Healthcare Premises in Dubai: DHA, DHCC and Fit-Out Approvals Investors Need to Know

Health facilities in mainland Dubai are licensed by the Dubai Health Authority (DHA), and DHA's own guidelines are explicit about the single exception: all health facilities in Dubai require a DHA licence "with exception of those located within the Dubai Healthcare City Freezone (DHCC)", which falls to the Dubai Healthcare City Authority (DHCA) instead.

For premises located in other free zones, DHA advises applicants to check the process with the relevant free-zone authority as well — the health licence still comes from DHA, but the building approval route may run through Trakhees for JAFZA and Dubai World Central or through the relevant authority in DDA/TECOM, DIFC and DMCC. Health licensing is one of several external approvals that sit outside the standard trade licence path, covered more broadly in our guide to external government approvals for Dubai business licences.

DHA runs the facility approval as two online applications through the Sheryan portal, and the building approvals from other authorities sit between them. Part A describes the DHA Health Facility Approval Process as part of the General Building Approval Process, which is "governed and managed by the Dubai Municipality in coordination with other Authorities".

Two details matter commercially. First, DHA inspectors compare the built facility against the approved drawings and record one of four outcomes — approval, approval with conditions, suspension, or outright rejection. A suspension requires a second inspection at additional fee.

Second, and more dangerous for a programme: if Dubai Municipality or Civil Defence require design changes after DHA has approved, it is the applicant's job to re-submit those changes to DHA. Part A warns that significant changes made at another authority's request but not reported to DHA "will risk future penalties such as denial of 'Licence to Operate' certificate post construction completion". A tenant who quietly value-engineers the layout to satisfy the Municipality can therefore reach practical completion with an unlicensable clinic.

On the DHA side, the Sheryan New Facility License service page states an average processing time of 5 working days — that is the label the page uses, and an average is not a guaranteed turnaround. Initial approval fees vary by facility classification, from AED 500 for a first-aid unit up to AED 2,000, with knowledge and innovation fees applied at checkout. Required documents include owner and partner passport copies, an engineering layout from an engineering or design company, and a completed facility proposal; a trade licence is optional at this stage. Applicants must also hold an electronic medical record compliant with NABIDH standards.

Every healthcare premises also needs a Dubai Civil Defence fire NOC — see our companion guide, Dubai Civil Defence approval and fire and life safety requirements, for how that process works across all sectors, and our guide to the Dubai Municipality fit-out permit process for the mainland building permit itself.

Less precisely than it first appears, and the distinction matters commercially. DHA publishes detailed room-by-room schedules, but it publishes them as samples rather than as thresholds — a point the schedules themselves are explicit about, and one that is easy to lose when a number is lifted out of the table.

The first question is which chapter applies. Part B, chapter 360 (Outpatients Unit) states that it is "applicable to a wide range of facilities including (but not limited to) Polyclinics, Specialist Clinics, Primary Health Centres, General Clinics, School Clinics, Dental Clinics, Rehabilitation Centres and Traditional, Complementary and Alternative Medicine Centres (TCAM)". That is a permissive applicability note, not a routing rule. What actually determines the chapter a given facility must be designed against is Part A's table of mandatory Functional Planning Units by Sheryan facility type — and on two of the types in that list, Part A points somewhere else. A Dental General Clinic takes the Dental Surgery Unit (Part B chapter 100) as its mandatory FPU, and a TCAM Center takes the Complementary & Alternative Medicine Unit. Polyclinics and Specialty Clinics do take the Outpatients Unit. Check the facility type against Part A before sizing anything against chapter 360.

For those facilities that do route to the Outpatients Unit, the Schedule of Accommodation is set out by consult room count:

Individual rooms are smaller than commonly assumed. A combined consult/examination room is 13 square metres; an ENT or ophthalmology consult room 14 square metres; a procedure room 20 square metres; a treatment room 14 square metres; an accessible toilet 6 square metres. Waiting areas are sized at a minimum of two seats per consult room, and schedule areas take precedence over the standard component sheets.

Read the schedule's own qualifications, though, because they are stronger than the table looks. The note beneath it reads in full: "Room sizes indicated should be viewed as a minimum requirement; variations are acceptable to reflect the needs of individual Unit". Variation is expressly contemplated, not merely tolerated. The preamble goes further still — "These guidelines do not dictate the size of the facilities, therefore, the SOA provided represents a limited sample based on assumed unit sizes. The actual size of the facilities is determined by Service Planning or Feasibility Studies." A further note adds that exact room quantities and sizes "shall reflect Key Planning Units (KPU) identified in the Clinical Service Plan and the Operational Policies of the Unit". Where a deviation from a mandatory requirement is proposed, it is recorded in a Non-Compliance Report for DHA's consideration, but that mechanism sits alongside the permitted variation in the schedule rather than replacing it.

One oddity in the table is worth knowing about before a consultant raises it. Three of the four columns close arithmetically at the stated 32 per cent circulation allowance — 132.5, 590 and 790 square metres net give 174.9, 778.8 and 1,042.8 respectively. The eight-room column does not: DHA prints 376 square metres net and 484.4 square metres departmental, which is not the same relationship. Both figures are DHA's own published numbers and we have reproduced them as printed rather than adjust either one. For appraisal purposes use the departmental total, which is the figure the design is assessed against.

On edition, the Part B chapters carry a 2019 date while Part A carries 2023. That gap is real but it is not an open question: the DHA guidelines portal was read in full on 17 August 2026 and the Outpatients, Dental Surgery and Pharmacy chapters it currently serves are the 2019 edition, DHA's November 2024 outpatient standard still refers facilities to those chapters, and the DHA circulars register showed no circular amending the Health Facility Guidelines when re-checked the same day. The 2019 chapters are the current ones.

For an investor, the practical translation is that the 174.9 square metres of departmental area for a three-consult-room outpatient clinic is DHA's sample for the clinical unit alone. For a stand-alone facility, Part B expressly allows designers to add further Functional Planning Units — a Main Entrance Unit, medical imaging, a laboratory unit, supply, housekeeping — on top of that figure according to the business model, so 174.9 square metres is a floor for the clinical space rather than a ready-made shell size. A dental practice is a different calculation, set out below.

DHA's Pharmacy Guidelines set explicit minimum areas by pharmacy category: 30 square metres for a community or retail pharmacy, 30 square metres for a hospital pharmacy, 25 square metres for an ambulatory care pharmacy, and 15 square metres for an inpatient pharmacy. The same document sets a minimum ceiling height of not less than 2.70 metres (8 feet 8 inches), and confirms that a pharmacy is expected to meet the building standards required by Dubai Municipality or the free-zone authority, with access provided for People of Determination.

For detailed layout, the Pharmacy Guidelines refer the reader on to the DHA Health Facility Guidelines Part B, Pharmacy Unit, citing the 2019 edition. The chapter is number 370: that is the number printed on the chapter's own cover page, and the number the Pharmacy Guidelines themselves use in their bibliography. Clause 5.3.11 of the Pharmacy Guidelines is inconsistent with the rest of that document and calls it 350 — if a consultant or contractor quotes chapter 350 back at you, that is where it comes from, and 370 is the chapter that actually exists. The Pharmacy Guidelines themselves set out several premises rules that bind directly, without needing Part B at all:

• Ground floor by default. A community or retail pharmacy should be located on the ground floor, and may only sit on a higher floor if it is inside a commercial centre or mall.
• Counselling space. DHA recommends the pharmacy provide adequate space for patient counselling.
• Narcotics and controlled-drug storage. DHA's own Pharmacy Guidelines are not internally consistent on this point: clause 14.2.13(e) closes the document's cabinet list — covering narcotic, controlled/semi-controlled, prescription-only and expired-medication cabinets — by saying those cabinets must be placed away from the general sales area, while clause 18.6.3, dealing specifically with narcotics, CD and SCD cabinets, says the same placement should happen and that the cabinets shall be inaccessible to the public. For fit-out purposes, price the stricter reading — placement away from the sales area treated as mandatory. The main narcotics cabinet must be steel with internal hinges, have a double locking system, be securely fixed to the wall or floor, use non-duplicable keys, and have a security or alarm system and/or a security camera.
• Storage conditions. Storage must be kept at least 50 cm below the ceiling and off the floor, with relative humidity no more than 60 per cent and temperature within 8 to 25 degrees Celsius.
• Back-up power for the medication fridge. DHA's wording is that a sufficient back-up emergency power supply for the refrigerator should be available, to protect medication in the event of an emergency power cut. It is expressed as a recommendation rather than an absolute requirement, but it is the kind of provision a tenant will expect the shell to be capable of supporting.

For a landlord, the 2.70-metre ceiling height is usually the binding constraint. Many older retail shells, and almost any unit with a heavily serviced suspended ceiling, will fail it before any other test is applied — and the 50 cm clearance below the ceiling compounds it, because the usable stacking height is lower again. The other two to price are environmental and electrical: an 8 to 25 degree band with humidity control is a cooling and dehumidification duty rather than an operational nicety, and the recommended refrigerator back-up means a tenant will be looking for a resilient supply. Our guide to DEWA load and connection requirements covers how that capacity is applied for, and DEWA and Civil Defence NOCs during fit-out covers where those approvals sit in the build.

DHA's Standards for Outpatient Facilities (issued November 2024, effective January 2025) layers operational requirements on top of the design guidelines, several of which have physical consequences:

• No 24-hour operation. Outpatient facilities are not permitted to operate on a 24-hour basis.
• Acoustic design. Facilities must be designed to minimise ambient noise and sound transmission between consult and treatment areas, staff areas and public areas.
• Dedicated rooms by specialty. Dental, ENT and ophthalmology require dedicated rooms not shared with other practices. Obstetrics and gynaecology may share with orthopaedics, neurology and urology, since all use ultrasound — but patient washrooms must be close to the ultrasound room with a nursing call system.
• Dental sterilisation space. A dedicated space of not less than 2 square metres is required for cleaning and sterilising dental instruments, and this must not happen inside the dental room.
• A physically separate sterilisation room. It must be physically separated from all other areas of the facility, with restricted access, high-vacuum steam sterilisers, handwashing stations in the clean room, the instrument processing area divided — physically or at minimum spatially — into three distinct areas for decontamination, preparation/packaging/sterilisation and sterile storage, and a one-way workflow from contaminated to clean.
• A locked, ventilated medical waste room. Appendix 2 to the standard, "PCI Requirements of Equipment and Items", lists a medical waste room at a quantity of one, requiring bins with yellow bags for the disposal of sharps and pathological or medical waste, a ventilated room, biohazard signs and a locked room.
• No carpets in examination and treatment rooms. Where carpet is used in patient waiting areas and corridors it should be glued or stretched tight and free of loose edges and wrinkles.
• No plants. Adding real or artificial plants is strictly prohibited throughout an outpatient facility to prevent the spread of infection, with reception and waiting areas the only permitted exception.
• A ground-floor clinical room in a two-floor clinic. If the clinic occupies two floors, there must be a treatment room or dental room on the ground floor to accommodate people of determination and elderly patients if the lift is not operational.
• Waste and infection control. A contract with a specialised medical waste company is required, meeting the conditions of Dubai Municipality's Public Health Department, with colour-coded segregation bins. Sinks must have deep basins in porcelain, stainless steel or solid surface materials.
• Security and safety systems. A visual surveillance system, an access control system, and a fire safety plan covering detection, containment, evacuation and alerting Dubai Civil Defence.
• Pre-construction risk assessment. Required for any new construction, renovation or demolition activity.

Three of those have direct leasing consequences. A restricted-access sterilisation room and a lockable, ventilated waste room are two rooms a general office or retail shell does not contain, and neither can be conjured out of circulation space — they take net area that would otherwise be revenue-generating consult rooms, which is part of why the departmental totals above run so far above the sum of the clinical rooms. The two-floor rule quietly closes off a common landlord solution: splitting a clinic between a ground-floor reception and a first-floor clinical suite is only workable if at least one treatment or dental room stays downstairs. And the ban on plants is worth flagging to any landlord whose building management installs planting in demised areas as standard.

Facilities inside Dubai Healthcare City are licensed by DHCA under its own rules. DHCA Rule No. 1 of 2025, effective 2 May 2025, publishes both the commercial licence fee and the minimum share capital by activity:

Two structural points sit behind that table. Each licensee is permitted to carry out one primary activity under its licence; further activities may be added on request, subject to DHCA approval and additional charges. And commercial licences are valid for one year and renewable annually — so the licence and the lease run on different clocks unless they are deliberately aligned. For the medical hub activity specifically, DHCA publishes a package fee of AED 22,000 a year for issuing an unlimited number of professional licences for doctors.

Three provisions matter to an asset owner. Licensees must obtain an Operating Permit from DHCA at licence issuance, amendment or renewal, and all licensed healthcare facilities must obtain a Clinical Operating Permit before commencing operation. Licensees must maintain valid commercial licence and lease agreements at all times, with revocation possible without prior notice if they lapse. And any third party operating inside a healthcare facility's premises under a lease or contract must hold its own separate commercial licence — relevant to any medical centre landlord planning concession space.

Note also that DHCC is not a route around DHA. The Rule's activity tables name DHA as the external approval for clinical activities, and its section on operating, education and research permits requires facilities providing clinical services to obtain prior approval from DHA before DHCA issues the licence. Article 3.4 adds that operations may not commence until all required permits, approvals and licences are in place, including any external approvals or no-objection letters.

DHCA does not publish a processing time, and none is quoted here. Rule No. 1 of 2025 sets out fees, share capital, external approvals and permit requirements, but contains no decision deadline. DHCC's Setting Up Business and Apply for License pages stated no turnaround for a commercial licence or for a Clinical Operating Permit when checked on 17 August 2026; the application page characterises the process only in general terms. Programme assumptions for a DHCC letting therefore have to come from the tenant's own recent experience rather than from anything DHCA publishes. The mainland route is only marginally better served: the DHA Sheryan service page gives an average processing time of 5 working days for the new facility licence application, which is a historic average for one stage rather than a commitment for any particular application. If a DHCC void period is being priced into a deal, price the uncertainty rather than a borrowed number.

DHA restricts healthcare design to prequalified Health Facility Design Consultants, prequalified for three years at Category 1 or Category 2. Category 1 covers the smallest and simplest facilities; Category 2 adds practical experience in hospitals and surgical facilities. The category required follows the facility type:

This is worth checking at heads of terms. A tenant who has already appointed a general commercial fit-out designer, rather than a prequalified consultant, has not yet started the clock — and for imaging or laboratory uses they need a Category 2 practice, of which there are fewer.

The pharmacy rows deserve particular attention from any landlord planning a medical centre with a pharmacy concession. Part A treats the two cases differently: a stand-alone pharmacy in any location sits at RDL 1 and Category 1, but a pharmacy attached to an ambulatory care centre, polyclinic or similar sits at RDL 2 and Category 2. The concession arrangement that looks like the simpler deal is the one that requires the scarcer and more expensive class of designer, and that is a cost and a programme item to surface before terms are agreed rather than after.

Electrical capacity deserves particular attention, since clinics sit well above general office demand — our guide to how electrical load needs vary by business activity covers clinics specifically. The wider pre-signature discipline is set out in our licensing and premises due diligence checklist.

Beyond the pre-signature checks above, three considerations bear on the asset rather than the transaction.

Because healthcare fit-outs are capital-intensive for the tenant, they tend to reduce churn risk once installed: an operator who has invested in a DHA-approved layout, and whose licence is tied to that approved layout, is materially less likely to relocate than a lighter-fit-out retail tenant. That trade-off — higher upfront specification and a longer void against lower expected turnover — is worth weighing explicitly, and it feeds directly into how the asset is valued. Our article on how commercial properties are valued in Dubai explains how covenant strength and lease length flow into the capitalisation rate, while the VAT rules on buying commercial property in Dubai covers the tax treatment of the acquisition itself.

The same logic applies in reverse when re-letting. DHA's rules on existing facilities are graduated: changing the type of service, or remodelling more than 50 per cent of a department, requires the whole unit to comply with current guidelines, and that 50 per cent threshold is cumulative across successive applications. Superficial redecoration does not trigger retrospective compliance. An older clinic unit that has been incrementally altered may therefore be much closer to a full re-approval than its condition suggests — worth establishing before you underwrite a quick tenant swap. For comparison with other regulated uses in the same building, see our guides to food and beverage premises approvals and education and training premises approvals.