Artificial Intelligence Due Diligence Requirements Under UAE National AI Strategy

The United Arab Emirates (UAE) has firmly established itself as a global leader in the adoption and regulation of artificial intelligence (AI). With the launch of the UAE National AI Strategy 2031, the nation has demonstrated a visionary commitment to integrating AI across all sectors, from government operations to private enterprise. However, as the use of AI accelerates, so too does the need for stringent due diligence to ensure that AI applications are ethical, secure, and aligned with national objectives. In particular, AI-related due diligence has become a cornerstone requirement, especially for businesses involved in transactions like mergers and acquisitions.

One of the most critical aspects for businesses to consider today is the role of due diligence services for mergers & acquisitions in Dubai. As companies increasingly leverage AI technologies, potential investors, acquirers, and stakeholders must thoroughly evaluate the AI assets, strategies, and compliance frameworks of their targets. The UAE's regulatory environment now mandates a more in-depth scrutiny of AI systems, reflecting the broader objectives of national security, economic growth, and ethical standards.

The UAE National AI Strategy: An Overview


Launched in 2017, the UAE National AI Strategy 2031 outlines ambitious goals, including positioning the UAE as a global leader in AI by fostering innovation, research, and regulation. The strategy envisions AI's integration across vital sectors such as education, healthcare, energy, transportation, and space exploration. It emphasizes principles such as transparency, security, and the ethical use of AI.

With the government's proactive stance, businesses operating in the UAE are now expected to align their AI initiatives with these national objectives. Companies must not only invest in AI but also demonstrate responsible stewardship of technology through comprehensive due diligence, especially when it involves corporate restructuring, funding rounds, or cross-border deals.

Due Diligence Requirements for AI Under UAE Regulations


The evolving regulatory landscape places significant due diligence requirements on companies involved in the AI sector. These requirements ensure that organizations are not only legally compliant but also ethically responsible. The key areas that due diligence must cover include:

  1. Data Privacy and Protection: AI systems often require large datasets. Companies must ensure their data collection, storage, and processing practices comply with the UAE’s data protection laws, including the UAE Data Protection Law (Federal Decree-Law No. 45 of 2021).


  2. Intellectual Property Rights: Organizations must validate the ownership and licensing rights of AI algorithms, data sets, and related IP assets. This is a critical part of due diligence services for mergers & acquisitions in Dubai, as acquiring AI technologies without clear ownership can result in significant legal disputes.


  3. Algorithmic Transparency and Bias: Firms must demonstrate that their AI systems are free from biases and operate transparently. Ethical considerations are paramount, particularly in sectors like healthcare, finance, and public safety.


  4. Regulatory Compliance: Companies must ensure their AI activities are aligned with sector-specific regulations, including those issued by the UAE’s Telecommunications and Digital Government Regulatory Authority (TDRA) and other sectoral bodies.


  5. Cybersecurity Measures: Given the sensitive nature of AI systems, robust cybersecurity frameworks must be in place to safeguard against breaches, data leaks, and other vulnerabilities.


  6. Ethical Frameworks: Businesses must provide evidence of ethical AI deployment, ensuring that AI systems promote fairness, accountability, and respect for human rights.



Importance of AI Due Diligence in Mergers and Acquisitions


In mergers and acquisitions, AI assets are increasingly a focal point of value assessment. When a company is valued, its AI capabilities—such as proprietary algorithms, predictive models, and machine learning platforms—often constitute a significant portion of its intangible assets.

However, without thorough due diligence, acquirers face numerous risks, including:

  • Inherited liabilities from non-compliant AI systems


  • Exposure to cybersecurity threats


  • Reputation damage from unethical AI practices


  • Financial loss due to inaccurate valuation of AI assets



Hence, due diligence services for mergers & acquisitions in Dubai must incorporate specialized AI assessments. These assessments evaluate not just the technical robustness of AI technologies but also their compliance with regulatory, ethical, and market standards.

Best Practices for Conducting AI Due Diligence


For companies seeking to undertake AI due diligence in line with UAE’s expectations, the following best practices are recommended:

Engage Specialized Experts


Given the technical complexity and regulatory nuances of AI, it is crucial to engage experts who specialize in AI technologies, cybersecurity, intellectual property, and UAE regulatory compliance. Legal advisors, technical auditors, and AI ethicists should work collaboratively.

Conduct Comprehensive Risk Assessments


A thorough evaluation should be performed, examining data governance policies, training data sources, bias mitigation strategies, and security architectures. This is particularly important when AI systems involve sensitive sectors like healthcare or finance.

Validate IP and Licensing Agreements


Acquirers must ensure that all AI-related intellectual property has clear, uncontested ownership, or that appropriate licensing agreements are in place. Any third-party components or datasets used must be reviewed for potential infringement issues.

Focus on Ethical AI


The UAE National AI Strategy emphasizes ethical AI use. Organizations should demonstrate active implementation of fairness, transparency, and accountability measures within their AI systems. Ethical certifications or independent audits can serve as strong validation.

Align with UAE Regulatory Frameworks


Given the UAE’s proactive regulatory environment, businesses must prove their compliance not just with current laws but also their readiness to adapt to evolving standards. This demonstrates resilience and future-proofing to potential investors or buyers.

The Role of Due Diligence Services Providers in Dubai


Professional service providers in Dubai specializing in AI due diligence offer a comprehensive suite of evaluations tailored to the UAE’s specific requirements. These providers deliver insights on technology readiness, market viability, legal compliance, and ethical standing.

Particularly in the context of due diligence services for mergers & acquisitions in Dubai, specialized firms offer:

  • AI System Audits


  • Cybersecurity Penetration Testing


  • Intellectual Property Validation


  • Regulatory Compliance Checks


  • Ethical AI Assessments


  • Strategic Recommendations for Risk Mitigation



Leveraging the expertise of these service providers ensures that acquirers are well-equipped to make informed decisions, optimize transaction value, and safeguard their investments.

Conclusion


As AI continues to reshape industries in the UAE and beyond, the importance of rigorous due diligence cannot be overstated. The UAE National AI Strategy has set a high bar for the ethical, secure, and compliant deployment of AI technologies. Organizations looking to invest, merge, or acquire must approach AI with a lens of comprehensive scrutiny.

Engaging specialized due diligence services for mergers & acquisitions in Dubai is not merely a best practice; it is increasingly becoming a regulatory and ethical necessity. By adhering to robust AI due diligence frameworks, companies ensure they contribute positively to the UAE’s AI-driven future, protect their stakeholders, and achieve sustainable growth in one of the world’s most dynamic economies.

 

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