Trademark protection plays a vital role in safeguarding brand identity, promoting fair competition, and preventing consumer confusion. While the GCC countries (Gulf Cooperation Council)—including Saudi Arabia, UAE, Bahrain, and Qatar—share common goals for intellectual property (IP) development and have even adopted the GCC Trademark Law framework, each jurisdiction maintains distinct local procedures and nuances. This article provides a comprehensive comparison of trademark registration in Saudi Arabia versus the UAE, Bahrain, and Qatar, highlighting the key differences across legal frameworks, registration processes, enforcement mechanisms, and practical considerations.
Legal Framework
Saudi Arabia
Saudi Arabia has adopted the GCC Trademark Law by Royal Decree No. M/51 of 1435H, which came into effect in 2016. However, its implementation is subject to local executive regulations issued by the Saudi Authority for Intellectual Property (SAIP), which means it operates with distinct procedural rules.
UAE
The UAE initially followed its own Federal Law No. 37 of 1992 on trademarks. In 2021, it aligned more closely with the GCC Trademark Law through Federal Decree-Law No. 36 of 2021, while also incorporating TRIPS and Madrid Protocol obligations.
Bahrain
Bahrain was the first GCC country to adopt and implement the GCC Trademark Law in 2016, and it closely adheres to its structure. Bahrain also acceded to the Madrid Protocol in 2021, allowing international filings.
Qatar
Qatar applies Law No. 9 of 2002 on trademarks and has not yet fully implemented the GCC Trademark Law, although partial alignment is evident.
This blog is a part of our The Ultimate Guide to Intellectual Property Law blogpost.
Governing Authority
| Country | Trademark Authority |
|---|---|
| Saudi Arabia | Saudi Authority for Intellectual Property (SAIP) |
| UAE | Ministry of Economy – Trademark Section |
| Bahrain | Directorate of Industrial Property (MoIC) |
| Qatar | Ministry of Commerce and Industry |
Filing Procedure and Timelines
Saudi Arabia
- Mode: Online via SAIP portal
- Timeline:
- Examination: 90 days
- Publication: 60 days for opposition
- Registration: ~180 days if uncontested
- Language: Arabic (with English translation if needed)
UAE
- Mode: Online via Ministry of Economy portal
- Timeline:
- Examination: 30–60 days
- Publication: 30 days for opposition
- Registration: ~120 days if uncontested
- Language: Arabic (mandatory)
Bahrain
- Mode: Manual or online
- Timeline:
- Examination: 90–120 days
- Publication: 60 days
- Registration: ~180 days
- Language: Arabic (with optional English support)
Qatar
- Mode: Manual (as of 2024, limited online support)
- Timeline:
- Examination: 6–8 months
- Publication: 2 months
- Registration: ~9–12 months total
- Language: Arabic
Classification and Coverage
All four countries follow the Nice Classification System (45 classes). However, local restrictions apply:
- Saudi Arabia: Does not allow alcoholic beverages under Class 33 or related goods/services promoting such products.
- UAE: Similar restrictions on alcohol and pork-related products due to religious and cultural norms.
- Bahrain: Allows broader interpretation but still prohibits alcohol-related marks.
- Qatar: Prohibits religiously sensitive or morally objectionable terms. Alcohol and gambling marks are rejected.
Opposition and Enforcement
Saudi Arabia
- Opposition Period: 60 days post-publication
- Venue: SAIP and judicial courts
- Enforcement: Strong administrative enforcement via Anti-Commercial Fraud Dept.
UAE
- Opposition Period: 30 days
- Venue: Ministry of Economy, then Civil Court
- Enforcement: Active enforcement including border control measures
Bahrain
- Opposition Period: 60 days
- Venue: MoIC, then High Civil Court
- Enforcement: Moderate – relies on formal court proceedings
Qatar
- Opposition Period: 60 days
- Venue: Ministry, then Civil Court
- Enforcement: Developing enforcement infrastructure
International Treaties
| Treaty | Saudi Arabia | UAE | Bahrain | Qatar |
|---|---|---|---|---|
| Paris Convention | Yes | Yes | Yes | Yes |
| TRIPS Agreement | Yes | Yes | Yes | Yes |
| Madrid Protocol | No | Yes (2021) | Yes (2021) | Yes |
| WIPO Member | Yes | Yes | Yes | Yes |
Saudi Arabia is not a signatory to the Madrid Protocol, meaning international applicants must file nationally. In contrast, the UAE and Bahrain offer Madrid filings, simplifying trademark protection across multiple countries through a single application.
Renewal and Validity
- Validity: 10 years from date of filing (all countries)
- Renewal: Allowed within 6 months prior to expiry, with grace period for late renewal (usually 6 months with late fees)
Unique Considerations
Saudi Arabia
- Recently modernized IP laws with digital filing via SAIP
- Emphasis on Islamic values and moral compliance
- No Madrid Protocol option—national route mandatory
UAE
- Most business-friendly IP system in the GCC
- Fast-track examination and registration
- Madrid Protocol accession facilitates international brands
Bahrain
- Closely adheres to GCC Trademark Law
- Flexible with foreign ownership and IP holding companies
- Madrid Protocol advantages for multinationals
Qatar
- Slower and more manual procedures
- Conservative examination approach
- Increasing IP awareness and upcoming digital reforms
Aligning Trademark Strategy with GCC Country-Specific Laws
While the GCC countries operate under the umbrella of the GCC Trademark Law, the implementation, enforcement, and procedural frameworks remain unique to each jurisdiction.
Saudi Arabia stands out for its distinct, localized approach—requiring national trademark filings, maintaining strict religious and moral content restrictions, and operating outside the Madrid Protocol. Despite these constraints, it remains a crucial market for brand owners due to its size and economic influence, demanding tailored trademark strategies and local legal insight.
On the other hand, the UAE and Bahrain represent the more progressive edge of trademark administration in the GCC. With streamlined digital systems, adoption of the Madrid Protocol, and a business-friendly regulatory climate, they offer global companies’ easier access to brand protection and enforcement tools.
Qatar, while making strides in aligning with regional IP norms, still relies heavily on manual processes and does not yet support Madrid filings—indicating that while opportunities are growing, procedural complexity remains.
