The UAE has opened a one-month consultation on proposed conditions and regulations for the transplantation and implantation of non-human organs and tissues into the human body.
The consultation follows amendments issued by the UAE Government on December 10, 2025, which expanded the law on organ and tissue donation and transplantation to include non-human organs and tissues. The changes defined a non-human organ to include animal and manufactured organs, and set the basis for detailed controls governing their use.
The consultation, posted through the UAE Legislation platform’s Community Engagement Unit, seeks feedback from relevant stakeholders on how the country should regulate this emerging field.
According to the consultation document, the transplantation of non-human organs and tissues represents a significant advancement in organ and tissue transplantation, as previous legislation was limited to human organs and tissues only. It says developing the resolution requires engagement with relevant stakeholders to ensure that their views are considered and studied from a technical perspective.
Participants have been asked to share their views using a provided template during the one-month consultation period.
What stakeholders are being asked
The feedback form seeks views on:
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The importance of having a clear legislative framework governing the transplantation and transfer of non-human organs and tissues
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The benefits of regulating the conditions and controls for transplanting such organs and tissues into the human body
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The controls and standards needed to ensure the safe use of non-human organs or tissues
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Measures that could support the successful implementation of the rules within the UAE healthcare system
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Key risks and considerations linked to the transplantation of non-human organs and tissues
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Additional suggestions to help develop the regulation in a way that ensures safety, governance and compliance with medical and ethical standards
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The main anticipated challenges or obstacles in implementing provisions related to the transplantation and transfer of non-human organs and tissues into the human body
Safeguards under amended law
The December 2025 amendments were part of the UAE’s efforts to advance its health legislative framework, enhance patient safety and modernise healthcare legislation in line with the latest international medical and technical practices.
The amended decree-law allows non-human organs and tissues to be transplanted only under clearly defined conditions, including where transplantation represents the most appropriate medical option for the patient’s condition.
It prohibits the removal of any animal organ for transplantation without a licence from the Ministry of Health and Prevention or the relevant health authorities, and requires health facilities and manufacturing entities to obtain the necessary permits.
The amendments also require clinical and laboratory testing to confirm the safety and effectiveness of the organ or tissue. Specialist physicians must ensure biological compatibility, inform the patient or their legal representative of all potential and confirmed health implications, and obtain written consent.
The amended law introduces penalties for violations involving the transfer or transplantation of non-human organs, their components or non-human tissues. Health facilities, manufacturing entities or specialist physicians found in breach of the controls may face imprisonment and a fine of not less than Dh100,000 and not more than Dh2 million, or either penalty.
Internationally, the World Health Organization says research into alternatives such as animal products, or xenotransplantation, and bioengineered materials is progressing, but notes that these are not yet a full replacement for human donation.
A WHO Executive Board report dated December 2025 said the WHO Secretariat hosted a consultation in September 2025 on the regulatory aspects of xenotransplantation. The report noted that advances in gene editing and other technologies have enabled the start of clinical trials in which animal organs are transplanted into deceased or living human subjects, highlighting the need for strong regulatory oversight in this field.
