General UAE Legal Questions LawCabinet Resolution No. (205) of 2025 Regarding the Regulations Ensuring Compensation for Damage Caused to Third Parties during the Conduct of Space Activities and Other Activities Related to the Space Sector (Third Party Liability)

Article (1) Definitions The definitions set out in Federal Decree by Law No. (46) of 2023 referred to above shall apply for the purposes of this Resolution. Without prejudice to the foregoing, the following terms and expressions shall have the meanings assigned to each of them, unless the context requires otherwise:

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Cabinet Resolution of 2025 Regarding the Regulations Ensuring Compensation for Damage Caused to Third Parties during the Conduct of Space Activities and Other Activities Related to the Space Sector (Third Party Liability) 2 Authorization Regulations : The regulations governing the Authorizations of Space Activities and Other Activities Related to the Space Sector, as in force at the Agency. Insurance Contract : A contract concluded between an insurance company (and, where applicable, an insurance broker), the Operator, and any other insured entities, under which the insurance company undertakes to pay Compensation to the Operator where Damage occurs thereto or is caused thereby to a contracting party or a third party, or to pay Compensation to the beneficiaries specified in the Insurance Contract, in consideration of the insured’s payment of insurance premiums to the insurance company or insurance broker, as applicable. Insured : The Operator, or, as the case may be, other entities covered by the Insurance Contract, including the owner of the Space Object, who is a party to the Insurance Contract and is obligated to pay the insurance premiums due to the insurance company in consideration for coverage of the risks specified therein. Compensation Guarantee Instrument : The document submitted to the Agency by an Authorization applicant or Authorized Operator evidencing its financial capacity, whether directly, through a guarantor, or by means of an insurance policy, to satisfy the liability compensation limit in respect of Damage caused to a third party arising from the conduct of, or participation in, a specific Space Activity or Other Activity Related to the Space Sector.

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Cabinet Resolution of 2025 Regarding the Regulations Ensuring Compensation for Damage Caused to Third Parties during the Conduct of Space Activities and Other Activities Related to the Space Sector (Third Party Liability) 3 Maximum Probable Loss (MPL) : The aggregate of potential material losses arising from an Accident or Incident caused by the Operator, resulting in loss of life, personal injury, health impairment, environmental losses, or property damage or loss.

Article (3) Compensation Guarantee Instrument 1. Prior to commencing any Space Activities, any Operator or Authorization applicant shall submit a Compensation Guarantee Instrument acceptable to the Agency, during the Authorization issuance process, in accordance with the provisions of the Authorization Regulations. 2. In assessing the Compensation Guarantee Instrument referred to in Clause (1) of this Article, the Agency shall take into account the nature of the Space Activity, the risks associated therewith, and the Maximum Probable Loss. 3. The Compensation Guarantee Instrument stipulated in Clauses (1) and (2) of this Article shall be submitted in accordance with the terms, conditions, rules, and requirements set forth in this Resolution. 4. The Agency may require an Operator or Authorization applicant wishing to conduct Other Activities Related to the Space Sector to submit an Insurance Contract, or such other guarantees as may be approved by the Agency.

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Cabinet Resolution of 2025 Regarding the Regulations Ensuring Compensation for Damage Caused to Third Parties during the Conduct of Space Activities and Other Activities Related to the Space Sector (Third Party Liability) 4

Article (4) Conditions for Accepting the Compensation Guarantee Instrument Proposal 1. A proposed Compensation Guarantee Instrument shall not be accepted unless the following conditions are met: a. The Authorization applicant or Operator shall declare that the information contained in the proposed Compensation Guarantee Instrument is accurate, correct, and up to date. b. The Compensation Guarantee Instrument shall remain valid throughout the duration of the authorized Space Activity. c. The Authorization applicant or Operator shall demonstrate the financial capacity, either directly, through a guarantor, or through an insurance company providing the required liability coverage, to meet the applicable liability Compensation limit as determined by the Agency. d. The Compensation Guarantee Instrument shall provide coverage for the Authorization applicant or the Operator, and other Insureds, in accordance with the Agency's requirements. e. The Compensation Guarantee Instrument shall be commensurate with the nature of the authorized activity and shall satisfy all relevant requirements of the Agency. 2. The Authorization applicant or the Operator shall submit the proposed Compensation Guarantee Instrument and all required information to the Agency within the timeframe determined by the Agency. 3. The Agency shall respond to the Operator within (14) fourteen working days from the date of receiving the Compensation Guarantee Instrument and any responses submitted by the Operator or Authorization applicant to the Agency’s queries. The Agency’s decision shall be either to accept the Compensation Guarantee Instrument and proceed with the Authorization procedures, or to reject the Instrument, stating the grounds for such rejection. 4. Failure by the Agency to respond within the period specified in Clause (3) of this Article shall be deemed a rejection of the proposed Compensation Guarantee Instrument.

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Cabinet Resolution of 2025 Regarding the Regulations Ensuring Compensation for Damage Caused to Third Parties during the Conduct of Space Activities and Other Activities Related to the Space Sector (Third Party Liability) 5

Article (5) Determination of the Liability Compensation Limit 1. The Agency shall determine the liability Compensation limit for an Authorization applicant or Operator on a case-by-case basis. This determination shall be made following an assessment of the Space Activities or Other Activities Related to the Space Sector and their associated risk levels, taking into account the Maximum Probable Loss and any other factors the Agency deems relevant. 2. The liability Compensation cap for Space Activities not classified as high-risk shall not exceed (AED 250,000,000) two hundred fifty million Dirhams. 3. Where the Agency deems the Space Activities to be high-risk, it may determine a liability Compensation cap that differs from the cap stipulated in Clause (2) of this Article. 4. When determining the liability Compensation cap for a Space Activity or Activities Related to the Space Sector, the Agency shall, during the Authorization procedures, consider all relevant factors, which may vary according to the characteristics of the Space Activities, including but not limited to: a. The type, size, and mass of the Space Object being Launched or undergoing Re-entry, including any payloads carried therein; b. The intended purpose of the activity; c. The type, characteristics, and operational record of the Launch Vehicle or Space Object Re-entry vehicle; d. The track record of the Operator and the Launch or Re-entry service provider; e. The planned trajectory/orbit and flight profile of the Space Object; f. The orbit of the Space Object, the radio frequencies used, and the extent of congestion thereof; g. The extent of compliance with the Space Debris Mitigation Guidelines issued by the Agency (as amended from time to time) and the Space Object disposal plan; h. Whether the Space Activities comprise a single mission involving multiple Space Objects, such as a satellite constellation; and i. Any other factors affecting the probability of Accidents or Incidents, including response capability and support for business management and continuity.

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Cabinet Resolution of 2025 Regarding the Regulations Ensuring Compensation for Damage Caused to Third Parties during the Conduct of Space Activities and Other Activities Related to the Space Sector (Third Party Liability) 6

Article (6) Liability for Compensation 1. The Operator shall be liable for compensating third parties for any Damage arising from Space Activities or Activities Related to the Space Sector conducted by the Operator, within the applicable liability Compensation cap. 2. If the Operator's liability for Damage arising from Space Activities or Activities Related to the Space Sector exceeds the applicable liability Compensation cap, the State; acting through the Agency or any other affected entity, shall have a right of direct recourse against the Operator to claim Compensation for the amount exceeding the liability Compensation cap. 3. In the event that any Operator conducts Space Activities without obtaining the required Authorization in accordance with the Decree by Law and the Authorization Regulations, the Operator shall be liable, without limitation, for any Damage caused to third parties by such activities.

Article (7) Required Information 1. The Agency may require an Authorization applicant or Operator to provide any information it deems necessary to assess the liability Compensation cap or to satisfy the requirements of the Compensation Guarantee Instrument. 2. The Agency may request further information after approving a proposed Compensation Guarantee Instrument if it deems the previously provided information insufficient to assess the liability Compensation cap or to satisfy the requirements of the Compensation Guarantee Instrument. 3. The Agency may reject a Compensation Guarantee Instrument, or likewise revoke an Authorization previously issued to an Operator in case of failure to provide the required information in a manner deemed appropriate by the Agency.

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Cabinet Resolution of 2025 Regarding the Regulations Ensuring Compensation for Damage Caused to Third Parties during the Conduct of Space Activities and Other Activities Related to the Space Sector (Third Party Liability) 7

Article (8) Exemptions 1. Any Authorization applicant or Operator may submit a request to the Agency for exempting certain activities from the requirements stipulated in this Resolution. Furthermore, the Agency may, on its own initiative, grant such exemptions where the activities fall within any of the following categories: a. The Space Activity contributes to the development of the Space Sector in the State. b. The activities are authorized but an appropriate Insurance Contract cannot be secured due to their novel nature, provided that the Authorization applicant or Operator demonstrates the financial capacity to satisfy the liability Compensation cap under this Resolution. c. The Agency considers that the imposition of liability obligations, having regard to the nature of the Space Activities and to the characteristics of the Operator, would constitute a burden on the implementation of such activities. d. The Space Activities are of a scientific or research nature and do not, in the Agency’s assessment, pose significant risks to any third party or the State. e. The Agency or any other Government Entity of the State elects to act as a guarantor for the purpose of bearing potential liabilities. 2. A temporary committee shall be formed by a decision of the Chairman of the Board of Directors to review requests for the full or partial exemption of activities referred to in Clause (1) of this Article and to render the necessary decision thereon. 3. In the event an exemption is requested pursuant to Clause (1) of this Article, the Authorization applicant or Operator shall provide all information and justifications as the Agency may require and in the form specified thereby.

Article (9) Other Compensation Guarantees 1. The Agency may, in coordination with the relevant Government Authorities in the State, require an Authorization applicant or Operator to provide a specific Compensation

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Cabinet Resolution of 2025 Regarding the Regulations Ensuring Compensation for Damage Caused to Third Parties during the Conduct of Space Activities and Other Activities Related to the Space Sector (Third Party Liability) 8 Guarantee Instrument relating to the use and transport of Space Nuclear Power Sources or any other highly hazardous materials associated with the activity. 2. The provision of a Compensation Guarantee Instrument pursuant to this Resolution shall not relieve an Authorization applicant or Operator from obtaining any other guarantees required under any other applicable legislation.

Article (10) Review and Audit of the Compensation Guarantee Instrument 1. Any Operator shall immediately notify the Agency of any changes to the Space Activities or Other Activities Related to the Space Sector, or to its legal or institutional status. This obligation shall include notifying the Agency of any amendments that materially affect the nature of its operations, or any significant investments that impact its ownership structure or the Space Objects subject to Authorization. Such notification is required to enable the Agency to assess the continued adequacy and suitability of the Compensation Guarantee Instrument approved pursuant to this Resolution. 2. The Agency may conduct the necessary audits of the Operator and request such relevant information as it deems appropriate in order to assess the adequacy and validity of the Compensation Guarantee Instrument.

Article (11) Compliance 1. Any Authorization applicant or Operator shall comply with the requirements of this Resolution, including providing the Agency with a Compensation Guarantee Instrument prior to the commencement of any Space Activities or Other Activities Related to the Space Sector. 2. Any Person conducting Space Activities or Other Activities Related to the Space Sector that may cause Damage to third parties shall cooperate with the Agency regarding the assessment of risks associated with such activities.

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Cabinet Resolution of 2025 Regarding the Regulations Ensuring Compensation for Damage Caused to Third Parties during the Conduct of Space Activities and Other Activities Related to the Space Sector (Third Party Liability) 9