Recording job interviews in the UAE: federal consent rules, free zones and cross-border calls

In the UAE, plan on getting the candidate's clear agreement before you record or transcribe a job interview. The federal Personal Data Protection Law, Federal Decree-Law No. 45 of 2021, prohibits processing personal data without the data subject's consent except in listed cases, which include steps taken at the person's request before a contract and obligations under employment law. It also applies to controllers outside the UAE that process the data of people in the UAE, so a US recruiter is not outside it. Companies in free zones with their own data protection law, such as the DIFC, follow that law instead. This is the position as of October 2026.

This page adds the United Arab Emirates to our country series alongside the UK, Canada, Australia and Germany. The UAE differs from those countries in two ways that matter to recruiters: consent is the default basis in the federal data protection law, and the answer depends on whether the employer sits on the mainland or in a free zone with its own regime.

The UAE rules at a glance

Can one participant record a call in the UAE?

Do not assume a US-style one-party rule. The UAE government's data protection page lists Federal Decree-Law No. 34 of 2021 on Combatting Rumours and Cybercrimes among the country's laws related to data protection and privacy (u.ae, data protection laws). We could not retrieve the official text of that decree-law from the federal legislation portal when checking this page, so we do not summarize its privacy offences here; read them, or ask UAE counsel, before you record anyone.

For an employer, the data protection law reaches the same practical answer anyway. Because the federal law makes consent the starting point, and its exceptions are narrow, the workable approach is to tell the candidate before the interview, ask at the start of the call, record only on a clear yes, and keep evidence that you asked.

What does the federal Personal Data Protection Law require?

Federal Decree-Law No. 45 of 2021 regarding the Protection of Personal Data took effect on January 2, 2022. The government portal links the text in Arabic only (PDF, Arabic). The provisions that matter for interview recordings:

• Consent by default (Article 4). "Processing personal data without the consent of its owner is prohibited," with listed exceptions. The two closest to recruiting are processing necessary for the controller or data subject to meet obligations and exercise rights under employment, social security or social protection law, to the extent those laws allow (item 8), and processing necessary to perform a contract the data subject is party to, or to take steps at the data subject's request to conclude, amend or end one (item 9). Whether recording an interview, as opposed to taking notes, is "necessary" for either is doubtful, which is why consent is the safer route.
• What valid consent looks like (Article 6). The controller must be able to prove consent; it must be clear, simple, unambiguous and easily accessible, in writing or electronically; it must state the right to withdraw it, and withdrawal must be easy. The person may withdraw at any time, without affecting earlier processing.
• Retention (Article 5). Among the processing controls: personal data must not be kept after the purpose of processing is exhausted, unless the data subject's identity is anonymized.
• Information (Article 13). On request and free of charge, the person can obtain the types of their data processed, the purposes, decisions made through automated processing including profiling, who the data is shared with inside and outside the UAE, the criteria for storage periods and how to complain. The article also requires the controller to provide information to the person before processing starts.
• Automated decisions (Article 18). The person may object to decisions from automated processing that have legal consequences or seriously affect them, including profiling, with exceptions such as where the processing is within the terms of a contract with the controller.

The law leaves a number of details to executive regulations, which Article 28 asked the Cabinet to issue, and Article 29 gives controllers six months from the regulations' issue to bring their processing into line. Check the current status with UAE counsel before relying on any transition period.

What if the employer is in the DIFC or another free zone?

Article 2 of the federal law excludes companies and establishments in free zones that have their own personal data protection legislation. The Dubai International Financial Centre has one: the DIFC Data Protection Law, DIFC Law No. 5 of 2020 (the consolidated text linked from the government portal is the March 2022 version; check the DIFC for later amendments). Under it:

• Scope (Article 6). The law applies to a controller or processor incorporated in the DIFC regardless of whether the processing takes place in the DIFC, and to others processing personal data in the DIFC as part of stable arrangements.
• Lawful bases (Article 10). Unlike the federal law, consent is one of several bases, alongside processing necessary for a contract or to take steps at the data subject's request before one, compliance with applicable law, and legitimate interests not overridden by the data subject's interests.
• Information (Article 29). At the time of collection, the controller must tell the person who it is, the purposes and lawful basis, any legitimate interests relied on, the recipients and any transfer out of the DIFC.
• Special categories (Article 11). Sensitive data may be processed where, among other grounds, it is necessary for obligations and rights in the context of employment, which the law says includes recruitment.

What if you interview a candidate in the UAE from the US?

The federal law is written to reach you. Article 2 says it applies to every controller or processor located outside the UAE that carries out processing of the personal data of data subjects in the UAE (our translation). A US recruiter recording or transcribing a candidate in Dubai or Abu Dhabi should apply its consent and information rules, as well as their own state's recording rules (see is it legal to record a job interview). In the other direction, a UAE employer sending transcripts to a system abroad must fit Articles 22 or 23: the destination has adequate data protection legislation or a relevant agreement with the UAE, or one of the listed alternatives applies, such as a contract binding the recipient to the law's requirements.

Can you use AI note takers or transcription?

Yes, on the same consent footing. Tell the candidate which tool is used, whether audio or video is kept, where the transcript is stored and whether it leaves the UAE, and get a clear yes. If a tool scores candidates, Article 18 gives them a right to object to automated decisions. Interview Signal, for example, joins no call as a bot, shows a read-aloud consent line with a one-click pause, and does not keep audio after transcription; the transcript is still personal data under the rules above. For retention, see our candidate data retention policy template.

A consent line for interviews in the UAE

Before we start: with your permission, I'd like to [record / transcribe
with software] this interview so I can focus on you and capture your
answers accurately. [Company] will use the [recording / transcript]
only for this recruitment, store it [where], and delete it [period]
after the process ends. Do you agree? You can say no now, or withdraw
your agreement at any time, and it will not affect your application.

Offer the same wording in Arabic for candidates who prefer it, and keep a record of the answer, since the controller must be able to prove consent. More options are in our interview recording consent script.

Checklist before you record interviews in the UAE

• Which regime applies: the federal law, or a free zone's own law such as the DIFC's.
• Candidate told in writing before the interview, asked again at the start, and a clear yes recorded.
• The right to withdraw consent stated, and an easy way to do it.
• A real option to continue without recording.
• Recordings and transcripts deleted once the hiring purpose is exhausted.
• Transfers out of the UAE checked against Articles 22 and 23.
• The criminal law position on recording confirmed with UAE counsel.

For other countries in this series, see South Africa, France and Canada.