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Deliverability and consent3 min read

PDPL and WhatsApp marketing: UAE and Saudi rules

By Shraddha Agarwal

The short answer: The UAE and Saudi Arabia each have a Personal Data Protection Law (PDPL). For WhatsApp marketing, both expect consent you can prove and an easy way to stop, and the Saudi PDPL names direct marketing outright. Meta's opt-in rules apply on top.

This guide is general information, not legal advice.

The two laws at a glance

TopicUAESaudi Arabia
LawFederal Decree-Law No. 45 of 2021Personal Data Protection Law, Royal Decree M/19
In force2 January 202214 September 2023
RegulatorUAE Data OfficeSDAIA
Detailed rulesExecutive regulation not yet publishedImplementing Regulation in force
Marketing consentNeeded, and you must prove it (Art. 4, 6)Prior consent (Art. 25)
StoppingRight to object to direct marketing (Art. 17)Opt-out as easy as opt-in (Reg. Art. 29)
Breach noticeTo the Data Office and affected people (Art. 9)To SDAIA within 72 hours (Reg. Art. 24)
FinesLeft to a Cabinet decision, none published (Art. 26)Up to SAR 5 million (Art. 36)
ReachBusinesses abroad processing data of people in the UAEProcessing abroad of data of Saudi residents

UAE: Federal Decree-Law No. 45 of 2021

  • Consent first. Processing needs consent unless a listed exception applies, such as performing a contract (Art. 4).
  • Provable consent. It must be specific, clear and unambiguous, and say it can be withdrawn easily (Art. 6).
  • Marketing stops on request. A customer can object to direct marketing, including profiling for it (Art. 17).
  • Free zones. A free-zone company under its own data protection law follows that law instead (Art. 2).

The executive regulation was not on the UAE legislation portal on 7 October 2026. Once issued, businesses get up to six months to comply, extendable once (Art. 29).

Marketing messages on social media apps also fall under the 2024 telemarketing rules, which our UAE guide summarizes.

Saudi Arabia: the PDPL and its Implementing Regulation

  • Prior consent. No advertising to a person's contact details without prior consent and a clear way to stop (Art. 25).
  • Consent per purpose. It must be free, documented and separate for each purpose (Reg. Art. 11).
  • Direct marketing. Name the sender, make the opt-out as easy as the opt-in, and stop without delay (Reg. Art. 29).
  • Registration. SDAIA's register applies to some businesses, such as those whose main activity is processing personal data.

The one-year grace period ended on 14 September 2024. Fines reach SAR 5 million, doubled for a repeat violation (Art. 36), and unlawfully disclosing sensitive data can bring up to two years in prison (Art. 35).

Meta's rules on top

Meta's Business Messaging Policy requires opt-in before you message someone first, asks you to honor every opt-out, and makes your business responsible for complying with local law. Our opt-in guide covers what counts and what to record.

A checklist for WhatsApp marketing

  • Record each consent with its purpose, channel, wording, source and time.
  • Keep marketing consent separate from order and booking updates.
  • Name your business in every marketing message.
  • Make stopping as easy as opting in, and suppress the number before the next send.
  • Have a breach plan that can notify SDAIA within 72 hours.
  • Check whether your business must register with SDAIA.

Where Otobiz fits

Otobiz Consent and Opt-outs records each grant and withdrawal per channel and purpose, with its source and wording, and checks it before every marketing send. How customer data is separated and encrypted is on our Security page.

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Common questions

What is the PDPL?

PDPL stands for Personal Data Protection Law, and the UAE and Saudi Arabia each have one. The UAE's is Federal Decree-Law 45 of 2021, and Saudi Arabia's is enforced by SDAIA.

Does the UAE PDPL apply to WhatsApp marketing?

Yes. Customer numbers and chats are personal data, so processing them needs consent unless an exception applies, and customers can object to direct marketing at any time.

Has the UAE PDPL executive regulation been issued?

Not as of 7 October 2026: it is not on the UAE legislation portal. Once issued, businesses get up to six months to comply.

What does the Saudi PDPL require for marketing messages?

Prior consent and a clear way to stop, under Article 25. The Implementing Regulation adds a clearly named sender and an opt-out as easy as the opt-in.

What are the fines under the Saudi PDPL?

A warning or a fine of up to SAR 5 million, doubled for a repeat violation. Unlawfully disclosing sensitive data can bring up to two years in prison, a fine of up to SAR 3 million, or both.

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