UAE Law on Online Reviews: When Can Negative Feedback Lead to Defamation?

Negative online reviews have become an important part of consumer decision-making, with people routinely turning to social media and online platforms to share their experiences with restaurants, retailers, service providers and other businesses.

In the UAE, consumers are generally able to express their views about products and services. However, the right to criticise does not extend to statements that unlawfully damage another person's reputation, dignity or honour.

The legal distinction largely depends on what is being said, whether it is based on a genuine experience, and whether the criticism remains focused on the product or service rather than becoming a personal attack.

For example, saying that a restaurant provided slow service, that a meal was disappointing or that a product was too expensive would generally amount to an expression of a consumer's experience or opinion.

The situation can be very different when a reviewer accuses a business owner of fraud, dishonesty or criminal conduct without evidence.

What Makes a Review Potentially Defamatory?

A negative review is not automatically unlawful simply because it is critical or damaging to a business's reputation.

The content and context of the publication are important. A genuine review should generally be based on the consumer's actual experience and should distinguish between personal opinion and statements presented as fact.

Potential legal problems may arise when online content:

The distinction becomes particularly significant on social media, where a single post, video or comment can quickly reach thousands of people.

Recent UAE Case Highlights the Risks

A recent case involving a social media influencer illustrates how criticism can potentially move beyond legitimate consumer feedback.

Earlier this month, the Abu Dhabi Judicial Department reported a case in which an influencer was penalised Dh81,000 after a video about a well-known restaurant was found to constitute defamation rather than legitimate criticism.

The court imposed a Dh30,000 criminal fine, ordered the removal of the video and confiscated the mobile phone used to record and publish the content.

The defendant was also ordered to pay Dh51,000 in temporary civil compensation.

The case demonstrates that the consequences of allegedly defamatory online content can extend beyond a criminal penalty and may include separate civil claims for compensation.

Criminal and Civil Liability

Depending on the circumstances and the applicable law, defamatory or insulting content can result in both criminal and civil proceedings.

A criminal fine is imposed as a punishment for an offence and is payable to the State. Civil compensation has a different purpose: it seeks to address the harm suffered by the person or entity affected by the publication.

Other consequences may also arise depending on the nature of the offence. These can include imprisonment, confiscation of devices used to publish offending material and, in certain cases involving expatriates, deportation.

UAE cybercrime legislation also contains provisions dealing with online defamation and insults. Publishing allegedly defamatory material through digital platforms can therefore carry significant legal risks, particularly when the content is widely circulated.

Social Media can Increase the Risk

The speed and reach of social media make online reviews particularly sensitive.

A comment that might otherwise have remained a private complaint can become widely accessible once it is posted publicly. Videos, reels and other forms of social media content can also combine spoken allegations, images and captions, potentially increasing the impact of the publication.

Consumers are not required to give positive reviews. A person can explain that a service was poor, a product did not meet expectations or a particular experience was unsatisfactory.

However, greater caution is required when expressing allegations about the people behind a business.

Calling a business a "scam", for example, or accusing its owner of fraud or deliberate dishonesty without supporting evidence can create potential legal exposure.

What Should Consumers and Influencers Do?

A simple way to reduce legal risks is to keep criticism focused on the actual consumer experience.

Before publishing a negative review, consumers and influencers should consider whether:

Keeping supporting material such as receipts, booking confirmations, correspondence, photographs or videos can also help establish the factual basis of a genuine complaint where appropriate.

Freedom to Criticise Does Not Mean Freedom to Defame

Freedom of expression allows consumers to share their experiences, but it is not unlimited.

The law also seeks to protect individuals and businesses from unlawful attacks on their reputation, dignity and honour. As a result, the fact that a review is based on a genuine dissatisfaction does not necessarily protect every statement made in the course of that review.

The safest approach is to focus on what happened rather than who is to blame, distinguish opinion from fact, and avoid allegations that cannot be supported.

In practical terms, consumers can say that they received poor service or were dissatisfied with a product. The legal risk increases when the review moves from describing the experience to making unsupported accusations about a person's character, integrity or alleged criminal conduct.

For influencers and other users with large online audiences, exercising particular care is important because the wider the publication, the greater the potential impact of the statement.

A negative review can therefore remain a legitimate form of consumer feedback — but once criticism becomes a personal attack or an unsupported allegation capable of damaging someone's reputation, it may cross into legally actionable territory.