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A comprehensive guide for insurers, policyholders, and market participants
Executive summary
Sanadak is the UAE's independent financial and insurance ombudsman, established by the Central Bank of the UAE (CBUAE) to resolve consumer complaints against licensed financial institutions and insurance companies. The name is an Arabic expression meaning "Your Support." It began operations on 7 March 2024, replacing the former Banking and Insurance Dispute Settlement Unit (BIDRU), and is the first legally independent ombudsman unit in both the UAE and the MENA region.
For the insurance market specifically, Sanadak represents a mandatory first step before any court proceedings. Under the current framework, most onshore insurance disputes must be referred to Sanadak before proceedings can be commenced in UAE courts.
The system is free for consumers. Insurance companies and licensed financial institutions bear the cost of the system through an annual levy and case fees. If Sanadak cannot resolve a complaint, cases escalate to the Insurance Disputes Settlement and Resolution Committee (IDSRC), a judicial body chaired by a judge, whose decisions carry the force of a writ of execution.
Legal basis and regulatory framework
Establishment
Sanadak was established under CBUAE Decision No. 1659/2023, issued pursuant to the "Regulation Concerning the Establishment of an Ombudsman Unit in the UAE" (the Ombudsman Regulation), published in the Official Gazette in March 2023. The regulation provided a one-year implementation period, making Sanadak operational from March 2024.
Governing legislation
The overarching legislative framework has evolved through three key instruments:
- Federal Decree-Law No. 48 of 2023 Regulating Insurance Activities — Issued November 2023; repealed by Law No. 6 of 2025 (September 2025). First established the Insurance Disputes Settlement and Resolution Committees under CBUAE oversight. Elevated the committees' judicial status by directing appeals to the Court of Appeal rather than the Court of First Instance.
- Federal Decree-Law No. 6 of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business — In force (effective 16 September 2025), one-year transition period. Consolidated law that repealed both Federal Decree-Law No. 14 of 2018 and Federal Decree-Law No. 48 of 2023. Unifies banking and insurance regulation under a single statute. Formalizes Sanadak's role as mandatory pre-court dispute resolution mechanism.
- CBUAE Ombudsman Regulation (Decision No. 1659/2023) — In force. Establishes Sanadak as an independent legal entity, defines its mandate, scope, funding, complaint procedures, and appeal mechanisms.
Institutional independence
Sanadak enjoys legal personality and is financially and administratively independent from the CBUAE. Its principal mandate is to receive, handle, review, and resolve complaints in a thorough, timely, transparent, fair, and legally sound manner. This independence is a structural feature designed to ensure impartiality — Sanadak is not an arm of the insurance regulator making enforcement decisions, but a separate dispute resolution body.
The three-tier dispute resolution system
The UAE operates a mandatory three-tier system for consumer and retail insurance disputes. Each tier must be exhausted before the next becomes available.
Tier 1: Internal complaint to the insurance company
The policyholder or beneficiary must first raise a formal complaint directly with the insurance company. The insurer has up to 15 calendar days to provide a response. This timeline was reduced from the original 30 calendar days stipulated in the Ombudsman Regulation, as part of Sanadak's operational efficiency improvements announced in late 2024/early 2025.
Important for insurers: Sanadak will reject a complaint if the consumer did not first raise an official complaint with the insurer and wait the requisite period. This means insurers must have a functioning internal complaints process with documented timelines. Failure to respond within the internal window effectively opens the door to Sanadak intervention.
Tier 2: Sanadak (the Ombudsman)
If the consumer is dissatisfied with the insurer's response — or if the insurer fails to respond within the required period — the complaint can be escalated to Sanadak. This is a mandatory step; court action cannot be initiated without first going through Sanadak. The service is free for consumers.
Sanadak reviews the complaint, requests documentation from both parties, and issues a determination. Complaints can be upheld, partially upheld, or rejected. If the consumer accepts the outcome, the case closes within five working days.
Tier 3: Insurance Disputes Settlement and Resolution Committee (IDSRC)
If either party disagrees with Sanadak's determination, the case can be escalated to the IDSRC, a judicial committee established under the insurance law. The IDSRC is chaired by a judge and includes another judge plus one or more experts appointed by the CBUAE. It has the power to settle all types of insurance disputes regardless of monetary value. Committees sit in Abu Dhabi and Dubai, with sessions in other emirates as needed. Virtual hearings are permitted.
IDSRC decisions carry the force of a writ of execution — meaning they are enforceable without further court proceedings. For disputes valued at AED 50,000 or less, IDSRC decisions are final with no appeal. For disputes exceeding AED 50,000, either party may appeal to the Court of Appeal within 30 days.
Detailed process: what happens at each stage
Filing a complaint with Sanadak
Who can file: Individuals (natural persons), sole proprietors, and small and medium enterprises (SMEs) as defined in the Ombudsman Regulation.
What can be complained about: Sanadak handles complaints involving all types of insurance — motor, health, property, marine, life, and compensation disputes. Eligible complaints include failure to provide a requested service or product due to arbitrary reasons, discriminatory or deceptive conduct, misleading or fraudulent practices, unfair treatment, and financial loss caused by insurer misconduct.
How to file:
- Website: sanadak.gov.ae
- Mobile app via UAE Pass
- Telephone: 800 SANADAK / 800 72 623 25
- Email: info@sanadak.gov.ae
- In person at the Abu Dhabi office (Monday to Thursday, 7:30 AM – 3:30 PM)
Filing deadline: Complaints must be filed within three years from the date of the conduct that gave rise to the complaint, or within two years from the date the complainant became aware of the conduct, whichever period is longer.
Grounds for rejection
Sanadak will reject a complaint if:
- The consumer did not first raise an official complaint with the insurer
- The required waiting period after filing with the insurer was not observed
- The complaint is identical to one already under review
- Court proceedings are ongoing for the same matter
- The complaint falls outside CBUAE's regulatory mandate
- The complaint concerns internal company policies, pricing decisions, or AML/CFT practices
- A pre-settlement agreement already exists between the parties
Resolution timeline
- Complaint acknowledgment by Sanadak: Within 3 business days
- Sanadak issues initial response / contacts parties: Within 15 working days
- Insurer must provide clarifications (once referred to IDSRC): 5 working days via Sanadak's e-system
- Referral to IDSRC committee (if needed): Within 5 working days
- Request for additional information from parties: Up to 10 business days to respond
- IDSRC committee decision: 20 working days from receipt of all documents (extendable)
- Appeal of Sanadak determination: Within 30 business days of determination
- Appeal of IDSRC decision (disputes > AED 50,000): Within 30 days to Court of Appeal
- Case closure after acceptance: Within 5 working days
Fee structure
Fees for consumers and SMEs
- Filing a complaint with Sanadak: Free — no charge at any point for the initial complaint
- Appealing a Sanadak determination: AED 500 per appeal — refunded if the determination is in the consumer's favor. The Chief Ombudsman may waive this fee in exceptional circumstances.
Fees for insurance companies and licensed financial institutions
The Ombudsman Regulation establishes four fee types that fund Sanadak's operations. These are borne by the regulated entities — not by consumers.
- Annual levy: A fee levied on all licensed financial institutions and insurance companies on an annual basis. Payment is due within 30 calendar days of the assessment notice. The specific amount is set by Sanadak's Board and is not publicly disclosed.
- Case fee: A fee levied on the insurer for each complaint closed by Sanadak during a financial year, regardless of when the complaint was originally referred. Specific amounts are not publicly available.
- Supplementary levy: An additional levy that may be imposed if the annual levy and case fees are insufficient to cover Sanadak's operational costs.
- Appeals fee: AED 500 for consumers. The regulation does not specify a different amount for insurers appealing.
Fees at the IDSRC (Judicial Committee) stage
These fees took effect on 1 May 2024:
- Fixed-value disputes: 4% of the claim value, minimum AED 100, maximum AED 30,000
- Unspecified-value disputes: Fixed fee of AED 3,000 (applies where the monetary value cannot be determined at filing)
Obligations for insurance companies
Internal complaint handling
Under the CBUAE Consumer Protection Regulation, all licensed insurers must maintain a formal complaint handling mechanism. This includes providing clear information on how to file a complaint (including contact details and channels such as email, phone, and fax), defined response times, and continuous monitoring and improvement of complaint handling effectiveness.
Responding to Sanadak
When a complaint is referred to the insurer through Sanadak, the insurer must respond within the timelines set by the system. If the matter escalates to the IDSRC, the insurer must provide clarifications within 5 working days via Sanadak's electronic system. The complainant may then object and request a formal committee referral, which occurs within a further 5 working days.
Compliance consequences
Non-attendance at IDSRC hearings without acceptable excuse allows the committee to issue a determination if the case is ready for decision, or to dismiss the case (with the complainant having 30 days to refile).
IDSRC decisions are enforceable as writs of execution. An insurer that fails to comply with a committee decision is subject to enforcement proceedings under applicable UAE law.
Separately, CBUAE maintains a schedule of administrative fines under Cabinet Resolution No. 7 of 2019. This resolution lists 204 violations with corresponding penalties, applicable to all UAE insurance companies and insurance-related professionals including TPAs and loss adjustors. The maximum fine is AED 2 million, doubled for repeat violations within one year.
Scope and exclusions
What Sanadak covers
Sanadak handles complaints against insurance companies and licensed financial institutions regulated by CBUAE. This includes all onshore UAE insurance companies writing motor, health, property, marine, life, and other lines of business. The mandate covers product and service delivery failures, arbitrary service denials, and financial harm from insurer misconduct.
What Sanadak does not cover
- Complaints about internal company policies or pricing — Commercial decisions are outside the ombudsman's scope
- AML/CFT-related matters — Handled by the Financial Intelligence Unit
- Disputes already before the courts — Prevents parallel proceedings
- Disputes subject to valid arbitration agreements — Arbitration takes precedence
- Claims between insurance professionals (insurer-to-insurer, reinsurance) — Sanadak is for consumer protection, not commercial disputes between licensed entities
- DIFC and ADGM-regulated entities — Free zone financial services regulators have their own dispute resolution mechanisms
- Subrogation claims by insurers — These are insurer commercial actions, not consumer complaints
The 2025 Law: what changed
Federal Decree-Law No. 6 of 2025, issued on 8 September 2025 and effective the following day, is the consolidated law that brought banking, financial institution regulation, and insurance regulation under a single statute. It repealed both the 2018 CBUAE law and the 2023 insurance law.
Key changes relevant to Sanadak and insurance disputes:
- Consolidated mandate: The law unifies consumer complaints for banking and insurance under Sanadak, reinforcing its role as the single front door for all regulated financial and insurance disputes.
- Mandatory pre-court referral: The requirement that most onshore insurance disputes pass through Sanadak before court proceedings is now embedded in the consolidated statute.
- Enhanced consumer protection: Article 149 mandates robust fraud prevention, prompt breach notification, and transparent fee disclosure.
- Resolution authority: The law establishes a formal Resolution Authority within CBUAE for financial institutions and insurers, extending beyond dispute resolution into regulatory intervention.
- Transition period: A one-year transition period applies for all in-scope entities to align operations with the new law's requirements. This period may be extended by the CBUAE Board.
Practical implications for insurers
Direct financial exposure
Each complaint that reaches Sanadak generates a direct cost to the insurer through the case fee, in addition to the annual levy all licensed entities pay. While specific fee amounts are not publicly disclosed, the structure creates a clear financial incentive for insurers to resolve complaints internally before they escalate. An insurer with a high volume of Sanadak complaints will bear proportionally higher costs.
If the complaint escalates to the IDSRC, further costs arise: the 4% of claim value filing fee (minimum AED 100, maximum AED 30,000), legal representation costs, and management time spent on committee proceedings.
Operational requirements
Insurers need robust internal complaint handling processes that meet CBUAE Consumer Protection Regulation standards. This includes documented procedures, clear response timelines, trained complaint handling staff, and systems to track complaint volumes and resolution rates. A failure at the internal stage — particularly failing to respond within the required period — automatically gives the consumer grounds to escalate to Sanadak.
Reputational considerations
Sanadak creates a centralized record of complaints against each insurer. While complaint data is not currently published in a public league table, the CBUAE has the data and the regulatory interest to use it. Insurers with disproportionately high complaint volumes relative to their market share may attract supervisory attention.
Precedent-setting decisions
Sanadak has shown willingness to favor proportionate outcomes in certain cases. For example, in non-disclosure disputes where a misrepresentation affected pricing rather than the acceptability of the risk, Sanadak has in some cases favored proportionate remedies rather than total policy avoidance. These outcomes are fact-dependent and not codified, but they signal a consumer-protection orientation that insurers should factor into claims handling decisions.
About the author
This report was prepared by Axxion Claims Settlement Services L.L.C., a Dubai-based end-to-end motor claims management company and the UAE's first dedicated motor TPA. Axxion manages the full claims lifecycle for insurance partners, from first notification of loss through repair coordination, quality control, and settlement.
Axxion is part of the Skelmore Group, a diversified automotive and insurance services group founded in Toronto in 1994, operating across North America and the Middle East with approximately $650 million in revenue and 4,000 employees.
