Medical Coding in the UAE: Code Sets and Rules for Clinics
Short answer: Medical coding in the UAE turns what your doctor writes into the standard codes that insurers pay on. Dubai (DHA, through eClaimLink) and Abu Dhabi (DOH, through Shafafiya) both require ICD-10-CM for diagnoses, CPT for procedures and HCPCS Level II for supplies, all at the 2021 version. Drugs use local lists, and dental is the big difference: Dubai uses the American CDT codes, while Abu Dhabi still mandates the Canadian (CDA) 2011 codes. Dubai planned to move to the 2024 code sets on 1 April 2026, but DHA deferred that until further notice.
Last verified: 29 October 2026 against the DOH Coding Manual v2.0, the DHA and DHIC general circulars on isahd.ae, the Dubai Claims Management Policy (PD-05-2025) and the eClaimLink code lists.
Key Takeaways
- Dubai claims use the 2021 ICD-10-CM, CPT and HCPCS code sets for encounters from 1 July 2023 (GC 04-2023). The 2024 update is on hold (GC 02-2026).
- Abu Dhabi’s Coding Manual lists the 2021 code sets as effective 1 January 2024, and the manual itself (version 2.0) took effect on 1 January 2025.
- Abu Dhabi sets coder qualifications: AHIMA or AAPC membership, or a degree or higher diploma in Health Information Management or Medical Records. Dubai publishes a training duty instead.
- In Abu Dhabi, a facility must pass JAWDA Data Certification and be listed as a Coding Certified Facility to bill E/M codes.
- In both emirates the code must match the medical record. Unbundling and upcoding are prohibited in Dubai and lead to audit, recovery and enforcement.
Which Code Sets Each Regulator Requires
| What Is Coded | Dubai (DHA, eClaimLink) | Abu Dhabi (DOH, Shafafiya) |
|---|---|---|
| Diagnoses | ICD-10-CM 2021 | ICD-10-CM 2021 |
| Procedures and Services | CPT 2021, plus Dubai Service List (DSL) codes for some local services | CPT 2021 |
| Supplies and Consumables | HCPCS Level II 2021 | HCPCS 2021 |
| Drugs | Dubai Drug Code (DDC) | DOH Drug codes (Mandatory Tariff version) |
| Dental Procedures | CDT (American Dental Association) | Canadian Dental Association (CDA) codes, 2011 version |
| Inpatient Grouping | IR-DRG (inpatient and day case claims) | IR-DRG v3.3 from 15 September 2023 |
Two local points of medical coding in the UAE catch new billing teams out. First, drugs are not coded with CPT product codes. The DOH Coding Manual says vaccine and immune globulin CPT product codes “are not assigned in the Emirate of Abu Dhabi”, and the drug is reported with its DOH Drug code next to the CPT administration code. Dubai works the same way with the DDC, which is updated often (the eClaimLink DDC list was refreshed on 26 October 2026). Second, Dubai has its own Dubai Service List for special cases without a suitable CPT code. For example, DHA added DSL codes 41 to 45 for teleconsultation from 5 April 2020 (GC 09-2020).
Clinics also cannot bill with their own internal codes. DHA’s GC 09-2015 made providers responsible for a CPT or CDT coded price list, and allows bundles and packages only when each item inside them is CPT coded.
Which Version Is in Force and From When
Dubai. DHA moved eClaimLink claims to the 2021 code sets for encounters from 1 July 2023 (GC 04-2023). Resubmissions for encounters before that date kept the 2018 codes, so the version follows the date of service. In December 2025, GC 06-2025 announced the 2024 ICD-10-CM, CPT and HCPCS Level II sets and DRG grouper version 3.5 for 1 April 2026. On 17 March 2026, GC 02-2026 deferred all of it “until further notice” and told the market to keep using the code sets currently in place until a new circular sets a date. When we checked the ISAHD circular list on 29 October 2026, no new date had been published.
Abu Dhabi. The DOH Coding Manual’s code set table shows ICD-10-CM, CPT and HCPCS 2018 from 1 July 2021, then 2021 from 1 January 2024. Dental stays on the CDA 2011 version. The Shafafiya notices page shows no newer code set notice.
One licence point is easy to miss. GC 06-2025 says the code files on eClaimLink are limited to health insurance claims processing and may not be used inside your own hospital information system or for clinical documentation. Check with your software vendor how your codes are licensed.
Who Can Code: Coder and Facility Certification
Abu Dhabi. The DOH Coding Manual lists “Mandatory Certifications for Medical Coders”. A coder needs one of these:
- membership of a professional body that certifies in the code sets used in Abu Dhabi, with AHIMA and AAPC named
- a Bachelor of Science in Health Information Management or Medical Records
- a Higher Diploma in Health Information Management or Medical Records
DOH also asks for proof of at least two years of coding experience (coding, not billing) and evidence of continuing education. The facility needs certification too. JAWDA Data Certification, which DOH (then HAAD) assigned to TASNEEF-RINA Business Assurance in 2016, reviews claims, the clinical coding process and JAWDA quality KPIs. The DOH coding audit gives a facility accuracy and completeness scores from 0 to 100, and passing certification is what gives a facility the right to bill E/M codes.
Dubai. We found no published certification or licence rule for coders in the DHA and DHIC documents we reviewed. The Claims Management Policy (effective 16 November 2025) does require providers to make sure “all treating physicians and billing personnel are trained and regularly updated on DHA coding rules, DRG protocols, and claim submission standards.”
Documentation: The Rule Behind Every Code
A code is only as good as the note behind it, and most problems with medical coding in the UAE start in the notes. Dubai’s Claims Management Policy says coding “must accurately reflect the actual services rendered, based strictly on the documented diagnosis, procedures performed, and consumables used”, and that the record must clearly reflect “the diagnosis, treatment provided, and medical necessity.” Non-compliance can mean claim rejections, recovery audits or regulatory penalties.
The DOH Coding Manual gives practical rules that work in any emirate:
- Review the record for the whole visit before you finalise the codes.
- Use lab, radiology and pathology reports for detail, but do not code a condition the doctor has not documented without asking the doctor first. A positive blood culture does not let you assume sepsis.
- Code neoplasms from the pathology report.
- When the notes are unclear or conflict, query the attending doctor before you code. DOH says this helps decrease denials.
- Run internal coding audits every month, and give every new coder induction and training.
Coding also connects to approvals. In Dubai a provider may not claim for treatment outside the scope of authorisation the payer granted, so the services you claim must fall within what the payer approved. Our guide to prior authorization in the UAE covers the approval rules.
Common Coding Mistakes That Lead to Rejections
| Mistake | What the Rules Say |
|---|---|
| Unbundling: billing several codes for one inclusive procedure | Prohibited in Dubai; DOH defines it as billing more CPT or HCPCS codes than necessary |
| Upcoding: billing a more complex service than was done | Prohibited in Dubai, subject to audit, claim recovery and enforcement |
| Coding from reports without the doctor’s diagnosis | DOH: consult the doctor before coding it |
| Using the wrong version for the date of service | Dubai: older encounters kept the code set in force on that date |
| CPT product codes for drugs or vaccines | Use the DDC (Dubai) or DOH Drug codes (Abu Dhabi) |
| American CDT codes on Abu Dhabi dental claims | Abu Dhabi mandates CDA 2011 dental codes |
| Services outside the approved authorisation | Dubai: not claimable |
When a claim comes back, Dubai allows resubmission within 21 calendar days of the payment or remittance advice and at most two resubmissions per claim. Dubai’s Claims Management Policy also links breaches to the fines in Executive Council Resolution No. 7 of 2016. For example, a provider that does not follow DHA’s procedures on health insurance claims faces AED 50,000 per claim. Neither regulator sets a separate fine just for a coding error. The eClaimLink and DHPO guide and the Shafafiya guide explain how claims and remittances move through each platform.
Frequently Asked Questions.
Does the UAE use ICD-10 or ICD-11?
For medical coding in the UAE on insurance claims, both Dubai and Abu Dhabi require ICD-10-CM, currently the 2021 version. We found no DHA or DOH circular that moves claims to ICD-11.
Is Dubai using the 2024 code sets?
Not yet. DHA planned the 2024 ICD-10-CM, CPT and HCPCS sets for 1 April 2026, then deferred them on 17 March 2026 until further notice. Keep using the current sets until DHA issues a new date.
Do medical coders need a licence in the UAE?
Abu Dhabi requires coders to hold AHIMA or AAPC membership, or a degree or higher diploma in Health Information Management or Medical Records. We found no published coder certification rule in Dubai, but providers must train billing staff on DHA coding rules.
Which dental codes are used in Abu Dhabi and Dubai?
Abu Dhabi mandates the Canadian Dental Association codes, 2011 version. Dubai uses the American Dental Association’s CDT codes through eClaimLink.
What is JAWDA Data Certification?
It is the DOH coding and data audit for Abu Dhabi providers that work with insurers. It reviews claims, the clinical coding process and JAWDA quality KPIs, and facilities must pass it to bill E/M codes.
Where This Comes From.
- DOH: Coding Manual for the Emirate of Abu Dhabi, v2.0 (effective 1 January 2025)
- DOH: JAWDA Certification for Healthcare Providers notice (December 2016)
- DOH: Shafafiya Standards
- DOH: Shafafiya Notices
- DHIC: Law and Regulations (general circulars index)
- DHA GC 04-2023: 2021 Code Sets from 1 July 2023
- DHA GC 06-2025: Update of Code Sets, DRG Parameters and Grouper Version
- DHA GC 02-2026: Deferral of the 2024 Code Sets
- DHA GC 09-2015: Coding Standards
- DHA GC 09-2020: Teleconsultation DSL Codes
- DHIC PD-05-2025: Dubai Health Insurance Claims Management Policy (4.2.3, 4.5, 4.7.3, 5.2 to 5.3; archived copy)
- eClaimLink: Dubai Code Sets
How OzaniX Partners Can Help.
Our Insurance and Revenue Cycle Management team sets up medical coding in the UAE for new clinics and repairs it for clinics already losing claims. We can check that your billing system has the right code set versions loaded, review a sample of coded claims against the notes, show your doctors what the codes need from the record, and work through your rejections with you. Talk to us if your rejection rate is climbing.
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