Flow by flow
The strictest rules here are Abu Dhabi's, under ADHICS v2 and the DoH Responsible AI Standard. Designing to them usually satisfies Dubai and federal buyers too, but confirm that for your case.
| Flow | Verdict | Basis |
|---|---|---|
| Patient data at rest: databases, object storage, logs, backups, disaster recovery | Stays in the UAE | Art. 13 Official; ADHICS CS 1.2(2): cloud "including backup and disaster recovery" in the UAE Official; DoH RAI 3.1.4.5.1 Official |
| AI inference on patient data (compute) | Stays in the UAE | DoH RAI 3.1.4.5.1: "compute and storage infrastructure … must be situated within the UAE" Official |
| Anonymised or de-identified extracts sent to a team abroad | Not in Abu Dhabi | ADHICS DP 1.4(4) covers copies "encrypted, anonymized, deidentified, pseudonymized"; exemptions need DoH approval Official. Outside Abu Dhabi, check whether a Resolution 51/2021 exception applies Secondary |
| Remote development or support access from abroad | Not in Abu Dhabi | ADHICS CS 1.2(3)(c) and CO 9.2(7) Official; DoH RAI 3.1.4.5.1 says remote access "should" be exclusively from within the UAE Official |
| Training or fine-tuning a model on production data | Not allowed (Abu Dhabi) | DoH RAI 3.1.4.4.2: "Production data shall not be used to train the model." Official |
| Health data transferred under a Resolution 51/2021 exception (e.g. treatment abroad, approved research, insurance) | Only on the exception's conditions | Conditions vary: consent, encryption, anonymisation, or keeping a UAE copy Secondary. In Abu Dhabi, DoH expects its own standards to be followed Secondary |
| Code, containers and model weights deployed into the UAE | Can move in | Not health data. We found no rule restricting inbound software Unverified (our reading, not a regulator statement) |
| Calls to global LLM APIs with public documents, code or synthetic data | Allowed if no health data | Art. 13 covers health data and information Official. Keep prompts free of patient data; in Abu Dhabi that includes de-identified data |
| Telemetry, crash reports, usage analytics sent abroad | Only if content-free | Strip every field derived from patient data. Under ADHICS DP 1.4(4), even de-identified copies count Official |
Design rules we apply
- One region, one boundary. Put every component that touches patient data in UAE regions, including logs, queues, caches, backups and the DR copy, and write the list down.
- Access from inside the UAE. Run production access through a bastion or VDI hosted in the UAE, used by staff based in the UAE. Log every session.
- Software comes in; data doesn't go out. Ship code and weights through CI/CD into the UAE region. Treat any outbound data flow as a design defect until it has a named legal basis.
- Keep training separate from production. Improve models on synthetic data, or on data obtained under a documented approval, never on the live data stream.
- Telemetry stays content-free. Send counts, latencies and error codes; never transcripts, notes, prompts or identifiers.
- Keys are not held by the cloud provider. ADHICS v2 expects encryption keys to be managed independently of the cloud provider. Plan for customer-managed keys or an HSM from the start.
Sources
- Federal Law No. 2 of 2019, Art. 13 (UAE Legislation portal)
- CMS: UAE health data, new data-transfer permissions (Resolution 51/2021), Jun 2021
- DoH: ADHICS v2 standard (PDF)
- DoH: Responsible AI Standard V1 (PDF)
Last checked 18 Oct 2026. Not legal advice. The full analysis is in the Landing Checklist.