Everyone’s social media feed is filled with AI-generated videos of people saying or doing actions that they themselves never said, knew, or intended. These deepfake videos are very realistic that people can easily be deceived to think it is original. While it may seem entertaining, it also raises many legal consequences. Artificial Intelligence (AI) offers many benefits in our daily lives; however, if it is not used carefully, it can lead to multiple legal issues. Deepfakes are one of the most dangerous forms of AI misuse.
AI can be defined as machines or computer systems performing tasks that usually require human intelligence, such as learning, writing, decision-making, voice recognition, and image creation. Deepfakes are fake images or videos created using artificial intelligence in a way that it is convincing that it is original.
The risks created by deepfakes are that these created images or videos can be used identity theft, fraud and financial scams, defamation, blackmail and extortion, fake evidence in court, privacy violations, impersonation, reputational damage and spreading false information.
UAE Criminal Legal Framework
The UAE does not yet have a separate law specifically for deepfakes, but existing laws provide legal protection.
Defamation – When deepfakes result in defamation under Article 426 of Federal Decree-Law No. (31) of 2021 Promulgating the Crimes and Penalties Law, which deals with general insults or attacks on honour and dignity, the offender shall face imprisonment for up to one year or a fine of up to AED 20,000. Whereas, when it comes to deepfakes, digital defamation is mostly the means of defaming; therefore, Article 43 of Federal Decree-Law No. (34) of 2021 on Countering Rumours and Cybercrimes applies, which deals with insults and false accusations made online through the internet, apps, social media, or any digital platform. A fine of a minimum of AED 250,000 and a maximum of AED 500,000 will be imposed.
Fraud – When deepfakes are misused for fraud, Article 451 of Federal Decree-Law No. (31) of 2021 Promulgating the Crimes and Penalties Law would apply, where the law punishes with imprisonment or fines anyone who deceives another to obtain their money or property through any means. Whereas, when a digital medium is used to obtain someone’s property, benefits, or documents, the offender shall face imprisonment of at least one year and a fine ranging from a minimum of AED 250,000 to a maximum of AED 1,000,000 under Article 40 of Federal Decree-Law No. (34) of 2021 on Countering Rumours and Cybercrimes.
Privacy Violation – Article 44 of the Cybercrime Law punishes anyone who invades someone’s privacy online through recording, photographing, tracking, or publishing content without consent, including manipulating or processing images or videos to defame someone, which directly covers deepfakes. An imprisonment of a minimum of 6 months and a fine ranging from AED 150,000 to AED 500,000 is imposed for privacy invasion, and a minimum of one year imprisonment and a fine ranging from AED 250,000 to AED 500,000 is imposed for processing or manipulating content to defame.
Under UAE law, liability for deepfake-related offences does not stop at the individual creator. If an employee creates or distributes a deepfake for the benefit of their company, the responsible manager can face the same criminal penalties if they were aware of the act and failed to prevent it, while the company itself becomes jointly liable for all fines and compensation awarded to victims.
Victims may also separately claim damages for reputational harm, business loss, or financial losses caused by deepfakes under Federal Law No. (5) of 1985 concerning the issuance of the Civil Transactions Law of the United Arab Emirates.
Deepfakes and Intellectual Property –Deepfakes may also create copyright infringement, misuse of voice and likeness, and unauthorized use of protected content. Federal Decree-Law No. 38 of 2021 on Copyright and Neighbouring Rights would apply if the content used to create deepfakes infringes the copyright of the original author.
In conclusion, deepfakes are one of the most serious risks created by the misuse of artificial intelligence. While AI brings many advantages, its misuse can cause serious harm to individuals, businesses, and society through fraud, defamation, privacy violations, and copyright infringement. Even though the UAE does not yet have a separate law specifically for deepfakes, existing criminal, cybercrime, civil, and copyright laws provide strong legal protection and penalties against such misuse.
Our team at Ayesha Al Dhaheri Advocates and Legal Consultants provides dedicated legal support in matters involving deepfakes, online defamation, privacy violations, cyber fraud, and misuse of artificial intelligence under UAE law. We assist clients in handling criminal complaints involving fake videos, manipulated images, false online accusations, identity theft, impersonation, and unauthorized use of personal content, as well as civil claims arising from reputational damage, financial loss, and privacy breaches caused by deepfake technology. Our firm advises on both criminal and civil remedies, including defence against false allegations, compensation claims for damages, and legal representation before courts and authorities across the UAE.