enforceability risks when contracting with customers aged 18–20.

• Before (21 threshold): Businesses faced a higher risk that an 18–20 year old customer could be treated as not fully capable for certain contracts, which could complicate enforcement, collections, chargebacks, and dispute resolution processes etc.
• After (18 threshold): most consumer contracts with customers 18+ would be on a stronger footing, reducing the need for parental/guardian involvement for ordinary consumer contracting.

The above amendment could therefore be seen as a practical win for consumer-facing businesses as it decreases the likelihood that a customer can try to unwind a contract on capacity grounds, or that a regulator/court might do the same.

2. Updates to consumer Terms & Conditions around age-gating language

Many consumer-facing terms in the UAE (and MENA more broadly) are drafted with statements like:

• “You must be 21 or older to create an account / enter into this contract”; or
• “If you are under 21, a parent/guardian must consent.”

With the new threshold:

• Businesses should review and update age eligibility clauses to reflect 18 as the new age of majority (or consciously keep a higher age requirement if justified—see below).
• If a business intentionally keeps 21 as a product/policy threshold (for the purposes of, for example, credit exposure, regulated products, internal risk etc.), it should be drafted as a commercial eligibility rule, rather than a statement of legal capacity.

Why it matters: If a business’ terms still say or imply that 21 is the age of majority, they may be legally inaccurate, and add to confusion in any disputes.

3. Onboarding flows and consent mechanics (clickwrap, app sign-up, web checkout)

Consumer-facing businesses should revisit:

• Age prompts (“I confirm I am aged 21 or over” becomes “18 or over” where appropriate).
• Parental consent flows—these may be unnecessary for many offerings once users are 18+.
• KYC/age verification triggers (especially where businesses currently route users aged 18-20 into a “minors” pathway).

Ultimately, this means simpler onboarding processes and less customer scrutiny for 18–20-year-olds, if they previously required parental/guardian approval.

4. Payments, subscriptions, buy now pay later (BNPL) and credit risk

If a product involves ongoing payment obligations (for example, subscriptions, auto-renewals etc.) or credit-like features (for example, BNPL, financing, postpaid pr delayed payment options etc.):

• Moving the capacity threshold to 18 will expand the population businesses can contract with directly, but it can also increase exposure if younger customers are more likely to dispute, or otherwise be unable to meet, their payment obligations.
• With a lower legal capacity age, businesses should consider tightening:

                 - authorization language for recurring payments;
                 - cancellation/refund terms; and
                 - collections and late-fee approaches (including ensuring compliance with any consumer protection or lending regulations that apply).

5. Customer support, disputes, and chargebacks

This amendment to the age of majority will likely also result in changes in how disputes are framed:

• There will be fewer successful claims that customers were not legally competent for individuals aged 18–20.
• Businesses will have a stronger legal posture when enforcing:

                  - cancellation fees;
                  - minimum terms;
                  - early termination charges;
                  - arbitration/forum clauses; and
                  - limitation of liability and indemnities.

6. Marketing and product access rules

Some businesses may still choose to restrict access to 21+ (for reasons including risk, brand, product suitability, or alignment with other regimes). If so, those businesses should:

• Ensure drafting is based on eligibility (i.e. “You must be at least 21 to buy/use this service”), not because that is the legal age of majority.
• Ensure consistency across:

                 - terms and conditions / terms of use;
                 - privacy notices / data consent mechanisms;
                 - app store age ratings; and
                 - customer-facing FAQs/policies etc. 

7. Data/privacy consents and “adult” permissions

Where a business relies on consent-based processing (for the purposes of, for example, marketing opt-ins, account data use, etc.), shifting legal capacity to 18 can:

• remove the need for parental/guardian consents for users aged 18–20; and
• simplify how businesses document and evidence consent.

However, it should be noted that sectoral rules and platform policies may still impose additional constraints for younger users.

What to do now (business checklist)

Businesses can undertake the following actions to align their age-eligibility measures with the UAE’s new age of legal capacity:

• Audit your consumer terms for any mention of “21” as majority/capacity; update to 18 where that is now the intent.
• Review sign-up/checkout flows (including age confirmations, parental/guardian consent steps, KYC rules etc.).
• Decide if 21+ is still the preferred policy for specific products; if yes, draft it as eligibility, and align all customer-facing documentation and messaging.
• Check regulated product overlays (including, for example, financing/BNPL, postpaid, sector licensing conditions etc.) that may keep stricter age rules.
• Add a clean capacity representation in any terms and conditions (for example that users represent that they are at least 18 years old and have capacity to contract).

For further information on these amendments please contact Ruby Khnom or Zil Rehman.