Health regulator inspection checklist and compliance calendar for Dubai clinics

Dubai's health regulator inspects outpatient facilities against the Standards for Outpatient Facilities (code ST-45, version 1), issued on 19 November 2024 and effective from 19 January 2025. The standard applies to polyclinics, specialty clinics, general clinics (including hotel and company clinics), express clinics and general dental clinics.

The regulator turns the standard into two published inspection checklists: a Final Checklist (issue 3, February 2025) and a Random Checklist (issue 2, February 2025). Both follow the ten standards in the document: (1) registration and licensure, (2) health facility requirements, (3) healthcare professionals, (4) laboratory and diagnostic services, (5) medication management, (6) emergency medication and equipment, (7) infection control, (8) health information asset management, (9) patient consent and (10) patient care. Each item is marked Yes or No, with space for the inspector's remarks.

The regulator's Health Facility Audit and Inspection policy says inspectors work from these checklists and fill in a checklist report during the visit. Each result is fulfilling, follow up, or not fulfilling; a not-fulfilling result leads to a violation. Approved violations appear in the facility's Sheryan account, and inspection field reports are issued through Sheryan within five working days.

The same policy asks facilities to run a self-inspection every three months, using the checklists the regulator publishes for each facility type, and to keep the completed checklists available for inspectors during a visit.

The regulator's audit and inspection policy lists four inspection types: routine inspections; management order inspections, which regulator management requests and which are also used for follow-up visits; file collection, which collects a copy of a patient file, for example for a complaint; and final inspections for new and existing facilities.

The final inspection happens before a new clinic can operate. The New Facility License service issues an inactive licence, and the facility then applies to activate it. Before applying, it must add and activate the licences of its professionals and select a medical director. The inspection team then contacts the facility to agree a date and time. The inspection fee is AED 2,000 for a general clinic, specialty clinic, polyclinic, general dental clinic or school clinic, AED 3,000 for a day surgery or fertility centre, and AED 4,000 for a hospital. If the facility fails, it must book a new inspection and pay again; the listed re-inspection fee for these clinic types is AED 1,000.

The facility licensing manual lists what must be ready for the activation inspection: the approved engineering layout, enough professionals to deliver the service, a medical director, a list of medical equipment, the civil defence certificate, approved policies and procedures, the third-party insurance contract, the waste management contract, the trade licence, and the approval email confirming tested connectivity with NABIDH. Changing the plan or design of a facility without prior approval is a listed violation with an AED 10,000 fine.

Routine inspections take place once the licence is active. The regulator does not publish a fixed timetable. Its policy says their frequency depends on the facility's risk rating (very low, low, medium or high), which takes into account violations in the past year, compliance in the last three visits, suspensions or revocations in the past year, renewal compliance, and whether the facility handles controlled drugs. Final inspections can be done on site or remotely through RASED, a live video call between an inspector and the facility's medical director.

Amendments to an active licence, such as adding a specialty, changing category, expanding the location or changing the layout, need initial approval, final approval and an inspection. The final inspection fee for an amendment is AED 2,000 for the clinic types above. Updating accreditation or a FANR licence does not need an inspection.

Staff licences. Every healthcare professional must hold an active licence from Dubai's health regulator and work within their scope of practice, and the facility must appoint a medical director. Under Executive Council Resolution No. 49 of 2024, a facility that engages a professional with an expired licence can be fined AED 10,000, and a professional who keeps practising after the licence expires can be fined AED 5,000. The standard also requires valid Basic Life Support certification for all healthcare professionals and documented CPD activity.

NABIDH and records. The Random Checklist asks for a NABIDH contract and a plan to integrate the electronic medical record with NABIDH. Before activation, the facility must show an EMR that meets the NABIDH Minimum Data Set and connectivity standards. Health records must be kept for at least 25 years from the patient's last encounter, as Federal Law No. 2 of 2019 on ICT in health fields requires. That law also does not allow health data about services provided in the UAE to be stored or processed outside the country unless a resolution permits it. The standard required paper records to be digitised within one year of its release.

Infection control and sterilisation. The sterilisation room must be physically separated from other areas, have restricted access, and contain high-vacuum steam sterilisers plus equipment for heat-sensitive items. The checklists look for internal chemical indicators in every package, complete package labels, sterilizer quality checks such as the Bowie-Dick test, and a sterilisation logbook recording date, time, cycle number, instruments and operator. Dental instrument processing needs a dedicated space of at least 2 square metres, divided into decontamination, preparation and sterile storage areas, with a one-way workflow. Every examination, treatment and procedure room needs a hands-free hand-washing station and wall-mounted soap and tissue dispensers, with non-refillable hand sanitiser as well. Staff must use PPE.

Medical waste. The facility needs a contract with a specialised company that collects, transports and destroys medical waste under the conditions of Dubai Municipality's Public Health Department. Bins are colour coded (yellow for medical waste, black for general waste), foot-operated medical waste bins are required in all treatment, procedure and examination rooms, and sharps boxes are discarded when three-quarters full or expired. Not meeting the approved methods for managing medical waste carries an AED 5,000 fine.

Fire safety. The standard requires a fire safety plan covering detection, containment, extinguishing, rescue, evacuation and alerting Dubai Civil Defence; fire training for staff; posted evacuation maps marked "You are here"; and staff who know where extinguishers, alarms and assembly points are. A copy of the civil defence certificate is checked at the activation inspection.

Equipment and premises. The facility needs an equipment management plan with preventive maintenance to the manufacturer's recommendations, a maintenance schedule, records of failures and repairs, and electrical safety checks. Extension cords are not allowed. Drinking water must be tested quarterly and non-potable water every six months. The patients' rights charter must be posted at the entrance in Arabic and English.

The regulator's audit and inspection policy, written under the earlier Executive Council Resolution No. 32 of 2012, sorts violations into two types: ethical and technical violations, which the Medical Practices Committee handles, and administrative violations imposed on the facility or professional. Executive Council Resolution No. 49 of 2024, issued on 28 August 2024, now regulates health professions and health activities in Dubai, with two schedules of violations.

Schedule 4 lists prohibited acts. For these, the Medical Practices Committee can issue a written warning, close the facility fully or partly for up to six months, cancel specific activities, revoke the facility licence, or impose a fine of AED 5,000 to AED 200,000 on a facility (AED 2,000 to AED 100,000 on a professional).

Schedule 5 lists violations with fixed fines. Examples for facilities: AED 1,000 for not displaying the facility licence or the patients' rights chart; AED 5,000 for not following the consent rules or not providing consent forms; AED 5,000 for not producing the licence or documents when inspectors ask; AED 5,000 for not meeting medical waste requirements; AED 10,000 for engaging a professional with an expired licence; AED 20,000 for operating after the facility licence has expired; and AED 50,000 for not following the measures that prevent the spread of communicable diseases. If the same Schedule 5 violation is repeated within one year, the fine doubles, up to AED 400,000 for a facility, and the Medical Practices Committee takes the case.

While a violation is investigated, the facility can be closed fully or partly as a precaution for up to three months, and this can be extended once for the same period. Violations that are criminal offences are referred to the judicial bodies.

A facility can appeal certain violations through the Appeal Violations service on Sheryan within 30 days of the issue date. The appeal is free, needs supporting documents, and takes about 30 working days. Each violation can be appealed only once, and the outcome is final.

A clinic's compliance year turns on two sets of dates: the facility licence expiry and the licence expiry of each professional.

Facility licence. Under Resolution No. 49 of 2024 a licence is valid for one year, and Sheryan offers renewal for one, two or three years. Renewal opens 90 days before expiry. The facility must upload a renewed trade licence, make sure all professional licences are active, and pay any outstanding fines before renewal goes through. The renewal fee for an active licence is AED 5,000 for one year for a general clinic or general dental clinic (AED 8,750 for two years, AED 12,500 for three), AED 6,000 for a specialty clinic and AED 15,000 for a polyclinic, plus Knowledge and Innovation fees. The late renewal penalty per month is AED 1,000 for a general or general dental clinic, AED 1,200 for a specialty clinic and AED 3,000 for a polyclinic (AED 500 to AED 8,000 across all facility types). A licence not renewed within three months of expiry can be revoked unless the holder gives a valid reason, in which case a further three months is allowed. A licence expired for more than six months cannot be renewed through the service and is treated as cancelled.

Professional licences. Renewal opens 90 days before expiry, for one, two or three years. The professional needs valid malpractice insurance, the minimum annual CME/CPD, and no unpaid fines. Late renewal of a full-time licence costs AED 600 per month for physicians and dentists and AED 200 per month for nurses, midwives, allied health and TCAM professionals. A full-time licence expired for more than six months cannot be renewed.

Example: a clinic whose facility licence expires on 30 June. The renewal window opens around 1 April. Before then, check every professional's expiry date and CPD status, renew the trade licence, and pay any open fines on Sheryan. Submit early in the window: renewal is usually processed in one working day, but an inactive professional licence or an unpaid fine will hold it up. Through the year, track the medical waste contract, the civil defence certificate, equipment maintenance dates and NABIDH connectivity.

The regulator's inspection policy asks for a self-inspection every three months. Spread across the year, for example in January, April, July and October, these give four checks for gaps before renewal.

Routine inspections are not on a published timetable, so readiness has to be continuous.

Displays. The facility licence must be displayed where patients can see it, each professional must display their licence while practising, and the patients' rights charter must be posted at the entrance in Arabic and English. Each of these is a Schedule 5 violation with an AED 1,000 fine.

Documents on hand. Keep the sterilisation logbook, waste contract, equipment maintenance records, civil defence certificate, policies and procedures, and the staff list with licence numbers where the manager and a deputy can find them. Not producing a licence or document when an inspector asks carries an AED 5,000 fine. The policy makes the medical director, manager or most responsible person accountable for assisting the inspection team and signing the e-inspection report.

Licence tracking. Flag each professional's licence expiry 90 days ahead, when renewal opens on Sheryan. Nobody should work on an expired licence, and new staff should not start before their licence is issued: engaging a person who meets the requirements but whose licence is not yet issued carries an AED 20,000 fine.

Policies. The standard lists the policies an outpatient facility must have, including patient assessment and referral, informed consent, health records, infection control and hazardous waste, incident reporting, privacy, medication management, emergency action, fall risk, sentinel events, pain assessment, complaints, scope of service, clinical audit, staffing and privileging, waiting times, fire safety, immunisation where applicable, and sick leave.

Consent. Written consent is needed for surgical or invasive procedures, anaesthesia and other listed treatments. The form should be in Arabic and English, or another language the community needs, and include the patient's full name as on the passport or Emirates ID, age, gender and identification number, the procedure, and the name and signature of any witness or interpreter.

Cooperation. Staff must cooperate fully with inspectors. Inspectors can collect photos and videos and seize items where they find non-compliance, and obstructing them or giving false information can lead to legal action.

Inspection field reports reach the facility through Sheryan within five working days. Each result is fulfilling, follow up or not fulfilling, and a not-fulfilling result leads to a violation.

Resolution No. 49 of 2024 requires a violator to fix a violation within the time the regulator sets. If it is not fixed in time, it counts as a new violation: a Schedule 5 fine doubles, the Medical Practices Committee must impose a penalty for a Schedule 4 prohibited act, and the facility can be closed temporarily until the problem is fixed.

For safety-critical findings, such as an unlicensed person treating patients, stop the activity at once and record what was done and when. For documentation findings, collect the evidence the regulator asks for, such as photographs, updated contracts, maintenance records or signed policies, and submit it before the deadline.

To contest a violation, use the Appeal Violations service on Sheryan: open the violation from the Violations widget on the dashboard, select Appeal, and attach supporting documents. The window is 30 days from the issue date, there is no fee, processing takes about 30 working days, and each violation can be appealed only once. Separately, Resolution No. 49 of 2024 lets an affected party file a written grievance with the Director General within 30 days of being notified of a decision; the Medical Grievances Committee decides it within 30 days, and its decision is final.

Fines are paid through the Payment of Fines service, and the regulator can approve payment in instalments. Violations in the past year also count towards the facility's risk rating, which sets how often routine inspections happen.