Practical checks for evaluating suppliers, protecting sensitive information and documenting vendor approval decisions in the UAE.
A vendor risk assessment checklist for listed companies, TPAs and insurance brokers should establish who the supplier is, what it will do, which information it can access and how service failure would affect the organisation.
But the checklist must reflect the business. A document-storage provider and a claims-processing platform create different exposures. Sending both the same questionnaire can produce paperwork without useful assurance.
For UAE organisations, the objective is a defensible decision supported by relevant evidence, clear approvals and unresolved issues that management understands.
No. Listed companies, health insurance Third Party Administrators (TPAs) and insurance brokers operate under different regulatory requirements.
For listed companies, applicable corporate governance provisions address risk management and internal controls. They shouldn’t be described as prescribing one universal vendor questionnaire for every issuer.
For CBUAE-regulated insurance brokers, Article 17 of the Insurance Brokers’ Regulation specifically addresses outsourcing, including material outsourcing non-objection requirements and the prohibition on outsourcing activities outside the UAE.
Health insurance TPAs have their own licensing and business requirements. Their permitted activities include claims settlement, claims payments on insurers’ behalf and managing approved health insurance programmes. Broker-specific rules shouldn’t automatically be applied to TPAs.
Use the following checklist as a practical assessment tool, supplemented by applicable regulatory and contractual requirements.
Start with the contracting entity.
Ask:
Does the legal name match the licence, proposal and agreement?
Is the trade licence current and appropriate for the service?
Are relevant regulatory permissions required?
Have ownership, conflicts of interest and authorised signatories been checked?
Evidence to review: Trade licence, incorporation records, relevant permissions, ownership information and signing authority.
Don’t assume a group brand identifies the entity performing the work. Contracting with one company while another accesses records can complicate accountability.
Describe what the vendor will actually deliver, including system access, processing responsibilities and dependencies.
Ask:
Would failure interrupt customer service, claims handling or reporting?
Could inaccurate processing cause financial loss or customer harm?
How quickly could the service be replaced?
Does the arrangement constitute outsourcing under applicable rules?
Evidence to review: Statement of work, process map, business impact assessment and materiality assessment.
For a listed company, consider reporting dependencies. For a TPA, examine claims workflow disruption. For a broker, assess effects on customer servicing and policy documentation.
A competitively priced supplier still needs sufficient resources to deliver.
Ask:
Is its financial position sustainable?
Does it have appropriately qualified staff?
Can it handle expected volumes and peak demand?
Are key services dependent on one individual?
Evidence to review: Available financial statements, staffing information, relevant experience, references and capacity plans.
Record limitations where financial information is unavailable. Unsupported confidence shouldn’t become a low-risk rating simply because the supplier is familiar.
Identify the information involved before approving access.
Ask:
Will the vendor receive customer, employee, financial or health information?
Where will information be stored, accessed and backed up?
Is access restricted to necessary personnel?
What rules govern disclosure, retention and deletion?
Evidence to review: Data-flow maps, hosting details, access arrangements and contractual confidentiality provisions.
Insurance brokers must store and maintain Personal Data in the UAE under Article 16. TPAs handling health information must consider applicable health-data requirements, including confidentiality and authorised sharing.
A UAE office address doesn’t establish where data processing occurs.
A vendor cybersecurity assessment should examine controls relevant to the service.
Ask:
Are privileged accounts restricted and monitored?
Are security weaknesses tracked through correction?
Are backups protected and restoration tested?
Do independent assessments cover the proposed service?
Evidence to review: Relevant assurance reports, security assessment summaries, remediation records and access-control documentation.
Check scope, dates and exceptions. A certificate covering another business unit offers limited assurance about the platform you intend to use.
The visible vendor may depend on several other organisations.
Ask:
Which subcontractors support delivery or access information?
Can the vendor change them without notification?
Do several important services share one infrastructure provider?
Who remains responsible when a subcontractor fails?
Evidence to review: Subcontractor lists, dependency maps and contractual notification provisions.
Look beyond individual contracts. Separate suppliers can still create a common point of failure.
Complete approval checks before services begin.
Ask:
Are responsibilities, service levels and escalation arrangements clear?
Are audit access, confidentiality and termination provisions adequate?
Have required internal approvals been obtained?
Is regulatory non-objection necessary?
Evidence to review: Executed agreement, legal review, approval records and applicable regulatory correspondence.
For insurance brokers, material outsourcing submissions require risk, materiality and due diligence information alongside specified internal confirmations and approval evidence.
Commercial urgency doesn’t remove these requirements.
Approval should lead to continued oversight.
Ask:
What happens during a prolonged outage?
Can records and services transfer to another provider?
Are recovery claims supported by testing?
Which events trigger reassessment?
Evidence to review: Recovery test summaries, exit plans, service reports and outstanding action logs.
Set review frequency according to exposure. Significant incidents, ownership changes and service expansion may justify earlier reassessment.
ASC Global UAE can support vendor due diligence in the UAE through tailored checklists, evidence reviews, risk classification, approval documentation and remediation tracking.
Support can also include sector-specific gap assessments and coordination with legal, compliance and information security teams.
Discuss your vendor portfolio with ASC Global UAE to identify which relationships need deeper scrutiny.
No. Request evidence proportionate to the service, exposure and applicable obligations.
No. Responses need evaluation, supporting evidence and appropriate approval.
Assess severity, legal restrictions and compensating controls. Document the decision; mandatory requirements cannot simply be waived internally.
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