UAE insurers must cover organ transplants and complications for life
Organ transplant complications, including immune rejection, can emerge years after surgery
In a landmark development set to reshape the healthcare and insurance sectors in the United Arab Emirates, the Central Bank of the UAE (CBUAE) has issued a binding circular to all health insurance companies operating in the country, requiring them to include healthcare services related to the removal and transplantation of human organs and tissues in their health insurance policies and relevant endorsements.
The requirement extends to comprehensive medical care for both donors and recipients before, during and after the procedure, including the treatment of long-term complications, with no time limit on coverage.
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The requirement covers healthcare services provided to both donors and recipients before, during and after transplantation.
In its circular addressed to all insurance companies operating in the UAE, the Central Bank clarified that the requirement covers healthcare services provided to both donors and recipients before, during and after the procedure, including the treatment of any resulting complications, regardless of when such complications emerge or are diagnosed.
The circular further stipulates that insurance companies must bear the costs of these services under all health insurance schemes in force across the UAE. Coverage also includes the costs of removing an organ or tissue from a donor, whether living or deceased, as well as post-donation and post-transplant follow-up care and the treatment of any complications arising from either procedure.
Legislative and regulatory framework
The Central Bank’s circular is not an isolated regulatory measure. Rather, it represents the financial and operational implementation of a comprehensive and interconnected legislative framework developed by the UAE:
• Federal Decree-Law No. 25 of 2023: Established the legal framework governing the donation and transplantation of human organs and tissues, while criminalising organ trafficking. Subsequent amendments introduced in 2025 extended the regulatory framework to cover non-human organs and organs manufactured using three-dimensional bioprinting technologies.
• Cabinet Resolution No. 61 of 2026: Issued the Executive Regulations of the law, which were published in the Official Gazette on 30 April 2026. Article 14 granted the insurance sector a six-month transitional period to bring its operations into compliance, with the mandatory insurance coverage stipulated under Article 9 becoming fully effective on 31 October 2026.
• Central Bank circular: Translates this legislative requirement into a direct regulatory obligation for insurance companies, applicable across all health insurance schemes operating in the UAE.
Scope of insurance coverage: Dual and long-term protection
The significance of this decision lies in its ability to address some of the most pressing financial and medical challenges previously faced by parties involved in organ transplantation. It does so through three key pillars:
Beneficiaries: Coverage extends to both organ recipients and donors, whether the donation involves a living or deceased donor.
Stages of treatment: Coverage includes medical examinations and preparations before surgery, the costs of organ removal and transplantation during the procedure, and post-discharge medical care and regular follow-up.
Complications: Insurance companies are required to cover the treatment of any complications resulting from organ removal or transplantation, regardless of when they emerge or are diagnosed, including complications that may arise several years after the procedure.
Why removing the time limit matters?
In organ transplantation, immune rejection and other secondary complications may emerge several years after surgery. Requiring insurance companies to cover such complications without any time restriction removes the burden of potentially substantial future medical expenses from patients and their families, while ensuring continuity of treatment and long-term medical care.
