UK's evolving Privacy and Consumer Protection Landscape in 2025 and how it compares to the UAE’s Federal Data

Protection Framework (a brief guide)

As businesses face a rapidly evolving data and digital compliance environment, staying ahead of local and cross-border privacy obligations is critical. The UK and the UAE have both introduced significant reforms to enhance personal data protection and consumer trust, but their approaches and enforcement powers differ in important ways (UK 2025 privacy and consumer enforcement updates and UAE framework under the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL).

The UK: Regulatory Expansion and Direct Enforcement in 2025

1. Increased Enforcement Powers
The Competition and Markets Authority (CMA) now holds direct enforcement powers under the upcoming Digital Markets, Competition and Consumers Bill, expected to pass by May 2025. It can impose fines of up to 10% of a business’s global turnover or £300,000 without going through court, which is a significant risk shift for businesses.

2. Strategic Market Oversight
The Digital Markets Unit (DMU) is empowered to regulate companies with Strategic Market Status (SMS).

3. Fake Review Ban
Hosting or soliciting fake reviews is now illegal. 

4. Subscription Reform
Requirements now include:

• Clear cancellation tools;

• Pre-renewal alerts;

• A mandatory 14-day cooling-off period.

Privacy and Data Protection Obligations

1. Cookie Compliance
Under PECR (Privacy and Electronic Communications Regulations):

• Prior consent is required for non-essential cookies;

• Users must be able to reject as easily as accept;

• Withdrawal of consent must be just as simple.

2. Privacy Policy Essentials
Organisations must publish a privacy policy covering data types, legal bases, retention, and rights.

3. Data Processing Agreements (DPAs)
Any sharing of personal data with third-party vendors (e.g. IT, CRM) requires a DPA with strict contractual controls under the UK GDPR.

4. International Transfers
Cross-border data transfers outside the UK require a Transfer Risk Assessment (TRA).

5. Children’s Data

More stringent requirements apply when relying on legitimate interests to process data of minors. Transparency and clear explanations are essential.

The UAE: Federal PDPL and Executive Regulations

Following the PDPL, the UAE continues to implement GDPR-like privacy rules, with an emphasis on contractual safeguards and local accountability.

Key Differences from the UK

1. No PECR Equivalent
The UAE PDPL does not impose cookie consent obligations in the same form. Cookies fall under general personal data rules meaning businesses can set usage terms in privacy policies unless sensitive or identifying data is involved.

2. Lawful Basis Still Evolving
The UAE recognises similar lawful bases as GDPR (e.g. contract, consent, legitimate interest), but implementation guidance continues to be refined through Data Office circulars.

3. Consent Requirements
Where consent is required (e.g., marketing), it must be freely given, specific, and informed similar to UK requirements.

4. Data Sharing and DPAs
Sharing data with a vendor even within a group company requires a Data Processing Agreement outlining the purpose, confidentiality, and technical safeguards. This is mandatory under both the PDPL and UK GDPR.

5. Cross-Border Transfers
Data can only be transferred outside the UAE if:

a. The destination is deemed “adequate” by the UAE Data Office; or

b. Appropriate contractual mechanisms (e.g. Data Export Agreement) are in place.

Remote access from outside the UAE (e.g. IT support in India) is treated as a cross-border transfer and must be documented.

6. Regulatory Enforcement
The UAE's Data Office is still building its enforcement profile. Fines and sanctions are possible under the PDPL, but unlike the UK, administrative enforcement mechanisms remain less aggressive for now.

Shared Employer Obligations (UK vs UAE)

Employee Data Processing

Conclusion

While the UK is moving toward more aggressive regulatory enforcement and consumer protection, the UAE is embedding international best practices with a focus on contractual governance and data localisation.

UK based firms with UAE operations (or vice versa) must adopt a hybrid compliance model, incorporating both local statutory requirements and international transfer frameworks. This includes maintaining robust privacy documentation, executing DPAs with local vendors, and preparing for regulatory inquiries from either regime for strategic business priority.