Certificates of good conduct already requested in some cases

IMPACT – MEDIUM

What is the change? Authorities in the United Arab Emirates have, in at least some cases, begun requesting certificates of good conducts (police clearance certificates) with visa applications.

What does the change mean? Authorities announced in January that the requirement would be put in place beginning Feb. 4. However, BAL is aware of at least one case of a certificate that was already requested for an in-country applicant applying for a new UAE residence visa through the Dubai Airport Free Zone Authority. While implementation dates may vary from free zone to free zone, and between the free zones and the mainland, the requirement will eventually apply across the UAE. The fact that DAFZA authorities have already requested a certificate is an indication that cases that have already been submitted, but not yet finalized, may be subject to the requirement for a certificate of good conduct.

• Implementation time frame: Ongoing.
• Visas/permits affected: Work and residence visas.
• Who is affected: First-time visa applicants, including those applying in country. It is not yet clear whether the change will also apply to visa renewal applicants.
• Impact on processing times: The change could add as much as six weeks to the visa application process, depending on how long it takes applicants to obtain a certificate of good conduct in their home country (or country of their residency for the last five years) and how long it takes to complete the required legalization processes.  
• Business impact: Businesses may need to adjust timelines and start dates if applications are delayed.

Background: Authorities announced the new requirement in January, saying it would be implemented as a security measure Feb. 4. Certificates of good conduct will be required from the applicant’s home country and any countries in which the applicant has resided in the past five years. The requirement will apply across the UAE, whether the company is in a free zone or the mainland. BAL has confirmed that the requirement will apply to new work and residence visa applications (whether in country or out of country) and work and residence visa transfers. It is not clear whether the requirement will apply to renewals of work and residence visas. BAL anticipates that the requirement will not apply to applications for dependent residence visas (new or renewal), non-sponsored ID cards or change of title. It is also unlikely to apply to tourist visas in general, but it may be required for certain nationalities.

BAL Analysis: Applicants should be prepared to provide the certificates of good conduct for all affected applications beginning Feb. 4 and may be asked to provide one even before then. Cases that have been submitted pending entry permit approval may be subject to the requirement as well. BAL continues to seek clarification on a few key points, including whether the requirement will apply to renewals. BAL will alert clients to any significant developments.

This alert has been provided by the BAL Global Practice group. For additional information, please contact your BAL attorney.

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