If we go back to the very beginning, Oman criminalised cybercrimes for the first time in the year 2001 when a new chapter on computer crimes was added to the Penal Law of 1974. This chapter was titled “Computer Crimes” and generally covered technical offences relating to illegal access, interception, and interference with computer systems as well as misuse of payment cards. The legal concepts that this chapter governed were what an ordinary person on the street would consider to be a cybercrime, i.e. a crime of a technological nature that affects the accessibility or safety of the technology we use.

Ten years after the introduction of the computer crimes chapter to the Penal Law, Oman decided in 2011 to create a standalone Cybercrime Law. This law took the technical crimes that were originally introduced in 2001 and expanded them into four chapters on infringing data and systems, misuse of technology, digital forgery and fraud, and infringement of payment cards. In addition to these technical chapters, a chapter titled “Content Crimes” was added to the law that governed matters beyond technical crimes committed by hackers and cybercriminals. This chapter criminalised misconduct that was already mostly criminalised by the Penal Law and other Omani law (such as defamation, intellectual property infringement, and pornography) when this same act was committed using technological means. Generally speaking, a content crime under the Cybercrime Law carried a heavier punishment in comparison to the same act under the original law.

The extent to which the Cybercrime Law of 2011 had to re-criminalise offences that were already captured by the Penal Law is at best questionable. The Penal Law and other Omani laws have always been worded using expansive terminology that was not tied to a specific technology and which was already used to capture criminal conduct irrespective of the medium. Furthermore, if the objective was to provide legal certainty, the Cybercrime Law could have had a single provision to confirm the application of the Penal Law to crimes committed using technological means without having to repeat the crimes one by one.

As a result of the Cybercrime Law of 2011, we ended up with a legal framework where multiple laws criminalise the same exact conduct. For example, if you insult someone using a text message, that would be a crime under the Penal Law, the Cybercrime Law, and the Telecommunications Law; if you infringe copyright on the internet, that would be a crime under the Cybercrime Law and the Copyright and Neighbouring Rights Law; if you launder money on the internet, that would be a crime under the Cybercrime Law and the Law of Combating Money Laundering and Terrorism Financing, etc.

Having the same conduct be governed by multiple laws makes predicting the application of the law difficult, especially since the Cybercrime Law does not always copy the terminology found in the original law that governs the content in question. However, my biggest problem with overloading the Cybercrime Law with content crimes that are already governed by other laws is that this distracted us from focusing on what the law is actually intended to govern. While the Cybercrime Law of 2011 had five substantive chapters with four covering technical crimes and one covering this strange category of content crimes, if you look at the number of articles in each of these chapters, the chapter on content crimes on its own is bigger (14 articles) than the four other chapters combined (12 articles).

The new Cybercrime Law of 2026 that came out last month retained the same general structure of having technical crimes and content crimes, but the technical crimes are now covered by 14 substantive articles while the content crimes are now covered by 33 substantive articles. In other words, the content crimes have more than doubled in comparison to the previous law and now take up almost two thirds of the substantive provisions of the law.

It is clear that the Omani government sees the Cybercrime Law more as a law to control illegal content on the internet than a law for controlling the misuse of technology. The new law does not introduce any transformative changes to the regulation of technical crimes and pays only lip service to contemporary issues such as artificial intelligence. Instead of focusing on technological developments, the new law introduces a new lengthy section on crimes against the state—not in regard to cyberattacks made against state networks—but in regard to content published against the state, publishing news that harms state prestige, insults against heads of other states, etc. The law also doubles down on increasing the penalties for many existing content crimes.

The disparity between the punishments for technical crimes and the content crimes provides further evidence that the Cybercrime Law has lost its purpose. The Cybercrime Law should help protect us, as individuals and as a state, against cyberattacks, so you would assume that the biggest fines under this law would be designated for those technical crimes that the law is intended to control. Under the new law, if a cybercriminal wipes the data and disables the systems of a private hospital, he would be punished under article 5 of the law with a maximum punishment of a single year, but if an individual posts a tweet with misleading information during a pandemic he would be punished under article 30 of the law with a maximum punishment of 15 years, 15 times the punishment of an actual cyberattack. In fact, the highest fine for a technical crime under the new law is only 20,000 Rial Omani under article 18 (which bizarrely was actually reduced from 50,000 Rial Omani under the previous law), whereas the highest fine for a non-technical crime is 500,000 Rial Omani under article 55.

Content crimes should not go unpunished, but the Cybercrime Law is not the place for determining what ordinary people should be allowed to post on the internet. This matter is already governed by the Penal Law, the Telecommunications Law, and many other laws. The Cybercrime Law should focus on combating cyberattacks, digital fraud, and misuse of technology that affects the safety and integrity of our digital systems. The new Cybercrime Law of 2026 makes it clear that we have forgotten the purpose of this law.

The new Cybercrime Law has already entered into force. You can read it in full in English on the link below:

While Oman has had free zones (such as Sohar Free Zone) and special economic zones (such as the Special Economic Zone in Duqm) for decades, these free zones were primarily designated to facilitate trading in physical goods, and as such focused on providing customs and tax exemptions and remained subject to standard Omani laws such as the Labour Law, the Commercial Companies Law, and all other laws that govern the way a business operates in Oman. IFCO is similar to free zones in that it is a zone within certain boundaries that has its own legal framework, but unlike industrial free zones that facilitate trading in goods, as a financial free zone, IFCO is intended to facilitate trading in capital. This goal is achieved by creating a financial regulatory framework that meets the requirements of international financial regulatory bodies in a way that makes it attractive for international financial institutions to operate from within the zone. To enable IFCO to achieve the required standard for its financial regulatory framework, IFCO will operate independently from the rules of the Central Bank of Oman, the Financial Services Authority, and all other regulatory bodies in Oman. In fact, IFCO will not be subject to any Omani laws other than the Penal Law, the Law of Anti-money Laundering and Counter-terrorist Financing, and certain aspects of Omani tax laws.

Financial free zones are not a new concept in the GCC as the DIFC in Dubai, QFC in Qatar, and ADGM in Abu Dhabi operate under this same exact model.

According to last week’s royal decree, IFCO will report directly to the new Office of Deputy Prime Minister for Economic Affairs, i.e. Sayyid Theyazin. It will have a board of directors appointed by royal order, and will primarily operate under three sub-authorities, an executive authority to manage the centre and create the infrastructure, a regulatory body to set the regulatory framework, and a dispute resolution tribunal to oversee the court system of IFCO. The royal decree gave IFCO the power to create its own legal framework without being bound by Omani law. DIFC, QFC, and ADGM have chosen to operate under a common law legal framework that operates entirely in English. It is likely that IFCO will operate under a similar approach.

This means that if a company is registered in IFCO, this company will not be subject to the Omani company law or the Omani labour law, but instead by new IFCO laws inspired by common law legislation. If there is a dispute between this company and third parties, the dispute will not be resolved by Omani courts, but by IFCO courts that operate using a common law legal framework, most likely by judges and lawyers trained in common law jurisdictions. In DIFC, QFC, and ADGM, all the presidents of their courts are international jurists from common law jurisdictions rather than nationals.

Last week’s royal decree merely set the very high-level structure and legal framework for IFCO, and it will be up to IFCO to create its own rules for what companies will be able to register in the zone. However, the royal decree states that companies can be registered under two categories: companies providing financial services (that is the key target of the zone—such as banking services, insurance, investment management, etc) and companies providing ancillary services (these are companies that provide support to financial service providers—such as legal services, accounting services, etc). The royal decree provides a non-exhaustive list of financial services that are permitted, and it is up to IFCO to determine the actual activities and the requirements for registration.

For a company to register in IFCO, the company must have physical presence in IFCO. The law also states that registration in IFCO allows you to operate in IFCO itself, but if you wish to operate outside IFCO in Oman, you will be bound by Omani law. The most obvious example of this is that if you are licensed to provide financial services in IFCO, this doesn’t mean that you can open an outlet outside IFCO and provide services to the Omani public without FSA’s approval. There is a small exemption that allows IFCO companies to promote their services or provide advice regarding IFCO legislation outside the zone and on the Omani mainland.

While the key objective of IFCO is to attract international financial institutions to Oman, registering in IFCO can provide significant advantages for Omani and non-Omani businesses that do not wish to be bound by Omani law and fall within the categories of financial services providers or ancillary service providers. For example, if IFCO permits the creation of holding companies created to own shares in other companies, a common law legal framework similar to that of England and Wales is likely to grant a higher level of autonomy for the shareholders in a way that Omani law currently does not provide. The mainland Omani legal system is known to being open to disregarding the concept of separate legal personality of LLCs and holding shareholders liable for the conduct of companies they own shares in. Creating a holding company in IFCO that owns the local Omani subsidiary can be extremely advantageous to Omani shareholders, even if the subsidiary is still subject to Omani law.

In addition to the benefits of not being bound by Omani law, companies established in IFCO will enjoy an exemption from corporate tax until 2076, non-Omanis working in IFCO will not be subject to personal income tax, and the zone is declared a zero-rated special zone for VAT purposes.

The creation of IFCO is a major and unprecedented development for the Omani legal system as a whole, not only for the way financial business is conducted in the country.

The royal decree came out only a few days ago, and it will take IFCO months, if not years, to start its actual operations, as it needs to develop its entire legal framework in a manner that complies with the international requirements of regulatory bodies and provide physical office space for the companies wishing to register in IFCO.

The Law of the International Financial Centre of Oman has already entered into force. You can read it in full in English on the link below:

The amendment makes it clear that the Official Gazette is to be published electronically, and that the MJLA can, if it wishes, publish it in a paper format as well. The amendment also stipulates that the MJLA may published certain items from the Official Gazette before the full publication of the issue. These two practices are already adopted by the MJLA and these amendments merely add a legal basis for the practices of the ministry.

Another change that is not based on current practices is the removal of the mention of the Directorate General of the Official Gazette from the law and its replacement with a generic term for the “competent division”. This suggests that the MJLA might be in the process of a restructuring that would move the mandates relating to the Official Gazette into another administrative division within the ministry.

You can read the full text of the new amendments to the Law of the Official Gazette on the link below:

You can also read the consolidated version of the Law of the Official Gazette on this link:

Prior to this new decision, employees subject to the Labour Law were entitled to a 3% annual increment on their basic wage as long as the performance of the employee is not deemed “poor”.

Under the new decision, the percentage of the annual increment can range between 5% and 2% depending on the performance of the employee, and can be withheld completely if the performance of the employee is deemed “poor”.

This obligation is imposed in relation to Omani employees only. Employers found in violation of this decision are to be fined 50 Rial Omani for each employee against whom a violation is committed.

The decision also provides some grounds for suspending the implementation of the annual increment in general as we all rules for withholding the increment for individual employees.

This new decision enters into force tomorrow. You can read it in full in English on the link below:

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Subsea cables are fundamental to the operation of the global internet as they connect continents and allow data to be exchanged between them at high speeds. Oman plays a critical role in this industry due to its strategic location on the Indian Ocean, making it a potential hub for internet connection between South Asia, the Arabian Peninsula, and East Africa. Oman also has the only subsea cable connecting the GCC to Australia—a critical piece of digital infrastructure for the digital industry in both regions.

Prior to this new Regulation Governing International Telecommunications Cables issued by the TRA, Oman did not have a formal legal framework for governing the subsea cable industry. The new regulation stipulates that any company can apply for the approval of the TRA to install a subsea cable. If the application is approved, the applicant must pay a fee of 200,000 Rial Omani for a 15-year permit. In certain cases, the TRA may make an exemption for the payment of this fee if the subsea cable is connected to an international cable landing station or terrestrial connection station.

Subsea cable service providers are now also required to obtain approval to maintain, repair, and survey subsea cables in Omani waters. The fee for obtaining this approval is 500 Rial Omani. Holders of licences to provide international fixed public telecommunications are exempt from the payment of this fee.

In addition to outlining the process for obtaining approvals, the regulation also sets out obligations and prohibitions associated with the laying, maintenance, repair, and survey of subsea cable, as well as the penalties for violating the regulation.

The Regulation Governing International Telecommunications Cables has already entered into force. You can read it in full in English on the link below:

His Majesty issued by royal decree a new Advocacy and Legal Consultancy Law in October of last year, which repealed the Advocacy Law of 1996 and introduced a major reform of the legal profession in Oman. The new Advocacy and Legal Consultancy Law splits the legal profession into two separate activities: advocacy and legal consultancy, with advocacy essentially covering all the activities of the legal profession—such as giving legal advice, drafting contracts, and providing litigation services, while legal consultancy covers the same activities with the exception of litigation services. Both advocacy offices and legal consultancy offices are also permitted to do arbitration work.

The framework created by the new law requires advocacy work to be exclusively delivered by advocacy offices that can only hire Omani advocates, while legal consultancy work must be exclusively delivered by legal consultancy offices that can only hire Omani and non-Omani legal consultants and no advocates. This means that if a law firm wishes to provide litigation services, this law firm must be registered as an advocacy office, and it will not be able to hire any non-Omani lawyer. If a law firm wishes to hire any non-Omani lawyers, this law firm must be registered as a legal consultancy office, and it will not be able to provide litigation services. The law also introduced new provisions that permit international law firms to open a branch in Oman in the form of a legal consultancy office without having a local partner.

In addition to this new classification, the law creates new qualification and continuous development requirements for advocates that an advocate is required to meet to move up the rolls that enable the advocate to appear before higher court levels.

While the law had comprehensive details of how advocates are admitted and qualified, it did not provide details on how legal consultants would be admitted, and left this matter to the executive regulation of the law, which was published this past Sunday.

The Executive Regulation of the Adovcacy and Legal Consultancy Law stipulates that for an Omani lawyer to be registered as a legal consultant, this lawyer must have at least two years of legal work experience, and that for a non-Omani lawyer to be registered as a legal consultant, this lawyer must have at least five years of legal work experience. The term used for legal work experience in the context of legal consultancy work is not the same term used for advocacy equivalent works provided for in article 12, so it is not clear what kind of legal experience is required. However, what this appears to suggest is that legal consultancy offices would not be able to hire any Omani person as a legal consultant if this person does not have at least two years of experience, and it also means that foreign lawyers can work in Oman in private practice only if they have at least five years of experience and only in legal consultancy offices.

Unlike advocates, there are no examination or continuous development requirements for legal consultants.

In regard to international law firms, the executive regulation stipulates that they can operate in Oman on their own or in partnership with legal consultancy offices (but not advocacy offices). This is only permitted for law firms that have been established for more than 15 years and have branches in at least three countries.

Both the law and the regulation have many other key changes that will affect the licensing of lawyers and law firms, and the impact that this will have on the industry will be unpredictable. If a local Omani law firm currently hires non-foreign lawyers (including Egyptian, Sudanese, and Indian lawyers), this law firm would have to decide whether to let go of these lawyers—if it chooses to remain as an advocacy office—or transform into a legal consultancy office and give up on its litigation business. International law firms operating in partnerships with Omani law firms might also have to reconsider their partnerships as the law now prohibits establishing a partnership with an advocacy office, and instead allows them to either operate independently or in collaboration with a legal consultancy office.

Both the law and its executive regulation have already entered into force. However, existing law firms generally have until October of this year to comply with it, and law firms established in partnerships with a non-Omani have until October of 2027 to remove the non-Omani partner.

You can read the law and its executive regulation in English in full on the links below:

A strange thing about this new Law of Special Economic Zones is that it does not define the terms “Special Economic Zone” and “Free Zone”. However, the key differences between them appear to be that a special economic zone is a more comprehensive project that may or may not include a free zone within it; that a special economic zone is directly managed by OPAZ, while a free zone is required to have a third-party operator; and that special economic zones can include real estate development projects where property may be sold to Omani and non-Omani persons, while standard free zones can’t.

The provisions regarding real estate development projects in special economic zones are a new addition not previously found in the System of the Special Economic Zone in Duqm. Outside this key change, the law appears to mostly attempt to consolidate the provisions that were uniquely provided through the System of the Special Economic Zone at Duqm into general provisions that can apply to any special economic zone to be created in the future.

It is worth noting that the provisions of the law remain conservative and the status they grant special economic zones is not comparable to the status of special free zones in neighbouring countries such as DIFC, ADGM, or QFC, that operate in a manner independent of the national legal system of the state and have their own regulators, substantive laws, and court system. In Oman, special economic zones created under the new Law of Special Economic Zones and Free Zones remain basic free zones that offer time-limited tax reliefs along with streamlined processes for obtaining government approvals.

The new Law of Special Economic Zones and Free Zones entered into force yesterday. You can read it in full in English on the link below:

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