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Gas and Fuel Volatility: Setting Up Energy Analytics or Procurement Software in the UAE
The short answer
A UAE company that sells fuel forecasting software or data does not fit the Dubai definition of dealing in petroleum products. One that buys, sells, markets or supplies fuel for customers does. In Dubai, Executive Council Resolution No. (85) of 2025 requires that activity to hold a Supreme Council of Energy permit and a place on the Ministry of Energy and Infrastructure's register. The deciding fact is whether customers pay for information and workflow, or for delivered litres and negotiated prices.
Most founders in this space begin with a dashboard and drift into brokerage. The drift is usually commercial rather than deliberate: a fleet client asks the software team to "just place the order". Decide before launch whether that request is a product feature, a separate service, or something the company declines.
Software adds data and contract duties. Managed procurement adds a commercial function. Anything that buys or supplies fuel enters Dubai's permit regime, where Resolution 85 of 2025 fines an unpermitted diesel sale or purchase AED 25,000 and a gasoline one AED 50,000.
What the monthly pricing mechanism means for a forecasting product
UAE pump prices are not floating by the hour. A committee reviews them monthly (the UAE Government portal calls it the Gasoline and Diesel Prices Follow-up Committee, chaired by the Ministry of Energy and Infrastructure), and the announcement is reported by the Emirates News Agency (WAM). For September 2026 the Fuel Price Committee approved Super 98 at AED 3.80, Special 95 at AED 3.69, E-Plus 91 at AED 3.61 and diesel at AED 4.30 a litre. Petrol prices were adjusted by between 5.56 and 5.87 per cent. Since August 2015 the mechanism has linked prices to global petroleum product prices, and it also counts operating and distribution costs.
That structure shapes what an analytics product can honestly offer. Retail buyers of petrol and diesel face a known price for a month at a time, so the value of forecasting sits in two places: predicting next month's committee decision, and managing exposure on products and contracts that do not follow the pump price. Industrial gas, bulk diesel supplied under contract, bunker fuel and marine gas oil all sit outside the retail announcement. A founder who pitches "fuel price prediction" to a fleet manager should be able to say which price series the model is trained on and which the customer actually pays.
The UAE Government's description of the pricing mechanism names inputs, average global petroleum product prices plus operating and distribution costs, but no benchmark or index. A model built on a named benchmark is therefore the founder's own assumption. Say so in the product documentation. Customers who later dispute a forecast will look for exactly that sentence.
Where a software company ends and a fuel business begins
There are four commercial shapes, and each one asks something different of the company.
Dashboard and data subscription. The company licenses information and charges a fee. Its obligations are mostly contractual: data rights, accuracy disclaimers and service levels.
Procurement workflow software. The customer uses the tool to compare quotes, raise purchase orders and track deliveries from its own suppliers. The customer contracts with the supplier. The software company never takes title to fuel or handles the supplier's invoice money.
Managed procurement. The company's staff run tenders, negotiate with suppliers and recommend awards, often for a percentage of savings. Here the business is performing a commercial function, and the Ministry of Energy and Infrastructure's petroleum products trading service is the place to ask whether that function needs approval.
Trading. The company buys and resells, or arranges back-to-back contracts. This is a commodities business with credit, storage and delivery risk, and it belongs in a different conversation from software. The related guide on commodities and energy trading companies covers that side.
A single UAE company can sometimes carry the first two. Carrying the third and fourth alongside them tends to blur the answer when a bank, an insurer or a regulator asks what the company does. In Dubai a permit holder must keep to the activity its permit authorises, which is a practical reason to ask whether a software line can sit beside it. Many groups keep the software entity clean and put managed services or trading in a separate vehicle, accepting the cost of two sets of accounts and an intercompany agreement. Velarozone works on this by writing the perimeter position first: which of the four shapes the company is, and what each customer pays for. The licence route comes second.
Customer data, telemetry and the data protection law
Procurement software gets better when it sees real consumption: fleet telematics, depot meter reads, delivery notes. Some of that is plainly commercial. Some is personal, such as driver identity linked to fuel-card use or vehicle location by person.
Federal Decree-Law No. 45 of 2021 came into force on 2 January 2022. It applies to personal data processed fully or partly through electronic systems, inside or outside the UAE. It sets controls on processing, expects holders of personal data to secure it, generally requires the individual's agreement unless an exception applies, and sets requirements for cross-border transfers. Individuals can ask for inaccurate data to be corrected and for processing to be restricted or stopped. The UAE Data Office, affiliated with the Cabinet, acts as the federal data regulator. The UAE Government's summary gives no penalty figures, so do not quote any.
Three practical consequences follow for an analytics company:
- Contracts should say who is the controller and who is the processor of fleet and driver data, and whether the data leaves the UAE for a cloud region elsewhere.
- Benchmarking products that pool customers' consumption need a clear permission to use data in aggregate, written into the customer contract rather than the privacy notice alone.
- The UAE Government lists DIFC Data Protection Law No. 5 of 2020 separately from the federal law, so a customer or entity inside DIFC may sit under a different regime. Map which rules govern each customer's data before choosing the entity.
Claims, fees and the savings promise
Procurement vendors sell on savings. Savings against what is the whole argument. A customer's previous price, the committee's retail price and a competing quote are three different baselines, and a percentage-of-savings fee gives the vendor a reason to pick the flattering one.
Write the baseline into the contract. Agree who audits it. Avoid any wording that reads as a promise of a result, in sales decks as much as in the agreement. If the model recommends when to buy forward, state that it is an analytical tool and that the customer decides. Where a recommendation does amount to an instruction to transact, the managed procurement question above comes back.
Preparing the file for a bank or investor
A bank opening an account for a company that sells energy data wants to understand the money flows quickly. Prepare:
- A one-page description of who pays the company, for what, and in which currency.
- Copies of the data licences for any third-party market data the product redistributes, since rights to display or resell a price feed are often narrower than founders assume.
- The customer agreement, including the data processing terms and the savings baseline.
- A plain statement that the company does not take title to fuel, if that is true, and the supplier-side paperwork if it is not.
The same story should appear in the website, the deck and the bank application. Differences between them are what prompt follow-up questions. None of this makes an account certain.
When it is time to pick between an onshore and a zone licence, the comparison in free zone versus mainland applies, with one addition specific to this sector: where the fleet and industrial customers are based. Dubai's petroleum permit rules apply in free zones too, including DIFC, so a zone licence does not take fuel dealing outside them. A company serving onshore buyers from a zone licence should confirm how that contracting arrangement is permitted. Founders relocating to run the company should look at residence visas for the founding team alongside the licence decision.
In short
What to take from this
- A committee chaired by the Ministry of Energy and Infrastructure reviews UAE retail fuel prices monthly. For September 2026 it put Special 95 at AED 3.69 a litre and diesel at AED 4.30.
- A subscription dashboard, a procurement workflow tool and a managed buying service are three different businesses, even when one team builds all three.
- Customer fleet, meter and driver data can be personal data under Federal Decree-Law No. 45 of 2021, which applies to processing inside or outside the UAE.
- In Dubai, buying or supplying fuel for a customer, or taking a margin on it, counts as dealing in petroleum products. That needs a Supreme Council of Energy permit and an entry on the ministry's register.
- Savings claims in sales material need a method behind them before they appear in a contract.
- Do I need approval from the Ministry of Energy and Infrastructure to sell fuel analytics software?
- Selling information and software does not fit Dubai's definition of dealing in petroleum products, which covers buying, selling, marketing and supplying fuel. Arranging, negotiating or taking a margin on fuel purchases is closer to it. If you plan that, ask the Supreme Council of Energy in writing before you describe it to customers. The permit holder must also be on the ministry's register, which charges a one-time AED 500 fee.
- Can I use the Fuel Price Committee's monthly prices as a data feed?
- The monthly announcement is public and carried by WAM, so quoting it with attribution is straightforward. Building a commercial feed that redistributes it, or a third-party price series, is a separate question about the terms of each source. Keep a record of where every series in your product comes from.
- Does fleet data count as personal data?
- Often, yes. A vehicle tied to a named driver, or a fuel card assigned to a person, is personal data under Federal Decree-Law No. 45 of 2021. Anonymised depot-level volumes usually are not. Decide at design stage which your product ingests.
- Can one company run both a dashboard and a managed procurement service?
- It can in some cases, but a Dubai permit holder must keep to the activity its permit authorises, and the two lines carry different contracts and liability. Many founders separate them once the service line grows. Model the extra accounts, governance and intercompany paperwork before deciding.
Sources
Where this comes from
General information drawn from the CBUAE Rulebook, including the Retail Payment Services and Card Schemes Regulation (C 15/2021), and Cabinet Resolution No. (134) of 2025 as published, not legal or tax advice. Rules and guidance change, so confirm the current text and each institution's own requirements before you submit.
