By: Mohamed Fouad – Managing Associate
Omar Qouteshat – Senior Associate
Law No. 3 of 2025 concerning the regulation of travel and air cargo offices (“Air Travel and Cargo Law”) was issued and entered into force on 10 April 2025.
Before the issuance of the Air Travel and Cargo Law, air travel offices were regulated under Law No. 26 of 2006, while air cargo offices were regulated under Law No. 6 of 2010. To facilitate better coordination, Qatar decided to regulate travel and air cargo offices under a single piece of legislation due to the interconnected nature of their activities and because both fall under the same regulatory authority.
This article highlights the key new legal provisions related to the regulation of travel and air cargo offices, which existing offices must comply with within six months from the date the Air Travel and Cargo Law came into effect.
One of the most notable provisions in the Air Travel and Cargo Law is the removal of the requirement that an applicant for a license be Qatari, as was required under the previous laws. However, the Air Travel and Cargo Law goes even further: it eliminates licensing for individuals entirely and restricts license applications solely to companies.
The Air Travel and Cargo Law does not specify the amount of insurance required for licensing, but instead obliges the applicant to provide an unconditional bank guarantee in favour of the Qatar Civil Aviation Authority (“Authority”). The amount, method of payment, rules for refund, and cases of deduction will be determined by a decision issued by the President of the Authority.
Under these new provisions, the Air Travel and Cargo Law allows the applicant to be a Qatari company wholly owned by non-Qataris, opening the door to greater foreign investment in the travel and air cargo office sector. The previous laws required that 51% of the capital of a company applying for a license be owned by Qatari citizens or citizens of GCC member states.
Another key feature of the Air Travel and Cargo Law is its regulation of companies operating global distribution systems (“GDS”). It stipulates that a company applying for such a license must have no less than five years of experience in the GDS sector. The law explicitly states that GDS companies may not engage in providing travel offices with reservation, ticket sales, or travel ticket issuance services—or any other airline-related services—without obtaining a specific license to do so.
In line with the new regulatory framework, the Air Travel and Cargo Law imposes several obligations on licensed companies, including the requirement to appoint a minimum number of employees who possess expertise in the field. However, the law does not specify the exact number of employees required.
Furthermore, hazardous materials transportation has been added to the list of activities that air cargo offices may engage in—an area that was not clearly regulated under the previous law. The Air Travel and Cargo Law requires air cargo companies that wish to handle hazardous materials to qualify at least two employees through IATA-approved international training programs and ensure that their warehouses meet international and domestic regulatory standards. A decision from the President of the Authority will determine the required number of employees for air cargo offices dealing in hazardous materials.
In addition to the above obligations, the Air Travel and Cargo Law requires air travel offices to comply with international systems for booking, selling, and issuing travel tickets and related services and to refrain from making fake bookings or violating ticket price rules. Similarly, air cargo offices must comply with international systems for issuing or refunding air waybills, pricing cargo services, and informing shippers of applicable air cargo rates.
Finally, existing travel and air cargo offices must adjust their status in accordance with the Air Travel and Cargo Law within six months of its effective date. The Minister of Transport may extend this period for an additional similar term.
