Federal Decree-Law No. (25) of 2025 promulgates a new UAE Civil Transactions Law, in force on 1 June 2026. It replaces the 1985 law in full. For hotel operators, restaurants, cafés, and venue managers in the UAE, the Civil Code provisions on guest property, hotelier privilege, gratuities, and adhesion-style booking terms are now restated with cleaner wording and a clearer void-clause map.
Here are four operational changes worth baking in before 1 June 2026.
1. Guest-property liability and the safekeeping protocol — Article 928
Article 928(1) confirms the hotelier's liability for the safekeeping of guest property, extending to acts by persons frequenting the establishment — not only by hotel employees. Article 928(2) carves out money, negotiable instruments, and valuable items unless:
- the hotelier received them for safekeeping;
- the hotelier unjustifiably refused to receive them for safekeeping; or
- the damage occurred as a result of fault on the hotelier's part or that of an employee.
Two practical takeaways. First, the in-room and front-desk safekeeping infrastructure has to be genuinely available and used — not buried in a policy that the guest cannot reach. Second, the refusal limb is itself a liability trigger: refusal to accept valuables for safekeeping must be supported by a documented operational reason.
2. The six-month claim window — Article 929
Article 929 imposes two parallel disciplines:
- The guest must notify the proprietor or the person in charge of theft, loss, or damage immediately upon becoming aware; delay without excuse forfeits the claim.
- The guest's claim against the hotelier is time-barred 6 months from the date of departure.
Two operational steps follow. First, an incident-log standard that captures contemporaneous notes — guest name, item, time, circumstances — should be in place. Second, every open guest-property claim received post-stay should sit on a six-month diary; the defence window is short.
3. The hotelier's privilege over baggage — Article 1416
Article 1416 codifies the hotelier's privilege: amounts due from a guest for accommodation, provisions, and account expenses have a privilege over the baggage brought by the guest to the hotel.
The privilege extends to baggage even if not owned by the guest, unless the hotelier knew of a third party's right at the time the baggage was brought in. The hotelier may object to removal of the baggage for outstanding accounts; if it is removed despite the objection or without the hotelier's knowledge, the privilege follows the baggage subject to good-faith third-party rights.
For collection workflows on dispute-laden guest accounts, this is a meaningful lever. Front-desk and security should be trained on the privilege and the right of objection. Article 1417 confirms the same rank as the lessor's privilege, with earlier-in-date prevailing where both exist.
4. Gratuities as wage — Article 846
Article 846 codifies the wage-status of gratuities in F&B and hospitality:
- Gratuities form part of the wage in industries where it is customary to pay them, provided there are rules that allow regulation.
- Where customers' gratuities are collected centrally — into a joint fund or electronic system — for distribution by the employer or under their supervision, the gratuity is part of the wage.
- In certain hotel, restaurant, and café occupations, the employee may have no wage other than gratuities and consumed food.
This is more than a labour-law issue. The wage-status carries consequences for settlement of rights at end of service and for attachment in execution. For operators running pooled-tip mechanics, the policy should be expressly documented to match Article 846 — and HR / payroll should reflect the wage-status implications.
A note on booking, banquet, and venue-hire terms
Standard booking and banquet contracts are typically adhesion contracts under Article 118(2). Article 223 gives the court an express power to modify unfair conditions, and any agreement to the contrary is void. Disproportionate cancellation, no-show, and rebooking penalty clauses are exposed; reciprocity in force-majeure drafting is the safer position. Article 134 confirms that acceptance in adhesion contracts is limited to mere acceptance of uniform conditions — relevant for online check-in and click-wrap booking flows.
The pre-contractual disclosure duty at Articles 121–123 also reaches corporate-event and venue-hire proposals. Material disclosures about venue condition, capacity, and licensing are part of the picture; clauses that try to exclude the duty are void (Article 122(4)).
A note on insurance for hospitality risks
Where general-liability or property insurance covers the venue, the Article 958 void-clause map applies in full: forfeiture for unrelated law violations, excused late notice, hidden printed conditions, embedded arbitration clauses, and unfair conditions without causation. Hotel managers should request a refreshed policy schedule from brokers and confirm the arbitration clause is a standalone signed agreement, not buried in general printed conditions.
Related Civil Code 2025 guides
Published 18 May 2026. General information only — not legal advice. Contact us for matter-specific advice.