The Dubai Health Authority has its own guideline for changing EMR. It sets timelines, says what must migrate, and expects proof that nothing was lost. Here is what to get right, and where the data usually goes wrong.
Clinics in Dubai change EMR for many reasons: a system that cannot meet NABIDH (National Backbone for Integrated Dubai Health) requirements, a group consolidating onto one platform, a vendor leaving the market, or simply a better fit. Since May 2025, DHA has also required facilities to run an EMR compliant with NABIDH integration requirements, with single sign-on.1
What many facilities do not realise is that DHA has published detailed expectations for the move itself. Its EMR Transition Guideline (HISHD/GD-03), effective from 25 September 2024, applies to every DHA-licensed facility planning to move from one EMR to another.2 It covers selection, timelines, teams, data migration, retention, testing, go-live, downtime and NABIDH.
This article is for Dubai clinics and hospital groups planning a switch, and for the EMR vendors on both sides of it. It focuses on seven expectations that depend most on getting the data right.
Figure 1. Key milestones in DHA's EMR Transition Guideline (HISHD/GD-03).
The guideline asks facilities to agree timelines with both the legacy and the new vendor. Most facilities should complete the transition within 60 days, while large hospitals may need six to nine months. Replacement should not exceed three months for small facilities or nine months for large hospitals (sections 6.1 to 6.3).2
Two milestones fall well before go-live. NABIDH must be notified by email at least one month before the transition (sections 15.1 and 15.2), and training should begin at least 30 days before go-live (section 16.8). The guideline also expects a steering committee, a technical team and a transition team, with a named in-house project manager who owns the migration (sections 7.1 to 7.10).
The data work is usually what stretches a timeline. Cleaning, mapping and verifying records takes longer than installing software, so it should start first, not last.
The guideline is specific about the core. Demographics, medical history, prescriptions, diagnostic results, and social, family and medication histories should be migrated as required by DHA's Health Data Quality Policy (section 8.8). Insurance data must also transfer correctly (section 8.10). Within that, the facility decides what to clean up and how far back to migrate (section 10.9).
Figure 2. What the guideline expects to move, and the decisions it leaves to each facility.
Older records do not simply disappear. The guideline allows records of deceased or long-absent patients to be made inactive, with a preferred five-year rule, but they must stay visible and accessible (section 9.3), and no record may be destroyed before the retention period set by DHA policy (section 9.6). Federal law separately requires health data to be kept for at least 25 years from a patient's last procedure.5 Whatever is not migrated in full still needs a safe, searchable home.
DHA's Standards for Clinical Data Coding and Terminology set the code systems facilities must use: international standards for diagnoses, procedures and laboratory observations, a dental code set, a vaccine code set, and the Dubai Drug Code for medicines.3 DHA reaffirmed its coding and terminology standards through a circular in December 2025,4 and the guideline expects vendors to keep code sets up to date (section 5.11).
Older systems rarely match perfectly. Laboratory tests may sit under local names, medicines under brand names or free text, and diagnoses under outdated code versions. A migration that copies these across unchanged moves the problem into the new system, where it becomes harder to see. Mapping each item to the current standard, with clinical review where meaning is uncertain, is what makes the new EMR's data usable from day one.
The guideline asks facilities to check legacy data for accuracy and catalogue duplicates (section 7.4), and expects the new EMR to offer advanced search, merge and un-merge functions for the medical record number to prevent or resolve duplicates (section 5.17.4). It also expects the new EMR to build a clinical summary from a patient's first visit to the most recent (section 5.17.6).
Figure 3. An illustrative duplicate. Merged before migration, the clinician sees seven years of history; left alone, half of it is easily missed.
Duplicates are one of the most common data quality problems in health information exchange. A published review of Dubai's NABIDH rollout found multiple medical record numbers for the same patient within a single facility.6 A migration is the best chance a facility will have to fix them, because every record is being examined anyway. Matching on the Emirates ID and other demographics, with human review for uncertain matches, prevents the new system from inheriting the old one's confusion.
Every EMR accumulates documents: outside laboratory reports, referral letters, discharge summaries from other hospitals, imaging reports, consent forms and scanned paper records. Many legacy systems store these as attachments, outside the structured record.
A migration that moves attachments as attachments preserves them, but not their value. The results inside them still cannot be trended, searched or shared, and the clinical summary the guideline asks for (section 5.17.6) will be missing whatever sits in those files. Structuring the most important documents during migration, starting with laboratory results and medication histories, gives the new system a far more complete picture of each patient. The guideline also requires audit trails and metadata to be archived so they remain retrievable and readable (section 9.4).
For patients who brought records from abroad, the same applies. We looked at that challenge in 7 Ways UAE Clinics Can Stop Losing Expat Patients' Medical Histories.
DHA expects evidence, not assurances. The guideline asks facilities to test thoroughly before go-live (section 10.2), using actual patient data in realistic scenarios (section 10.3), with integration test cases that include regulatory systems (section 10.4). Testing must confirm that data is complete, correctly allocated and unchanged during migration, and the verification records must be available to auditors and inspectors (section 10.7). A go-live checklist signed by all stakeholders is expected (section 8.7), as is a rollback plan (section 11.7).
In practice, this means sampling migrated records against the source, reconciling counts of patients, visits, results and prescriptions, and checking that units, dates and codes survived the journey. Clinicians should be involved in the review, because they will notice a result that looks wrong far faster than a script will.
The guideline sets clear NABIDH steps: notify NABIDH at least one month before the transition (sections 15.1 and 15.2), notify it again when the old EMR is closed so connections can be shut (section 15.3), and support re-integration as early as possible after the transition (section 15.4). Where an EMR change is part of a merger, DHA's standards for managing health information during facility closure add that data from both merging facilities must remain submitted to NABIDH.7
Figure 4. Vendor expectations in DHA's EMR Transition Guideline. These apply to every partner that touches your data during the move, not only the EMR vendor.
Residency matters during migration as much as after it. Data extraction, cleaning and mapping are often done by third parties or with tools that process data outside the country by default. Under Federal Law No. 2 of 2019, health data related to services in the UAE may not, by default, be stored or processed outside the country unless an exemption applies.5 Ask every partner in the migration where processing happens.
Yes. The DHA EMR Transition Guideline (HISHD/GD-03), effective from 25 September 2024, applies to all DHA-licensed healthcare facilities planning to move from one EMR to another.
The guideline says most facilities should complete within 60 days, and large hospitals may take six to nine months. Replacement should not exceed three months for small facilities or nine months for large hospitals.
Email nabidh@dha.gov.ae at least one month before the transition, notify NABIDH again when the old EMR is closed, and support re-integration as early as possible.
The guideline lists demographics, medical history, prescriptions, diagnostic results, and social, family and medication histories, with insurance data transferred correctly. The facility decides what to clean up and how far back to migrate.
No record may be destroyed before the retention period set by DHA policy, and federal law requires health data to be kept for at least 25 years from a patient's last procedure. Inactive records must stay visible and accessible.
An EMR switch is the one moment when every record is examined. Used well, it leaves a facility with cleaner, more complete data than it started with. There are two ways we can support you.
This article is for general information and is not legal or regulatory advice. Always refer to the current DHA documents.
Suhina Singh is a physician, the Founder and CEO of Jonda Health, and a health data strategist working at the intersection of artificial intelligence and clinical information systems.
