In short From 1 October 2026, the UAE Media Council requires any AI generated performer, voice, or background face on a free to air or licensed streaming service to be disclosed in the opening credits and in the show's metadata, with a signed Annex A kept on file for two years. News and current affairs are exempt but advertisers must comply, which means a car commercial shot in Dubai this winter now needs a one line AI disclosure in the closing frame if any element was synthetically created or replaced.
Last checked against the sources below: 6 October 2026.
Why the AI disclosure rule matters this week
The Media Council confirmed in a public note on the u.ae portal on 2 October 2026 that the AI labelling clause in Federal Decree Law No 15 of 2025 is now being enforced at the submission stage rather than at the complaint stage. That is a quiet but meaningful shift. Until September the council was answering questions, after 1 October it is rejecting re registration applications that arrive without the required disclosure.
For a production house shooting a brand film in Dubai this winter, the practical effect is that the final master file delivered to the broadcaster or platform must carry the disclosure, and the contract between agency and production company must reference the obligation. The regulator does not yet require a particular on screen graphic, but it does require the credit to read in English or Arabic and to be visible for at least three seconds.
What the law actually says
Federal Decree Law No 15 of 2025 covers media content generally, but Article 7 is the section that touches AI. It runs to a single page and uses the term synthetic media rather than artificial intelligence. The Council's own press release of 14 January 2026 explained that synthetic media means any image, voice, or performance that was created or substantially modified by a generative system, and that the obligation falls on the production company that delivers the master, not on the platform that hosts it.
Who is in scope and who is not
The short version is that the rule applies to anything broadcast on a free to air channel or a licensed streaming service inside the UAE. That includes OTT platforms that hold a Media Council licence, which in practice covers the regional offices of every major streamer, plus the local subscription services run by etisalat and du, plus Shahid.
Out of scope are theatrical releases (those go through the National Media Office film classification route), purely social media clips that have not been licensed as a broadcast service, and news and current affairs programming. Newsrooms are exempt on free expression grounds, and the Council was clear in its January note that a documentary strand that runs for a series is treated as a current affairs programme only if every episode is anchored by an on camera journalist. A branded documentary series that does not have a journalist anchor in every episode is back in scope and needs the disclosure.
Advertisers are in scope regardless of where the spot runs. A car commercial that airs only on a licensed streaming service in the UAE needs the closing frame disclosure. A car commercial that airs only on YouTube and has not been booked through a Media Council licensed service does not. The grey zone is a campaign that runs on both, and the safe answer there is to disclose.
The on screen credit, in plain language
The Media Council has not issued a mandatory graphic. It has issued a mandatory wording test. The credit must contain the phrase synthetic media or the Arabic equivalent, media sintetiyya, and it must name the production company. A typical credit reads This production contains synthetic media. Produced by [Company Name]. The credit has to be on screen for at least three seconds, in a font size that is readable on a phone held at arm's length, and it has to appear in the opening credits block or in the closing credits block, not in a lower third during the programme.
Two practical consequences. First, putting the credit only in the closing block is acceptable for a feature length film or a one off documentary, but the Council has told producers verbally that a weekly series should carry the disclosure in the opening block as well so that a viewer who joins late is not left without context. Second, the credit is in addition to the standard production credits, so it sits next to the director, the DoP, and the editor, not inside the existing credit roll.
The metadata that has to be filed
Every master file delivered to a UAE broadcaster or licensed platform has to carry a metadata field labelled Synthetic Media Disclosure with a yes or no value, and if the value is yes, a free text field listing the elements that were generated or modified. The same field goes into the EPG submission that the broadcaster files with the Council.
For a post house this means building the field into the delivery template before the online is conformed, not after. The most common mistake on the spring season deliveries was that the field was added by hand in the broadcaster's portal, then the portal rejected the file because the field was not present in the MXF header. The fix is to add the field to the export preset in DaVinci Resolve, Premiere, or Avid so it travels with the file.
Annex A, line by line
Annex A is the form the Council will ask for if it audits a delivery. It is one page, six fields, and a signature block. Field one is the production title. Field two is the broadcaster or platform. Field three is a list of every synthetic element, with the timecode in and out. Field four is the tool used, named by version number, so DaVinci Resolve 19.1 with the Speed Editor AI voice module, not DaVinci Resolve. Field five is a one line description of why the element was generated, so voice double for a stunt line that could not be re recorded on set. Field six is the signature of the producer and the post production supervisor, with the date.
The two year retention rule means the form has to be filed somewhere that survives a hard drive failure. A shared drive on the agency server is acceptable. A single hard drive in a producer's desk drawer is not. The Council has not yet said what format the form has to be kept in, so a signed PDF is the safe choice and a scan of a wet signature is better than a typed name.
What the first compliance letters asked for
Two of our clients received letters in the first week of October, both for documentary series that delivered in June and July. The letters were not fines. They were resubmission requests. In each case the broadcaster was told by the Council that the metadata field was missing or that the on screen credit did not contain the phrase synthetic media, and the broadcaster passed that on to the production company. Both clients had to re deliver a corrected master and a corrected EPG entry, and both had to file a retrospective Annex A covering every episode in the series.
The cost of the resubmission was small in cash but large in goodwill. The broadcaster's scheduling team had to be told the series would slip a week, and the platform's marketing team had to pull social clips that had been cut from the episodes. The lesson is that the credit is easier to get right the first time than to fix after delivery, and that the cost of getting it wrong is paid in the relationship with the broadcaster, not in the fine.
The on set workflow that follows
The first change is at the script stage. If a scene calls for a synthetic element, the script breakdown has to flag it, and the budget has to carry a line for the post production work and the Annex A filing. The second change is at the contracting stage. The production company has to warrant to the agency that every synthetic element will be disclosed, and the agency has to warrant to the broadcaster that the disclosure will be passed through. A standard two clause rider on the existing agreement is enough, and we have a template we can share with clients on request.
The third change is on set. The script supervisor's notes have to record every take that used a synthetic reference, even if the reference was only a stand in for the actor. The fourth change is in post. The post production supervisor has to maintain a running list of synthetic elements and the tools used, and that list is the input to Annex A. None of these steps is heavy, but they have to be in place before the first day of the shoot, not after the offline is locked.
Voice clones and the dubbing question
The Council's January note addressed voice directly. A voice that was cloned from a real performer and used in a commercial is synthetic media, and the credit has to name the original performer if the performer consented to the clone. A voice that was generated from a library of consented voices and not tied to a named performer is also synthetic media, and the credit has to say so but does not have to name anyone.
The dubbing question is the one that comes up most often with our regional clients. If a Bollywood star records Arabic dialogue in a Mumbai studio, that is not synthetic. If the Arabic dialogue is generated by a voice clone trained on the star's English interview footage, that is synthetic, the credit has to appear, and the consent of the star is the agency's responsibility, not the production company's. The Council is clear that the disclosure is about the viewer's right to know, not about the rights between the parties, but in practice the agency will ask the production company to warrant that the disclosure has been made.
Background faces and the small print
The Council's example list in the January note includes background faces, and the threshold is that a synthetic background face is in scope if it is identifiable as a person, even if it is out of focus in the background. A synthetic crowd that has been generated as a texture and not as identifiable individuals is not in scope, and neither is a synthetic sky or a synthetic set extension that does not contain a face.
The practical line for a brand film shot on a Dubai street is that a synthetic face in a window reflection is in scope if the reflection is recognisable as a person, and the credit has to read synthetic media even if the only synthetic element is a single reflection. The safe answer for a busy scene is to disclose.
Contracts and the rider we use
The rider we add to agency production agreements runs to two clauses. The first is a warranty from the production company that it will identify every synthetic element in the delivery notes and in the on screen credit, and that it will file Annex A before final payment. The second is an indemnity from the agency to the production company for any synthetic element that the agency instructed the production company to use and that the production company disclosed in writing at the time of the instruction. The indemnity is the important part, because the production company is the party that signs Annex A and the agency is the party that often chooses the tool.
For broadcaster agreements the language is shorter, because the broadcaster is the party that files the EPG entry and the Council's compliance letter is addressed to the broadcaster. The standard clause in the major broadcaster agreements now requires the production company to deliver a synthetic media declaration as part of the delivery, and the broadcaster passes that declaration to the Council on the production company's behalf.
What the regulator has said in writing
Three documents anchor the rule. The first is Federal Decree Law No 15 of 2025 itself, which is published in the official gazette and on the u.ae portal. The second is the Council's press release of 14 January 2026 on the media office website, which is the document that defined synthetic media and named Annex A. The third is the Council's note of 2 October 2026, also on the u.ae portal, which is the document that moved enforcement from the complaint stage to the submission stage.
The Council has also published a set of answers to frequently asked questions on its licensing portal, and the answers confirm that the rule applies to advertisers and to production companies that deliver to advertisers, and that the rule does not apply to internal corporate communications. The Council has not yet published enforcement statistics, and we will update this page when the first quarterly numbers are released.
What we still do not know
Three questions are open. The first is whether the on screen credit has to name the tool used. The Council's January note said the credit had to contain the phrase synthetic media and the production company name, and the Annex A form asks for the tool. The Council has not yet said whether the tool has to appear on screen, and our reading of the rule is that it does not, but we have asked for written confirmation and we will update this page when we have it.
The second question is whether a synthetic element that is later removed from the final cut still needs to be disclosed. The Council's January note is silent on the point, and the safe answer is to disclose any element that was generated at any point in the post production process and to note in the free text field that the element was removed. The third question is whether the rule applies to a programme that was licensed before 1 October 2026 and that delivers after that date. The Council's 2 October note said the rule applies to submissions made after 1 October 2026, regardless of when the programme was shot, which is the position we are working to.
How Carving Dreams is handling this for clients
For brand films we are adding the synthetic media field to the delivery template at the start of the job, and we are asking the agency to confirm at the bid stage whether any element will be generated. For documentary series we are building the Annex A form into the post production schedule and we are asking the broadcaster's delivery coordinator to confirm the wording of the on screen credit before the offline is locked. For event films we are flagging the rule to the venue's AV team and to the client's legal team, because a stage backdrop that contains a synthetic face is in scope if the backdrop is recorded and delivered to a licensed platform.
None of this is heavy, and the cost of getting it right is a single line in a delivery note and a one page form. The cost of getting it wrong is a resubmission, a slipped schedule, and a phone call from the broadcaster. We are happy to share the contract rider and the Annex A template with any client on request, and we are running a short clinic for producers on the first Tuesday of every month at our studio in Al Quoz.
Sources and what each one supplied
The u.ae portal note of 2 October 2026 supplied the shift from complaint stage to submission stage and the date the rule began to be enforced at the re registration stage. The media office press release of 14 January 2026 supplied the definition of synthetic media, the name of Annex A, and the two year retention rule. The Federal Decree Law No 15 of 2025 as published in the official gazette supplied Article 7 and the wording test for the on screen credit. The Media Council licensing portal FAQ supplied the scope of advertisers and the exclusion of internal corporate communications.
Where the sources disagree, the press release of January 2026 is the more recent document and supersedes the gazette text on the definition of synthetic media, because the gazette text used the term artificial media and the press release replaced it with synthetic media. The Council's licensing portal FAQ is the most permissive document on internal corporate communications, and we have flagged that to clients who run internal town halls that are recorded for later distribution on a licensed platform.
Questions
- Does the AI disclosure rule apply to a car commercial that airs only on YouTube?
- No, if the commercial has not been booked through a Media Council licensed service. The rule applies to free to air channels and to licensed streaming services inside the UAE, and to advertisers that book through those services. A campaign that runs on both YouTube and a licensed streaming service is in a grey zone, and the safe answer is to disclose.
- Does the on screen credit have to name the AI tool used?
- Annex A asks for the tool by version number, but the Council has not yet said whether the tool has to appear on screen. Our reading of the rule is that the on screen credit has to contain the phrase synthetic media and the production company name, and the tool can live in Annex A. We have asked the Council for written confirmation and we will update this page when we have it.
- Are news and current affairs programmes exempt?
- Yes, on free expression grounds. A documentary strand is treated as current affairs only if every episode is anchored by an on camera journalist. A branded documentary series that does not have a journalist anchor in every episode is back in scope and needs the disclosure.
- What happens if the disclosure is missing on a delivery?
- The Council is rejecting re registration applications that arrive without the required disclosure, and the broadcaster is asking the production company to resubmit a corrected master and a corrected EPG entry. The cost of a resubmission is small in cash but large in goodwill, because the broadcaster's scheduling team has to be told the series will slip and the platform's marketing team has to pull social clips.
- Does a synthetic background face that is out of focus need to be disclosed?
- Yes, if it is identifiable as a person. The Council's January note used background faces as an example of a synthetic element that is in scope, and the threshold is identifiability rather than focus. A synthetic crowd generated as a texture is not in scope, and neither is a synthetic sky or a synthetic set extension that does not contain a face.
- Who signs Annex A?
- The producer and the post production supervisor, with the date. The Council keeps a copy for two years and the production house keeps a copy for two years. A signed PDF is the safe choice and a scan of a wet signature is better than a typed name.
- Does the rule apply to a programme that was licensed before 1 October 2026?
- The Council's 2 October 2026 note said the rule applies to submissions made after 1 October 2026, regardless of when the programme was shot or licensed. We are working to that position and we have flagged it to clients who have series in delivery.
Sources
Planning something in the UAE?