UAE and Dubai CLPD: Which Regulator Actually Requires CPD Points
If you work in the Gulf legal market and believe the DIFC Courts impose a continuing professional development requirement, you are in good company and you are wrong. The DIFC Courts impose none. Neither does ADGM, and neither does the UAE federal regime.
The requirement that does exist is a Dubai emirate one, administered by the Government of Dubai Legal Affairs Department, and it catches DIFC-registered legal consultants because the bylaw expressly extends into the free zones. It is specific, quantified and tied to annual registration renewal. This guide separates the four regimes, because conflating them is how the misconception took hold.
Dubai: 16 CLPD points a year, and it affects your registration
The governing instrument is Administrative Resolution No. 53 of 2022, issued by the Director General of the Government of Dubai Legal Affairs Department on 21 December 2022. Article 3 provides that it takes effect on publication in the Official Gazette, and Article 2 supersedes Administrative Resolutions 240 of 2015 and 375 of 2016.
The core requirement, in Article 5, is 16 Continuing Legal Professional Development points per Filing Period, split so that at least 8 come from CPD Activities and at least 8 from Accredited CLPD Activities. No single Accredited CLPD Activity counts for more than 4 points, so the requirement cannot be met in two sittings.
Article 2 defines the Filing Period as twelve months running from 1 January to 31 December, which makes Dubai a calendar-year regime rather than a rolling one.
The DIFC composition is different
Article 5 sets a separate composition for legal consultants registered in the DIFC. They also owe 16 points, made up of 8 points from CPD Activities, 2 points for each Professional Development activity selected by the DIFC Academy of Law and approved by the Legal Affairs Department as a CPD Activity, and 6 points from Accredited CLPD Activities, with the same 4-point cap.
This is the provision that explains the confusion. The Academy of Law courses genuinely do carry 2 mandatory CLPD points each, exactly as advertised. The obligation they satisfy is a Dubai one, not a DIFC Courts one.
Who is caught, and who is not
Article 4 applies the scheme to practising Legal Consultants on the Roll, including those in free zones such as the DIFC. It does not apply to non-practising legal consultants, nor to those employed by Government Entities, corporations, companies and other entities that do not provide legal services to the public. In-house counsel in a commercial company are therefore outside it, which is a significant carve-out.
Article 9(1) preserves a further power for the Legal Affairs Department to exempt other categories.
First year, filing and carry-over
- Pro-rata on first registration (Article 5(c)): 100 per cent of the requirement where 9 to 12 months of the Filing Period remain, 75 per cent for 6 to 9 months, 50 per cent for 3 to 6, and 25 per cent for under 3.
- Foreign graduates (Article 6): those newly registered who graduated from non-UAE institutions must complete the special CLPD Programme within twelve months of registration, and pass any other examinations the Department requires.
- Filing (Article 9): the Professional Development Record is due within 30 days of the Filing Period expiring.
- Carry-over (Article 12): a maximum of 2 points. This is tight by international standards.
- Other regulators (Article 11): up to 2 points for training accredited by another regulator the Department approves, which is useful for dual-qualified practitioners but capped low.
- Records (Article 15(a)): retained for 3 years, with audit available on 15 days notice.
What happens if you miss it
Article 14 sets out a graduated process. The CLPD Affairs Committee serves a notice of non-compliance requiring cure within 15 days. The Committee may then grant up to 30 days grace, set a final deadline, or reduce or waive the requirements. On continued failure, the Committee notifies the Competent and Concerned Directorates to take the necessary actions, and the bylaw does not specify what those are.
The real consequence is found in a different instrument. Administrative Resolution No. 51 of 2022, issued the same day, governs registration. For Legal Consultants, Article 9 makes registration valid for one year, renewable, and Article 11(a)(3) requires the applicant to meet the professional development requirements prescribed by the Legal Affairs Department as a condition of renewal. Article 11(a) requires renewal in the last month before expiry.
Article 17(a) permits suspension for up to one year, or striking off, including for failure to renew registration in the practising category and for failure to comply with the applicable legislation and the Department bylaws and instructions.
So CPD compliance is a condition of annual renewal, and failure to renew can end the right to practise in Dubai. That is a genuine enforcement chain, unlike several schemes in the region.
One caveat on advocates
Resolution 53 of 2022 is, by its title, a scheme for Legal Consultants. Advocates are caught by Resolution 51 of 2022, whose Article 13(a)(3) makes meeting the Department professional development requirements a condition of their renewal too, on a one-year cycle under Article 11. But no quantified points scheme for Dubai advocates could be located. The 16-point figure should not be assumed to apply to advocates, and anyone in that category should confirm their requirement with the Department directly.
UAE federal: no CPD requirement
Federal Decree-Law No. 34 of 2022, regulating the legal profession and legal consultation profession, was issued on 3 October 2022 and came into force on 2 January 2023. Article 13 sets ten one-off conditions for registration on the Roll of Practising Lawyers, including Article 13(5), successful completion of the training period determined by the Executive Regulations, which is an entry training period. Article 15 makes listing on the Roll valid for three years, renewable, with renewal conditions delegated to the Executive Regulations. Article 19(2) likewise delegates training conditions.
The Decree-Law itself contains no continuing professional development provision. Article 86 sets the sanctions for breaching professional duties or the Code: warning, administrative fine of AED 5,000 to 30,000, suspension for up to two years, and permanent removal from the Roll or Register.
Cabinet Resolution No. 9 of 2025, approving the Code of Ethics, was issued on 10 February 2025. Article 4(9) makes professional competence a core value requiring practitioners to meet the highest professional standards, and Article 16(3) addresses trainee lawyers, who are to seek knowledge actively and learn from senior lawyers. Neither sets hours, points or a course requirement.
An honest gap. Article 15 of the Decree-Law delegates the renewal conditions to the Executive Regulations, which are Cabinet Resolution No. 8 of 2025, issued 10 February 2025, effective 15 March 2025, published in Official Gazette No. 793 of 14 February 2025. That text could not be obtained from an official source: the legislation portal download endpoint was unreachable and two Ministry of Justice copies were rejected. A secondary reproduction indicates it contains no continuing development provision and no renewal article, with training appearing only for trainee lawyers. Since this is precisely the instrument that sets renewal conditions, anyone relying on there being no federal requirement should verify it against the Arabic original.
At Abu Dhabi level, registration is administered by the Abu Dhabi Judicial Department Lawyers Affairs Committee under the federal regime. Published accounts of its decisions describe Emirati lawyers registered after completing the approved training programme at the Abu Dhabi Judicial Academy, which is entry training, with renewals granted on meeting the approved requirements and no continuing development element. No Abu Dhabi decision imposing CPD could be found.
DIFC Courts: no CPD, and the Academy framing needs correcting
DIFC Courts Order No. 1 of 2025, issued and effective on 30 July 2025, governs rights of audience and registration in Parts I and II of the Register of Legal Practitioners. It imposes no CPD or continuing-training obligation, and sets no registration term and no renewal procedure. Training appears only as a discretionary step: under paragraph 13(b)(iii) the Committee may request that an applicant consider further training on DIFC Courts law and procedure, with registration remaining provisional until the next hearing, and paragraph 13(f) allows a fresh Part II application after twelve months where the applicant can demonstrate changed circumstances or relevant training.
The Guidelines for the Register provide that Part I and Part II registrations are valid for one year and may be renewed annually, with renewal requiring a current Practising Certificate or letter of good standing dated within three months and, for those practising in Dubai, the Legal Affairs Department Card. No training or CPD completion is a renewal condition.
Instead the Courts defer to the home regulator. The Guidelines require a practitioner to be currently actively registered in their own jurisdiction, including participating in the mandatory Continuing Legal Professional Development requirements, if any. Those last two words carry the weight. Important Note 8 reserves a case-by-case power to require training or a designated test to maintain registration, which is discretionary rather than a standing scheme.
Order No. 2 of 2025, the Mandatory Code of Conduct, issued on 30 July 2025 and signed by Chief Justice Wayne Stewart Martin, likewise contains no training or hours requirement. Its competence duties are qualitative: familiarity with the Rules and the Overriding Objective, familiarity with relevant DIFC and Dubai laws, and an obligation to accept proceedings only where the practitioner can handle them promptly and with competence. Breach goes to the Professional and Disciplinary Ethics Committee, and the Chief Justice may suspend, impose conditions or terminate registration, one ground being a lack of appropriate litigation expertise.
Two points of detail are worth noting. Order No. 1 of 2025 does not expressly revoke Order No. 1 of 2019, though the Courts registration page now cites only the 2025 Order; and the 2019 Order provision allowing two years credit toward rights of audience for completing designated training programmes does not carry over into the 2025 Order.
The DIFC Academy of Law markets courses as carrying 2 DIFC mandatory CLPD points each, naming the Dubai Legal Affairs Department as the accrediting body, and describes them as essential for DIFC-registered practitioners. The points are real and the figure matches Article 5 of Resolution 53 of 2022 exactly. Where the framing needs care is in attributing the requirement to the DIFC Courts, whose own instruments contain none.
ADGM: no CPD, and no register of practitioners at all
ADGM is the simplest of the four. The ADGM Courts, Civil Evidence, Judgments, Enforcement and Judicial Appointments Regulations 2015, enacted on 17 December 2015 and amended as recently as 17 October 2025, contain zero occurrences of continuing professional development, continuing legal education or professional development in any form across the whole instrument.
Section 219 governs rights of audience. A person who has practised or been employed as a lawyer for a continuous period of at least five years immediately before appearing has the right of audience; one who has not may seek leave; and any person may appear before the Small Claims, Employment and Real Property Divisions of the Court of First Instance, subject to the Courts rules of conduct. Section 219(2) disapplies the automatic right where the person has been banned or suspended by their approved regulator and the ban has not been lifted or the suspension has not expired.
Section 220 imposes duties on lawyers exercising a right of audience, including a duty to the Court to act with independence in the interests of justice, and defines the relevant conduct rules as those of the home approved regulator.
The ADGM Courts FAQ puts the registration question beyond doubt: the Courts have not instituted a registration system of lawyers as a prerequisite for a right of audience. Registration on the eCourts platform is a filing-access matter, open to any person or organisation. Practice Direction 1, re-issued on 30 November 2023, simply points to sections 219 and 220.
There is one indirect link. Because section 219(1)(a) depends on continuous practice and section 219(2) withdraws the automatic right where the home regulator has suspended the lawyer, a CPD failure at home that resulted in suspension would remove the automatic right of audience in ADGM.
The practical summary
A practitioner position in the Gulf depends on which roll they sit on, not which court they appear in.
- A practising legal consultant on the Dubai Roll, wherever they are based in the emirate including the DIFC, owes 16 CLPD points per calendar year on the composition set for their category, files within 30 days of year end, may carry over 2 points, and needs compliance to renew annually.
- A DIFC Courts registered practitioner who is not on the Dubai Roll owes the DIFC Courts no CPD, but must stay actively registered with their home regulator and hold a current practising certificate or good-standing letter.
- An ADGM advocate owes nothing to ADGM, which has no register, and is exposed only through their home regulator standing.
- A federally registered advocate appears to owe no continuing requirement, subject to the Executive Regulations caveat above.
- In-house counsel in a company not providing legal services to the public are outside the Dubai scheme under Article 4.
For comparison across the jurisdictions covered in this series, Kenya requires five units a year and makes non-compliance professional misconduct, Singapore runs an escalating points system, and India imposes nothing on advocates at all. Dubai 16 points a year with a 2-point carry-over cap and a renewal consequence sits at the stricter end of the range.
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