Scroll through Sana Chikhalia's Instagram feed and you'll soon be struck down with wanderlust. The carefully curated grid of images show sojourns to London and Osaka in amongst perfectly framed shots of food at some of the hottest spots in Dubai, where Chikhalia is based. She describes herself as a blogger, traveller and storyteller, posting updates to her near-70,000 followers on the platform.
She's one of a number of influencers - people who earn money or receive gifts for posting about products on social networks such as Instagram, Facebook and YouTube - who are being forced to register with the United Arab Emirates government by the end of June. The new influencer licensing laws, introduced by the UAE's National Media Council (NMC) earlier this year, apply to "any paid or unpaid form of presentation and/or promotion of ideas, goods, or services by electronic means, or network applications."
As you'd expect from a super-rich Gulf emirate, there are plenty of influencers giving a snapshot into their lives through Instagram, YouTube and Twitter. Dubai is the home of Rashed Saif Belhasa, the teenage son of a Dubai businessman who made his millions from the construction trade; Belhasa has more than a million followers on Instagram. Dubai is also the home of the video that transformed Nusret Gökçe, a moderately successful restaurateur into viral video sensation Salt Bae: the video of Gökçe slicing up a tomahawk steak then sprinkling it with salt that rolled down his forearm was tagged with the location of his Nusr-Et steakhouse in Dubai.
The fee influencers have to pay to get the requisite licence from the NMC is a cool 15,000 dirham, or £3,000. In 12 months time, they need to renew their licence. The average annual salary for workers in the Emirate of Dubai? 52,000 dirham.
Notably, the cost of obtaining the new licence for "websites and social accounts specialised for online advertising electronic", as the NMC describes it, is more expensive than attaining a licence to set up a publishing house or news agency. Getting the right permits from the government to shoot a feature film in the UAE is cheaper.
If you don't register in time, or if you breach the opaque set of rules that influencers will be held to, you can be fined 5,000 dirham (£1,000), and have your account closed.
The laws will encourage "balanced and responsible media content that respects the privacy of individuals, and protects the public - especially children - from negative or harmful material," said Mansour Ibrahim Al Mansouri, the director-general of the NMC, at a press conference announcing the regulation. (The NMC, and Dubai's government, did not respond to interview requests for this story.) Others fear it'll have a chilling effect on a burgeoning industry.
"Being an influencer is not necessarily a full-time job," explains Gus Younis, a digital marketing consultant based in Dubai. "For some people it is but for others, especially the microinfluencers, it's a side gig. It's people making extra bucks on the side."
If you're Huda Kattan, a 34-year-old Oklahoma-born, Dubai-based influencer who posts to her 25 million Instagram followers under the name of Huda Beauty, then the £3,000 licence fee is a drop in the ocean. (Kattan's estimated by one count to be able to charge many times that just for mentioning brands in her posts.)
For Chikhalia, who estimates she earns around $4,000 on an average month from her social media support for brands including tourism boards, airlines and food and drink companies (though "my earnings completely depend on the high and low months in Dubai, as during Ramadan time the market gets slow," she explains), it's also manageable.
"The law is a good thing," she says. "It means anybody cannot just wake up and think of becoming a blogger. With the new law, you will have to first register a company. This makes it more difficult, and regulates the market. I will have more credibility."
"We've been getting very positive signs from clients who are more comfortable dealing with agencies rather than individuals," explains Ahmad Bashour, general manager of ITP Live, an influencer marketing agency which launched in 2016. "We notice that the industry faced and is still facing many challenges", including opaqueness about the amount influencers should charge for posts to brands refusing to pay influencers for the work done. "The UAE government stepping in and passing on these laws will only reduce these challenges, increase the transparency and basically start cleaning up and setting up a proper base for one of the most exciting industries in recent times," he says.
Younis worries that increased difficulty - and the enormously costly barrier to entry - may hollow out the roster of influencers available.
"I understand why they made the law," he says. "There's a lot of influencers who make huge amounts of money and it's not reported; there are no contracts, nothing." But setting such a high cost to register, along with the complications of registering (smaller ex-pat influencers who use social media as a side job will have to contact their main employer to transfer their visa from their current employer to a new business they set up to register with the NMC) discounts the vast swathes of microinfluencers, who brands are increasingly turning to in favour of larger, more-followed internet celebrities, because of their higher engagement with their audiences.
"It's a headache that I'm not sure is going to work for most people," says Younis. It'll also have a knock-on effects on the success of campaigns big companies hire smaller influencers for.
Losing microinfluencers will result in less competition and price inflation, he reckons. "A lot of brands won't see the return on investment we used to see from microinfluencers. It'll have negative effects."
Chikhalia's willing and able to pay the fee, so will stay competitive in the influencer world. "I'm excited for the change as now there will be few[er] bloggers who would register," she says. "Genuine bloggers put their effort and time [into their work] whereas people who are there just for the freebies get the advantages as the PRs prefer them since they're a cheaper option."
She's in the process of registering a company and applying for the licence with the help a firm helping her navigate the complexity of the UAE's laws, who are charging her between £200 and £400 for the process. "These companies know the procedure in and out, so it's way easier to go with them. Hopefully before June it should be done," she says.
Though Younis isn't happy with the way the licensing regime is being implemented, he's unsure about a better way of managing the system. "It's complicated," he admits. "I think it shouldn't be that you have to register as a business," he says. Rather, he'd have influencers register as such with the NMC, then report how much money they're making from their activities. If it ticks over a certain amount, influencers should be required to then register as a business, to prevent unnecessary paperwork for the part-time influencers who occasionally accept a free meal in exchange for a well-lit Instagram post to their thousands of followers.
Many of the law's foibles and intricacies are unique to the UAE's position as a home for a largely itinerant population. Previous few people who live in Dubai are actually from there; most are ex-pats. The regulations, which include signing on to a licensing regime, serve two purposes: they allow the emirate to create a database of influencers operating there, and allow the government to drive revenue.
"It's an interesting situation because you have so many people from so many different countries there," says Harry Hugo of The GOAT Agency, a London-based influencer marketing firm. "The rules have to be blanket ones to make sure they're okay for everybody."
Bashour believes that "the model definitely applies elsewhere", pointing to the US Federal Trade Commission (FTC) implementing new rules around influencers there.
Though Hugo believes the Dubai model is "interesting", he has his reservations about much of it. "I don't see why you need licences," he says. "It's not like having a gun." Simply using the term 'licence' gives it a negative connotation, he reckons. "I think it comes from a misunderstanding of what influencer marketing is, and a perceived negative power that these people have because they have a social media following."
The UAE is a highly conservative, tightly regulated society. A 122-page white paper, published in 2014 by the Emirates' Telecommunications Regulatory Authority, outlines the rules and regulations of each social network - from Twitter to "Keek" - and repeatedly makes clear that "the laws of the UAE prohibit the publication of content which is contrary to public morals, the principles of Islam and the social and moral welfare of the UAE."
While those rules are more stringent than western governmental approaches to social media use, there is an increasing awareness of the impact that social media can have on society at the highest levels. A class action petition to the FTC, made last month by 21 different pressure bodies, expressed concern that YouTube and the creators on it were taking advantage of the platform to market to an often pre-teen audience, in violation of US law. We've seen more scrutiny of the kinds of content being posted on YouTube; Facebook and Twitter are making inroads into the fake news problem, and there's an intolerance of hate speech on such platforms, embodied by Germany's decision to make social networks culpable for any hate speech hosted on their platform, with the potential of multi-million Euro fines for not taking it offline promptly.
In part, the UK already has regulations similar to the UAE's influencer regulations. When five British YouTubers - TomSka, Dan and Phil, Emma Blackery and PF Liguori - all uploaded videos in 2014 testing how fast they could lick the creamy centre out of a double-stuffed Oreo, it was unlikely they thought they'd kickstart a debate about the role of sponsored content on social media that would end up with part-regulation by Britain's Advertising Standards Authority (ASA).
But that's exactly what happened.
Oreo brand owner Mondelez approached the YouTubers, asking them to shoot the "lick race" videos in exchange for payment while mentioning within the video itself that they were connected in some way to the brand (which some creators did by simply saying: "Thanks to Oreo for making this video possible"). The ASA ruled that wasn't sufficient, and introduced new advice for influencers to follow, which includes expressly stipulating in the title or description of any content that it was an advertisement or sponsored.
The Oreo incident was just one of many questionable brand deals brokered around that time. Two gaming YouTubers who used the names TmarTn and Syndicate were censured by the US Federal Trade Commission (FTC) in September 2017 for endorsing a company within which they owned interests without declaring those interests, as well as paying other influencers to advertise the company. It was the first time the FTC took action against individual named influencers. Such incidents are, through the natural evolution of the market and intervention by the relevant authorities, becoming less commonplace.
"From 2015 to mid-2017, influencer marketing was the wild west," says Hugo. "Now we've got more analytics on these platforms, an increased awareness of fake engagement and bots, and brands are investing more and want better returns. Because of that, things have to professionalise at a rapid rate."
Although western countries are unlikely to follow some of the more hardline elements of the regulation, parts of Dubai's strictly regulated model could be a template for others to follow.
One thing is certain, though: the UAE won't be the last country to introduce such legislation directed at influencers.
"I think we're going to see quite a lot of ways of tackling this profession in the next few years - maybe even the next few months," says Hugo. "This is just one of them, and it'll change over time."