After the Decision: Appeal, Cancellation, and Notification
September 19, 2026
9 min read
DITEC Experts, Radiation Protection Team, ALDuha Institute for Training and Environmental Consulting
A refusal is not the end of the road
Article 15 provides that a natural or legal person whose licence is refused under the preceding article may appeal against the decision to the Secretary-General within one month of being notified of the refusal; that the appeal must be decided, after taking the opinion of the Committee, within one month of its receipt; and that the decision of the Secretary-General on the matter is final.
Four operative facts sit in that one sentence. The window is one month and it runs from notification of the refusal, not from the date of the decision. The appeal goes to the Secretary-General. The Radiation Protection Committee's opinion must be taken before it is decided. And the decision that comes back is final in this process.
This is why the reasoned refusal required by Article 14 matters so much in practice: the reasons are the material the appeal is built from, and the month starts running the day they arrive.
The five grounds a licence is cancelled on
The same article also provides for the lighter outcome: the Council may approve a modification of the licence where the nature of the work or the type of the licensed practice has changed, or where the place of work stated in the licence application has changed. A change of premises or of the nature of the work is a modification question, and it is put to the Council rather than absorbed quietly.
Executive Regulation, Article 18 - the cases in which a licence is cancelled
| # | The ground | What it means in practice |
|---|---|---|
| 1 | Where it emerges that the licensee submitted incorrect information, or resorted to unlawful means, that led to the licence being issued | The licence file itself is the exposure. This also carries a criminal penalty under Article 11 of the Law. |
| 2 | Where the licensee breaches any condition laid down in the Law, in this Regulation, or in the decisions issued under it | Any condition - the licence conditions, the Regulation, and decisions issued under it are all in scope |
| 3 | Where the licensee is afflicted by an illness that renders him unable to work with ionising radiation | This is why Article 17 requires an approved medical report with a personal licence application, and why fitness is reviewed rather than assumed |
| 4 | Where a hazard is found to exist to the environment, to the licensee, to his workers, or to the general public, as a result of exposing them to radiation | Four protected interests, and the environment is named first |
| 5 | Where the licensee breaches the conditions stipulated in the licence | The conditions attached to your own licence are enforceable in their own right |
Three things you must notify before they happen
Article 19 is short and easy to overlook, and it is the article that catches ordinary, well-run facilities. The licensee is obliged to notify the Council in advance of three things.
Executive Regulation, Article 19
Before commissioning trials
- The date of commencing the trials that precede operation of the licensed facility, where those trials use ionising radiation
Before operation begins
- The date of commencing operation of the licensed facility, or of carrying out a practice that uses radioactive sources
Any change - including stopping
- Any change in the circumstances in which the work is carried on, and any stoppage of work - stopping work is a notifiable event exactly as starting it is
You cannot simply give a source away
Article 20 provides that no person licensed to hold radioactive sources may dispose of them permanently, transfer them to another, or lend them to another, without obtaining a licence to do so from the Council.
Three verbs, and the third is the one that surprises people: disposing of it, transferring it to someone else, and lending it to them. Lending a gauge to another contractor for a fortnight is a licensed act, and so is handing a disused source to the company that sold it to you.
This is the article that meets the sixth obligation in Article 8 of the Law - the clause requiring import contracts to provide for the source's return to the supplier. The contract creates the route out; Article 20 requires a licence to use it.
And the conditions for licensing workers
Article 21 keeps the requirements for individual workers deliberately open: the Chairman issues, on the recommendation of the Committee, the conditions governing the licensing of workers in the various fields of radiation work.
The practical consequence: the qualifications expected of a radiation worker are not frozen in the Regulation but set by decision, field by field, and they can change. Checking the current requirement for your field is part of keeping a personal licence valid, not a one-off step at the beginning.
Frequently asked questions
How long do I have to appeal a refusal?
One month from being notified of the refusal, under Article 15. The appeal goes to the Secretary-General, and it must be decided within one month of receipt after the Committee's opinion is taken.
We are moving to new premises - is that a new licence or a modification?
Article 18 treats a change of the work location specified in the licence application as a ground for the Council to approve a modification. It is put to the Council either way; what it is not is a silent change.
We are pausing operations for a few months - does anyone need to know?
Yes. Article 19 requires prior notification of any change in the circumstances in which the work is carried on, and of any stoppage of work. Stopping is listed alongside starting.
A colleague at another company wants to borrow our source for a week.
Article 20 requires a licence from the Council to lend it - lending is named in the text itself. Article 6 of the Law puts lending and borrowing inside the licensed categories as well, so both sides are engaged.
How the Institute can help
That completes the licensing route from the first question to the last. The next instalment turns to inspection - who the inspectors are, when they arrive unannounced, and the seven purposes the Regulation gives their rounds.
Related services: reviewing licence conditions against actual operations, preparing notification and modification files, and RPO and RSO training.
Scope of what the Institute does: training and consulting. Field radiation surveys are carried out through specialist partners working in the field. The Institute does not carry out laboratory analysis, instrument calibration or equipment testing.
This explanation is published for awareness by the radiation protection team at ALDuha Institute for Training and Environmental Consulting. The English text is an explanation, not a certified translation: the Arabic text published in the Official Gazette governs in case of any difference, and this article does not replace the official text or advice from the competent authority. Last updated 19 September 2026.