Music Licensing for Brand Video in Dubai

The four are easy to name and easy to confuse. There is the right to play recorded music in a commercial space, which is what the December regime prices. There is the right to combine a recording with moving image, which is what a brand film needs. There is the platform layer, which governs what a business account may post regardless of what you have licensed off-platform. And there is the future right, the one nobody thinks about at handover, which decides whether the client can legally re-cut the film in two years.

The December date is why this is on your desk now. Gulf News and The National both report annual fees taking effect on 1 December 2026 under Ministerial Resolution No. 136 of 2026, issued by the Ministry of Economy and Tourism, with collections administered by two licensed organisations. That is a genuine change and it is worth taking seriously.

Here is the sentence to carry into the next meeting. Every description of those organisations' remit that this research could find, official and legal alike, covers public performance, broadcasting and streaming. None of it says the licence reaches synchronisation, which is the industry term for music married to picture. That gap is the subject of most of this article.

The parallel question, who owns the film itself and the material shot to make it, is covered separately in the Journal's article on usage rights and raw-file ownership.

The reason music is harder than any other element in a film sits in the primary text of Federal Decree-Law No. 38 of 2021 on Copyrights and Neighbouring Rights, and it is worth reading rather than summarising.

Article 7 reserves to the author and the rights holder alone the power to authorise use of a work, naming reproduction including electronic storage, broadcasting, rebroadcasting, public performance, public communication, translation, assimilation, modification, rental, lending, and making the work available through computers or communication networks. Cutting a recording under picture and posting the result engages three of those at once. The track is copied, it is modified in the sense of being edited and mixed, and it is made available.

Then the law grants a second and third layer of rights over the same piece of audio. Article 17 gives performers exclusive economic rights including fixing their performance on sound or audiovisual recordings, reproducing it, and communicating it to the public. Article 18 gives producers of phonograms their own exclusive rights over the recording, covering reproduction, distribution, making it available, and communication to the public in any manner whatsoever. Article 16 adds perpetual moral rights for performers that cannot be assigned or prescribed, including the right to prohibit modification of their performance in a manner that would prejudice their reputation.

What that means in practice for a brand film is a single sentence worth memorising. A commercial track is at least two live permissions, the composition and the recording, held by different people. Clearing one is not clearing the track.

Two further articles dispose of the most common assumptions. Article 20 protects economic rights for the author's lifetime plus fifty years from the first day of the calendar year following their death, which is why an old song is rarely a free one. Article 22 sets out the exceptions, and the personal-use exception is drawn expressly for reproducing a single copy for purely personal use, for non-profit and non-professional purposes. A brand film fails all three tests in that phrase.

This is the correction the December news makes necessary, and it needs to be stated carefully, because the research supports a clear warning rather than a clear rule.

What the collective licence covers is consistently described. EMRA's own material says it administers both musical works and sound recording rights, representing songwriters, publishers, performers and record producers, and that it covers public performance and broadcasting rights and other optional rights. The law firm Gowling WLG describes the remit as royalties arising from public performances and broadcasts of music and from entities making commercial use of musical works. Streaming appears across the coverage. Synchronisation does not appear anywhere.

Being precise about that: no source reviewed for this article states that either licensed organisation administers synchronisation rights, and none states that it does not. The absence is not a ruling. It is a question that has not been answered publicly, and it is a question with a real financial consequence attached, which makes it worth asking directly rather than assuming in either direction.

The scenario this produces is easy to predict, because it will happen across Dubai in January. A hotel group buys its licence, ticks music off the compliance list, commissions a brand film, and the agency cuts the film to a record everyone in the room recognises. The licence answers the lobby and the restaurant. It says nothing about the film, which is a separate use, of a separate right, granted by a separate party.

Clearing a commercial record directly means negotiating with the publisher for the composition and the label for the recording, separately, with each free to say no or to price the answer at a number designed for a television campaign. For international repertoire, against a hospitality marketing budget, that negotiation usually ends the conversation. This is why almost no hotel film in this market is cut to a chart record, and why the handful that are usually should not have been.

One related question could not be resolved here and should be raised with the same email: whether a brand film containing properly licensed music, played on a screen inside a licensed venue, needs anything beyond the venue licence.

For almost every brand film, the working answer is a production music library, and the reason is structural. One party controls the rights to both the composition and the recording, so a single licence clears the track. That collapses the two-permission problem in Article 17 and Article 18 into one transaction.

It works, and it breaks in three predictable places.

The first is the lapse. Library licences are commonly tied to an active subscription rather than being perpetual. Epidemic Sound's help material describes content published during an active subscription as staying cleared, while tracks used in projects published after the subscription ends are not covered. Consider what that means across a normal client relationship. A film is delivered in year one under an agency's subscription. In year three the client re-cuts it for a new campaign, the agency has long since changed vendors, and the re-cut is unlicensed even though the original was fine.

The second is the tier. Licensing on behalf of a client is a distinct, higher tier of subscription rather than a default right. Epidemic Sound's own plan structure places sublicensing, so that a client can publish on their own channels, on the plans aimed at agencies and production companies rather than on individual plans. A production company delivering a client film under a personal-tier subscription is delivering an unlicensed film, and the client will be the one holding it.

The third is scope. The tier required is decided by questions that belong in the brief rather than in post: how many channels the film will run on, whether paid media is involved, whether broadcast or out-of-home is in the plan, whether the film plays at events, and how long the client intends to run it. Territory is usually worldwide in library licences, so the term is the variable that catches people, and the term is exactly what Article 9 requires the licence to state.

Vendor terms are vendor terms rather than law, they differ between libraries, and they change. Read them at the point of purchase rather than relying on what was true when someone on the team last checked.

Music is a pre-production decision. The scope of use determines the licence tier, the licence tier determines the available pool, and the pool determines what the editor is allowed to cut to. Reversing that order is how a film ends up locked to a track it cannot legally keep.

So the questions get answered in the brief. Which platforms. Organic, paid, or both. For how long. Which territories. Whether the film plays on screens inside the venue. Whether any of it goes to broadcast or out-of-home. Whether it will be shown at events or trade shows. And whether the client intends to re-cut it internally, which is the question that decides everything about year two.

There is a practical reason to settle it early that has nothing to do with law. A client who approves an edit cut to an uncleared reference track will hear every legitimate replacement as a downgrade, because they have already learned the film in that key. So the reference comes from the licensed pool from the first cut, and the edit is built on music the film is allowed to keep.

The December regime changes none of this. What it changes is the conversation, because the client has now been told by their own government that music is not free, and a production company no longer has to make that argument from scratch.

We treat music as a scope question asked at the brief rather than a taste question answered in post. The permitted pool is agreed before the first cut, the reference is licensed from the start so nobody falls in love with a track we cannot keep, and the film is handed over with its licence documentation attached rather than with a verbal assurance.

Luis Grolez, the founder, pitches this personally, founder to founder. Get in touch about a specific brief and a specific quarter.