Managing Local Campaigns Before Franchising in the UAE

When an established business becomes a franchise network, local advertising is no longer a decision for the founder alone. A franchisee might launch an offer or publish an advert under the brand’s name before its terms have been reviewed or its permits checked. Before awarding your first franchise in the UAE, you therefore need a clear campaign approval process: who reviews the content, who obtains the permit and who has the authority to stop an advert? This structure protects customer trust across the franchise network without holding back useful local initiatives.

Separate brand approval from government permits

A franchisor’s approval of an advert’s design is not a government permit. Equally, the issue of a permit does not mean that the advert meets the brand’s standards. Keep these two processes separate in your procedures, and do not allow publication until all approvals and permits applicable to the campaign are in place.

In Dubai, Law No. 13 of 2011 Regulating the Conduct of Economic Activities, as amended, defines a commercial permit as the approval granted to an establishment to conduct a marketing activity. The definition of marketing activity includes advertising, signage, discounts, promotional offers, exhibitions and other activities. The law states that an establishment may not conduct marketing activities for its products or services without first obtaining a commercial permit from the relevant department, in accordance with the approved requirements.

In practice, check the campaign’s classification and requirements with the relevant economic authority before fixing its launch date. Do not automatically apply Dubai’s procedures to another emirate, or assume that approval from a shopping centre replaces an official permit. For businesses in free zones, check the rules of the relevant free zone authority and any requirements associated with the location where the campaign will run.

The UAE has no standalone, comprehensive federal franchise law, nor a general mandatory disclosure regime covering all franchise agreements. The relationship is governed by general contract and commercial transaction rules, with consumer protection, trade mark and licensing legislation applying as relevant. Federal Law No. 3 of 2022 on Commercial Agencies may apply if the relationship meets the conditions for its application. A franchise agreement therefore does not exempt either party from local advertising requirements.

Define authority before signing the agreement

Start by listing the activities the franchisee may undertake: an opening advert, paid digital posts, outdoor signage, vouchers, seasonal offers or participation in an exhibition. Then classify them according to their impact on the brand and their regulatory requirements, rather than using a broad statement such as ‘all marketing requires approval’.

You can allow the use of pre-approved materials within defined limits, while requiring a fresh review of any changes to claims, terms or the scope of the campaign. However, pre-approval of the material does not remove the need to check which permits are required when it is used.

Specify the following in the franchise agreement or its marketing schedule:

• Which party is responsible for applying for the permit, following up the application and paying the cost.
• Who is authorised to approve content on behalf of each party.
• The permitted scope of use of the brand name, imagery and digital accounts.
• Responsibility for correcting non-compliant advertising and honouring commitments made to customers.
• The right to suspend a campaign and the process for resolving any dispute about it.

Have these provisions legally reviewed: allocating responsibility between the parties does not remove either party’s responsibilities towards the relevant authorities or consumers.

Create a single file for each campaign

Rather than exchanging approvals through scattered messages, use a form that the franchisee submits before the campaign. It should include the name of the licensed business, participating branches, channels to be used, campaign duration, intended audience, final content and the terms customers will see.

Ask the franchisee to explain how the advertising promise will be delivered: is the offer available at every branch listed? Are there exclusions or quantity limits? Can staff apply it using the systems in place? An advert that looks acceptable may still lead to a complaint if the branch cannot honour it.

Add fields identifying the permit required, the authority to which the application will be made, the application status and any conditions attached to approval once granted. Keep a copy of the permit and the approved materials in the same file. If the campaign’s timing or content changes after approval, check whether the permit needs to be amended or the campaign approved again.

Make the file’s status clear: draft, under review, awaiting permit, approved for launch, then closed. Do not treat a lack of response as implied approval; appoint a backup reviewer and establish an escalation route for delays.

Test the process and establish a stop-and-correct procedure

Trial the approval process on a real campaign in your existing business before handing it over to a franchisee. Measure how long reviews take, identify documents that are repeatedly requested and test whether branch staff understand the terms. The aim is to test how advertising is managed, not to reassess the entire operating model.

After launch, assign someone to compare the published advertising with the approved version, including marketing agency posts and materials displayed in the branch. Retain evidence of publication and record complaints and amendments, rather than measuring views or sales alone.

Establish a rapid response procedure for any breach: stop publication or promotion where necessary, notify those responsible, preserve evidence and determine the appropriate correction, coordinating with the relevant authority where needed. Agree in advance how to deal with customers who relied on the advert, rather than leaving branch staff to devise inconsistent solutions.

Practical takeaway: Before awarding a franchise, prepare a schedule setting out marketing authority, a campaign request form, a permit register and a stop-and-correct procedure. These tools give franchisees room to take the initiative while ensuring that advertising promises can be reviewed and fulfilled.