Procedure Explainer Videos for Dubai Clinics
Most clinics in Dubai believe that explaining a treatment publicly is somewhere between risky and forbidden, usually on the authority of someone repeating a half-remembered rule. The Dubai Health Authority takes the opposite position and says so in a specific clause. Educational content is expressly permitted.
This guide is for the clinic marketing lead and the founder-clinician who want to explain their work without a compliance problem. It covers the clause that permits it, the three things that actually move an explainer across the line, why the risk statement is a design element rather than an end card, the point at which the video stops being a DHA question and becomes a product-advertising one under a different regulator, and the order the approvals run in.
The one line to hold onto
The fence is not where clinics think it is. Detail is not what moves an explainer across it. Naming a prescription product, omitting the risk statement, and manufacturing a need instead of answering a question are.
A procedure explainer for a Dubai clinic is allowed, and the rule says so
Watch out
This article explains how the DHA standards and the product-advertising regime apply to an educational clinic video, for a clinic planning one. It is not legal advice. Requirements change, so confirm them with the DHA, the Emirates Drug Establishment or qualified counsel before publishing.
Clause 6.9 of the DHA Standards for Medical Advertisement Content on Social Media states that health facilities and healthcare professionals may promote public health information as part of a public health campaign or public health activities, and may raise public awareness of particular products and services through public health. Appendix 1 of the same standard repeats it in advertising terms, listing a statement providing public health information encouraging preventative or corrective care among acceptable content, with the qualifier that it should be evidence-based wherever possible.
One honest qualifier belongs here, because it makes everything else in this article make sense. An explainer is still a social media advertisement in the regulator's vocabulary. The standard defines that as any information about a health product, service, facility, professional, treatment or therapy published through social media, which catches an educational video as surely as a promotional one. So the piece is educational in content and advertising in category, and it is governed accordingly.
That combination is better news than it sounds. It means a clinic is not looking for a category that escapes the rules. It is working inside a set of rules that already contemplate exactly what it wants to publish.
The three things that move an explainer across the line
Naming a prescription product
Article 39 of Federal Law No. 8 of 2019 prohibits the advertisement of prescription-only drugs, with the only exception being promotion in scientific resources or magazines intended for healthcare practitioners, and then only with ministry approval, as the CMS expert guide on advertising medicines and medical devices in the UAE sets out.
In aesthetics that lands directly on the injectables an explainer is most often about. The practical consequence is a useful one to hold in a script meeting: the treatment can be explained, the mechanism can be explained, the candidacy and the aftercare can be explained. The product's brand name is a different thing, promoted to the public, and it is the part that is prohibited.
Omitting the risk statement
Appendix 1 lists as acceptable, for any surgical or invasive procedure, the appropriate warning statement in a clearly visible position. It then lists three things as not acceptable: failure to disclose health risks associated with a treatment, omission of the necessary warning statement for surgical or invasive procedures, and invasive or non-invasive procedures presented without a clear statement on the associated risks.
Clause 6.6 reinforces it from the other direction. All advertising must be substantiated, especially where it relates to treatment outcomes whether implied or explicitly stated, and should always include the associated risks. So an outcome claim that arrives without its risks fails the clause, however thorough the rest of the piece is.
Manufacturing a need
Clause 8.1.14 bars inducing fear or concern in patients about their own health in order to increase demand, and creating an unnecessary need for a product, procedure or service. Appendix 1 adds content that encourages inappropriate, indiscriminate, unnecessary or excessive use of health services, including references to improving physical appearance framed so as to create unrealistic expectations.
This is the one that catches good marketing rather than bad. An explainer that opens by naming a flaw the viewer had not been worrying about is doing what the clause describes, however elegantly it is shot.
There is a fourth item, and it is a matter of degree rather than a line. Clause 10.7.3 of the DHA Standards for Code of Ethics and Professional Conduct for Health Professionals, in force since 3 September 2025, requires clinicians to refrain from providing individualised clinical advice to the public through social media channels. Explaining what a treatment does is education. Telling a named viewer what they should have done to their own face is a consultation held in public.
1 · A named prescription product
Explain the treatment, the mechanism, the candidacy and the aftercare. The brand name of a prescription-only product is the part that cannot be promoted to the public.
2 · A missing risk statement
Appendix 1 treats omission of the warning statement, and any procedure shown without a clear statement of associated risks, as not acceptable.
3 · A manufactured need
Clause 8.1.14 bars inducing fear about the viewer's own health to increase demand, or creating an unnecessary need for a procedure.
When the explainer stops being a DHA question
Watch out
Two questions in this area are genuinely open and should not be answered by guessing. Whether naming a product category, such as botulinum toxin, rather than a brand triggers the product regime. And whether a clinic, as opposed to the marketing-authorisation holder, is the correct applicant for an EDE advertisement licence, since the EDE service describes its audience as medical stores, pharmaceutical manufacturing facilities and marketing offices. Put both to the EDE for your own case. The conservative practical answer, and the one most clinics should take, is to keep product names out of a clinic-published explainer entirely.
Advertising a medical product is a separate licence with a separate regulator, and this is the part of the landscape that most clinic marketing guidance has not caught up with.
The Emirates Drug Establishment operates a service for licensing an advertisement for a medical product, covering printed, audio, video, social media and website advertising, with the licence displayed on the approved materials. Its requirements read like a content brief: a valid marketing authorisation for the product, advertising materials that are accurate, non-misleading and substantiated by evidence, clear disclosure of any associated risks or side effects, compliance with the rules for the intended audience whether healthcare professionals or the general public, and submission of the product registration certificate together with the advertisement designs.
The numbers are modest and specific. An application fee of AED 100, additional fees varying by facility category and advertisement type, three working days processing, e-payment, and an expiry date that must be referenced on the designs alongside the approval date.
The regulator moved recently, which is why this is unfamiliar. The health ministry's own service transfer notice confirms the move, and regulatory advisories including MedDeviceGuide and RegDesk report the Emirates Drug Establishment handling medical device marketing authorisations from 29 December 2025 under Federal Decree-Law No. 38 of 2024. The date and the decree number come from those advisories rather than from primary text.
So the distinction a producer needs is this. An explainer about what a treatment does, who it suits and what the risks are sits under the DHA content standard. An explainer built around a named product, its brand and its claims moves towards the product-advertising regime, which is a different licence, a different regulator and possibly a different applicant.
The regulator map
Four bodies, four different jobs
| Who | What they govern |
|---|---|
| Dubai Health Authority | The content standard for clinic advertising, medical director accountability, and audit against Appendices 1 and 2. |
| Ministry of Health and Prevention | The health advertisement licence whose number is displayed on the clinic's account. |
| Emirates Drug Establishment | The medical product advertisement licence, covering video and social channels. AED 100 application fee, three working days. |
| Dubai Healthcare City Regulatory | The parallel route for DHCC clinics. At least fourteen working days before the advertising date, approval valid six months. |
A procedure explainer is a DHA question. A product explainer starts to be an EDE one.
The risk statement is a design element, not an end card
The DHA does not prescribe the wording. Appendix 1 requires the appropriate warning statement in a clearly visible position for any surgical or invasive procedure, which leaves the drafting to the clinic's medical director and the placement to the production.
Clause 7.1.5 is the one that decides whether the placement works. Fine print statements have to be placed in a prominent location, legible to the unaided eye or target view. Small grey type over a moving background does not satisfy that, and neither does a two-second card at the end of a ninety-second film.
Where the piece touches results, clause 6.6 requires substantiation together with the associated risks, and any before-and-after material carries the fixed results-vary statement in the same font size as the rest of the advertisement under clause 9.6. The Emirates Drug Establishment requirement runs the same way, that advertising materials clearly disclose any associated risks or side effects. Two regimes, one instruction.
Good to know
Treat the risk line as a timed element with a duration, not as a design afterthought. It has to be readable at the size the platform actually plays at, which on a vertical social cut means a real constraint on the edit rather than a note for the designer. Decide the wording with the medical director before the shoot, so the edit is built with the space already in it.
Who presents it, and in what register
Only a DHA healthcare professional may advertise medical content and procedure details or benefits, under clause 7.1.12, which settles who fronts an explainer. That presenter must be competent through education, training and experience to provide the service advertised under clause 6.5, and must state name, title, professional qualification and speciality as per their DHA licence under clause 8.1.3.
The register is where explainers are won or lost. Clause 8.1.5 requires information supported by current international best practice, peer-reviewed literature and recognised bodies of scientific and clinical knowledge. Clause 8.1.6 then requires the content to clearly indicate whether what is being said is based on scientific studies, expert consensus, professional experience or personal opinion.
That second clause is the most useful line in the standard for a scriptwriter, because attribution is protective. In my experience, patients in their forties tend to ask about this first is a compliant sentence. The evidence shows this lasts eighteen months is a claim that has to be substantiated and carry its risks. The standard is not asking a clinician to sound hedged. It is asking them to say which kind of statement they are making, which is what a good clinician does in a consultation anyway.
Clause 6.11 bans the familiar list of absolute expressions, and the one an explainer reaches for is has no side effects, which is exactly the reassurance a nervous viewer wants and exactly the phrase the clause names. The ethics standard adds two more at clauses 10.5.3 and 10.4.5: public communications must be truthful, evidence-based and verifiable and must disclose known risks or limitations, and a clinician must not favour or recommend specific medications, devices or services from particular manufacturers without clear, evidence-based clinical justification.
The room, the equipment and the clinician are available. A patient in treatment is not.
Filming the procedure, and what to shoot instead
Clause 9.7 prohibits video filming or live streaming for advertising while a patient is undergoing minor or major surgery, is under general anaesthesia, or is in a procedure room, in any DHA-licensed facility, and Appendix 2 repeats it as an outright prohibition. Live procedure footage of a patient cannot be the spine of an explainer, which is worth knowing before a schedule is built around access to a treatment room. Clause 5.5 adds that the facility is liable for all content filmed within its premises, however it was captured.
Written consent must be obtained and documented from any individual whose pictures, images, videos or statements are used, limited under clause 6.10.1 to the subject it was requested for and the period it was granted for.
What an explainer is actually built from, then: the clinician to camera, the room and the equipment without a patient in treatment, a demonstration on a model or a mannequin, and consented material wherever a real patient appears at all.
The fourth option is the one most clinics underuse. Animation removes both the consent question and the procedure-room prohibition for a mechanism-of-action sequence, while remaining subject to the same substantiation and risk-disclosure rules. It also explains a mechanism better than a camera can, because it can show a plane of tissue that no lens has access to. A compliance-safe choice that is also the better creative one does not come up often.
The order the approvals run in
Good to know
On penalties, two sentences are enough. The DHA content standard sets no monetary tariff and enforces through medical director accountability, audit and licence action, with clause 10.1.12 of the ethics standard describing escalating discipline as increased fines, suspension of practice privileges or referral for potential revocation of licensure. The federal figures reported by law firms for the medical-products regime run from written notices and warnings through fines of AED 1,000 to AED 1,000,000, with criminal penalties of six months to five years imprisonment and fines of AED 50,000 to AED 500,000 depending on the offence, per Chambers and Partners and the UAE firm Awatif Mohammad Shoqi Advocates. The realistic exposure for a clinic explainer is a takedown, a warning and an audit finding against the medical director rather than a headline fine.
The medical director approves the content before publication where the piece names or locates the facility, under clause 5.3, and is accountable for content and style on any account promoting the facility under clause 7.3. The account displays the health advertisement licence number issued by the health ministry under clause 5.2. A clinic inside Dubai Healthcare City clears through the Dubai Healthcare City Regulatory authority at least fourteen working days before the advertising date, with approval valid six months provided the content does not change.
If the explainer names a product, the EDE advertisement licence enters the sequence with its own three-working-day turnaround and its own expiry date shown on the approved design.
Then the housekeeping that clinics forget. Under clause 7.1.13, advertisements and posts have to be archived with their edits and formats for verification and audit, and the Health Regulation Sector audits against Appendices 1 and 2 from time to time. The version that was approved is the version that has to be retrievable.
Emirates Drug Establishment · medical product advertisement licence
If the explainer names a product
Requirements include a valid marketing authorisation, evidence-substantiated materials and clear disclosure of associated risks or side effects.
One planned day. The presenter, the room and the lighting are already set, and the series comes off the same setup.
How the explainer gets built
Start from the question a patient actually asks. Clause 6.9 protects public health information, and a sales script with a diagram in it is not that, however good the diagram is. The questions are usually the same four: what does it do, will it hurt, how long does it last, and who is it not for. The last of those is the one that makes an explainer trustworthy and the one most clinics leave out.
Attribute the register under clause 8.1.6, so the script says which kind of statement each claim is. Attach the risks to every outcome statement under clause 6.6, and design the warning statement as a legible, timed on-screen element under Appendix 1 and clause 7.1.5. Keep product names out unless the piece is deliberately being built as a product advertisement, in which case the EDE licence and the marketing-authorisation position get settled first. Put a licensed clinician on camera under clause 7.1.12, captioned from the licence record under clause 8.1.3 and inside their scope of practice under clause 11.1.2 of the ethics standard. End on a consultation rather than an offer. Route to the medical director before publication under clause 5.3, archive the approved version under clause 7.1.13, and brief whoever moderates the account that a clinical question in the comments gets an invitation to consult rather than an answer.
Who you hire is part of this. Grolez Films builds explainers inside clause 6.9: the question first, the evidence attributed, the risk statement designed and timed to be read on a phone, product names kept out, a licensed clinician captioned from the licence record, and a cut the medical director can approve and archive. The alternative is the explainer that opens by making a viewer anxious about their own face, promises no side effects, and names an injectable brand.
On cost, indicative ranges only, in three tiers. A solo videographer sits around AED 3,500, the fast-turn end of the market and work Grolez Films does not take. A DOP and small crew runs roughly AED 25,000 to 45,000. A full production starts from AED 100,000. The more useful commercial point for this format is that an explainer series comes off one shoot day rather than one day per film, because the presenter, the room and the lighting are already set.
Watch out
Keep the figures apart. The AED 100 EDE application fee is a government charge. The federal penalty ranges are what a breach can cost. The production tiers are what a film costs to make. None of them convert into each other.
Common questions
Can a clinic explain a procedure on camera at all, or is that advertising?
Education is expressly permitted. DHA clause 6.9 allows health facilities and healthcare professionals to promote public health information as part of a public health campaign or public health activities, and to raise public awareness of particular products and services through public health. Appendix 1 lists a statement providing public health information encouraging preventative or corrective care as acceptable, with the qualifier that it should be evidence-based wherever possible.
Do we have to state the risks?
Yes, and this is where most explainers fail. Appendix 1 lists as acceptable, for any surgical or invasive procedure, the appropriate warning statement in a clearly visible position. It lists as not acceptable the failure to disclose health risks, the omission of that warning statement, and invasive or non-invasive procedures presented without a clear statement on the associated risks. Clause 6.6 requires advertising to be substantiated and to always include the associated risks.
What wording does the warning statement have to use?
The standard requires it in a clearly visible position without prescribing the text, and the exact wording the DHA expects was not established by this research. That is a question for your Medical Director rather than for a production company, and it should be settled before the shoot rather than at the caption stage.
Can our doctor answer viewers' questions on camera?
Not individually. Since 3 September 2025 the DHA code of ethics requires a clinician to refrain from providing individualised clinical advice to the public through social media channels, and not to favour or recommend specific medications, devices or services from particular manufacturers without clear, evidence-based clinical justification. General education is permitted. Diagnosing the person who commented is not.
Can we name the product we use?
That is where a second regime starts. The Emirates Drug Establishment operates a medical product advertisement licensing service covering printed, audio, video, social media and website advertising, requiring valid marketing authorisation, accurate and substantiated materials, clear disclosure of risks or side effects, an AED 100 application fee, three working days processing, and an expiry date referenced on the approved designs. Whether naming a category rather than a brand crosses that line was not established.
Are there things we can never say?
Prescription-only medicines may not be advertised to the general public at all. Article 39 of Federal Law No. 8 of 2019 prohibits it, with an exception only for scientific resources or magazines intended for healthcare practitioners and with ministry approval. Separately, content must not lead to inappropriate self-diagnosis or self-treatment, must not induce fear about the viewer's own health to increase demand, and must not create an unnecessary need for a procedure.
What is the exposure if we get it wrong?
Penalty exposure comes from the federal medical-products law rather than from the DHA standard itself. Reported disciplinary sanctions run from written notices and warnings to fines of AED 1,000 to AED 1,000,000, licence suspension and cancellation, with criminal penalties reported at six months to five years imprisonment and fines of AED 50,000 to AED 500,000 depending on the offence. Those figures are law-firm sourced rather than retrieved from the instrument.
What to hold onto, in one pass
Educational content is expressly permitted under clause 6.9 and Appendix 1, and an explainer is an advertisement in the regulator's vocabulary regardless. Three things move it across the line: naming a prescription product, omitting the risk statement, and manufacturing a need instead of answering a question. The risk statement is a designed, timed element that has to be readable on a phone. Naming a product moves the piece towards a different regulator with its own licence. A licensed clinician presents, captioned from the licence record, the medical director approves before publication, and the approved version gets archived.
This remains an operator's briefing rather than legal advice. Confirm the position for your own clinic and your own content before you publish.
Grolez Films: explainers built inside the standard
We build clinic explainers the way the standard is written: the patient's question first, the evidence attributed to its kind, the risk statement drafted with the medical director before the shoot and given room in the edit, and a series that comes off one properly planned day rather than four scattered ones.
Luis Grolez, the founder, pitches this personally, founder to founder. We take on a handful of clinic clients at a time, so the work does not blur. Get in touch about a specific brief and a specific quarter.
Sources and methodology
The content rules in this article are taken from the Dubai Health Authority's own published standards, cited by clause: the Standards for Medical Advertisement Content in Social Media at clauses 6.6, 6.9, 8.1.5, 8.1.6, 8.1.14 and Appendix 1, and the Standards for Code of Ethics and Professional Conduct for Health Professionals, ST-66, at clauses 10.4.5 and 10.7.3, effective 3 September 2025. The medical product advertisement licence, its scope, fee and processing time come from the Emirates Drug Establishment's own service description. The prohibition on advertising prescription-only medicines to the public under Article 39 of Federal Law No. 8 of 2019 comes from a law-firm expert guide rather than from the instrument. Penalty figures are law-firm and legal-blog sourced rather than retrieved, and are attributed as such. Three questions were left open rather than answered: the exact wording of the warning statement the DHA expects for a surgical or invasive procedure, whether naming a product category rather than a brand is treated as product advertising, and whether the EDE licence is required of a clinic as opposed to the marketing-authorisation holder. Where the DHA content standard ends and the medical product advertising regime begins is not drawn in any single document, and this article reasons across both rather than pretending the boundary is settled. This article is informational and is not legal or medical advice. Clear any clinical content with your Medical Director before publication. Prepared 11 August 2026.
- Dubai Health Authority, Standards for Medical Advertisement Content in Social Media, clauses 6.6, 6.9, 8.1.5, 8.1.6, 8.1.14 and Appendix 1: dha.gov.ae
- Dubai Health Authority, Standards for Code of Ethics and Professional Conduct for Health Professionals ST-66, clauses 10.4.5 and 10.7.3: dha.gov.ae
- Emirates Drug Establishment, licensing an advertisement for a medical product: ede.gov.ae
- CMS, expert guide to advertising of medicines and medical devices in the United Arab Emirates, on Article 39 of Federal Law No. 8 of 2019: cms.law