Bahrain Recording Laws: All-Party Consent Rules and Penalties (2026)

Bahrain Recording Laws: All-Party Consent Rules and Penalties (2026)

Bahrain is an all-party consent jurisdiction. Recording a phone call, face-to-face conversation, or electronic communication without the knowledge and agreement of every participant is a criminal offense under multiple overlapping statutes. The penalties are severe: the Cybercrime Law alone carries fines up to BHD 100,000 (roughly USD 265,000) plus prison time.

This guide covers the full legal framework governing recording and wiretapping in the Kingdom of Bahrain, including the Cybercrime Law, the Penal Code and its 2025 amendments, the Personal Data Protection Law, workplace and public surveillance rules, the recording-police risk, voyeurism provisions, and the pending deepfake legislation that would expand criminal liability to AI-generated audio and video content.

Information last verified on 2026-05-15. This article has not yet been reviewed by a licensed lawyer.

Jurisdiction scope: This article addresses recording and surveillance law in the Kingdom of Bahrain under Bahraini federal law, including the Penal Code, Cybercrime Law, and Personal Data Protection Law. It does not address laws of other GCC states; for UAE recording law, see our UAE recording laws guide.

Constitutional Foundation: Article 26

Before examining the specific statutes, it helps to understand where Bahrain's recording restrictions originate. Article 26 of the Bahrain Constitution states that "the freedom of postal, telegraphic, telephonic and electronic communication is safeguarded and its confidentiality is guaranteed."

Communications can only be intercepted or their confidentiality breached "in exigencies specified by law and in accordance with procedures and under guarantees prescribed by law." This constitutional provision underpins every statute discussed below. It establishes that privacy in communications is not just a regulatory preference but a fundamental right protected at the highest level of Bahraini law.

The phrase "exigencies specified by law" is significant. It means the legislature cannot authorize unlimited interception. Any statute permitting interception must define the conditions narrowly and provide procedural safeguards. Courts reviewing interception cases look to whether the statutory authorization met this constitutional standard.

The Cybercrime Law: Law No. 60/2014

The most significant statute for anyone considering recording a phone call or intercepting electronic communications in Bahrain is the Law on Combating Information Technology Crimes, enacted as Law No. 60 of 2014 (also cited as Decree-Law No. 60/2014).

Article 4: Wiretapping and Interception

Article 4 is the core provision. It criminalizes wiretapping, interception, eavesdropping, and the capturing of data transmitted between information technology systems. The offense covers any unauthorized act of listening to, recording, or capturing communications sent through electronic means.

The penalties are substantial. Anyone convicted under Article 4 faces imprisonment combined with a fine of up to BHD 100,000. At current exchange rates, that is approximately USD 265,000. The law does not distinguish between personal and commercial interception. Recording a single phone call without consent carries the same statutory penalties as large-scale corporate espionage.

The Cybercrime Law organizes offenses into three categories: crimes against IT systems (unauthorized access, system disruption), crimes involving the means of IT (using technology as the instrument of an offense), and content crimes (offenses related to the substance of communications). Wiretapping and interception fall primarily within the first two categories, depending on how the interception is carried out.

Article 6: Aiding and Abetting

Article 6 extends criminal liability beyond the person who actually performs the interception. Anyone who aids the offender by providing tools, passwords, or similar information for the purpose of wiretapping or interception faces imprisonment of up to one year and a fine of up to BHD 100,000, or both.

This means that a person who provides recording software, shares login credentials used to access another person's communications, or otherwise facilitates illegal interception can be prosecuted even if they did not personally press the record button.

Pending Deepfake Amendment: Proposed Article 10 (bis)

In November 2025, members of the Shura Council proposed adding a new Article 10 (bis) to the Cybercrime Law. As of May 2026, this proposal was still at committee stage and had not been enacted. The proposal is covered in detail in the Deepfake and AI-Generated Content section below.

The Penal Code: Decree-Law No. 15/1976

The Penal Code has served as Bahrain's primary criminal legislation since 1976. Several articles directly address recording, eavesdropping, and the disclosure of private information. The 2025 amendments significantly increased penalties that had been unchanged since the code's original enactment.

Article 370: Privacy and Unauthorized Surveillance

Article 370 addresses the unauthorized publication and disclosure of information that breaches an individual's privacy. Under the original 1976 text, the maximum penalty was six months in prison or a fine of just BHD 50. Legislators recognized for years that these penalties were outdated given the ease with which recordings can be made and shared through smartphones and social media.

Following years of parliamentary debate, the Bahraini Parliament passed Law No. 25 of 2025, which was published in Official Gazette No. 3812 on May 29, 2025, and entered into force on May 30, 2025. The amended Article 370 now carries significantly stronger penalties for unauthorized audio or visual surveillance, recording private conversations without permission, and recording people in private settings without their knowledge.

Basic offenses under the amended Article 370 carry fines of BHD 500 to BHD 1,000 with possible imprisonment. If the recorded material is publicly shared or published, the fines increase to BHD 1,000 to BHD 3,000.

The 2025 revision consolidated two earlier draft proposals: one originating from the Shura Council and one from the government. Parliament's Foreign Affairs, Defence and National Security Committee reviewed both drafts across 27 committee meetings before approving the final text.

Article 354: Violations of Private and Family Life

Article 354 addresses broader violations of private and family life. Under the original text, the maximum penalty was three months in prison or a BHD 20 fine. Law No. 25/2025 increased these penalties to three to six months of imprisonment with fines of BHD 100 to BHD 1,000.

This article captures conduct that goes beyond recording itself, such as publishing details of someone's private life, even when those details are factually accurate, when the publication causes harm to the person.

Article 372: Unlawful Disclosure of Messages and Calls

Article 372 specifically targets the unlawful disclosure of messages and calls. Under the original Penal Code, the fine was a mere BHD 20. The 2025 amendments transformed this provision:

For basic disclosure of private communications, the penalty is now BHD 500 to BHD 1,000, or imprisonment. For disclosures that harm third parties or involve matters of personal honor, the penalty rises to BHD 2,000 to BHD 5,000 in fines, plus prison time. In the most severe cases, offenders face up to five years in prison and a BHD 5,000 fine.

Legislative Decree No. 3/2025: Device Theft and Data Access

Separate from the privacy amendments, Legislative Decree No. 3 of 2025 (published Official Gazette January 23, 2025, in force January 24, 2025) amended the Penal Code to address theft of electronic devices with intent to access their data. The amendments added new provisions to Articles 380 and 396.

Under the amended Article 380, theft of a mobile phone, laptop, tablet, or any electronic device "with the intent to obtain the information, data, or images that they contain" carries a minimum of one year imprisonment.

Article 396 now provides that seizing such devices to access their data carries penalties of up to two years imprisonment or a fine up to BHD 500, or both. These provisions complement the Cybercrime Law by addressing physical access to recorded communications stored on devices.

The Personal Data Protection Law: Law No. 30/2018

Bahrain's Personal Data Protection Law (PDPL), enacted as Law No. 30 of 2018 and enforced since August 1, 2019, adds another layer of regulation over recording activities. The PDPL is administered by the Personal Data Protection Authority (PDPA), an independent public body established by the same law.

What Counts as Personal Data

Under Article 1 of the PDPL, personal data means "any information in any form concerning an identified individual, or an individual who can be identified" through identifiers or factors relating to their identity. A person's voice in a recorded conversation qualifies as personal data. So does any video footage in which a person is identifiable.

This broad definition means that virtually any audio or video recording involving a real person triggers PDPL obligations, regardless of the purpose of the recording.

Consent Requirements

Article 24 of the PDPL requires that consent for data processing be "written, explicit, clear, and specific to the processing of certain data." The person providing consent must have full legal capacity, and the consent must be freely given after the individual understands the purposes and potential consequences.

This standard applies directly to recording. If you record someone's voice, you are processing their personal data, and you need their written, explicit consent unless a specific legal exception applies. Generic terms-and-conditions sign-offs do not satisfy the Article 24 standard.

Surveillance Authorization

Article 15 of the PDPL requires that any automatic processing involving visual recording used for surveillance purposes receive prior authorization from the Personal Data Protection Authority. This applies to CCTV systems, security cameras, and any form of automated visual monitoring.

Biometric and genetic data processing also requires pre-authorization for automated operations, which is relevant for any recording system that uses voice recognition or facial recognition technology.

PDPL Penalties

The penalties under the PDPL are separate from and cumulative with those under the Penal Code and Cybercrime Law:

Criminal penalties include imprisonment of up to one year and fines of BHD 1,000 to BHD 20,000 for violations such as processing data without consent, processing without notifying the authority, or unauthorized sensitive data processing.

Administrative penalties include daily fines of up to BHD 1,000 for initial offenses and up to BHD 2,000 for repeat violations within three years, plus lump-sum fines of up to BHD 20,000.

For corporate offenders, the fines are doubled. A company that records calls without proper consent could face criminal fines of up to BHD 40,000 on top of any penalties under the Cybercrime Law and Penal Code.

Civil Liability

Article 58 of the PDPL grants individuals the right to seek civil compensation for damages resulting from unlawful data processing. A person whose conversation was recorded without consent can pursue both criminal charges and a separate civil claim for monetary damages. These two tracks are independent: criminal prosecution and a civil lawsuit can proceed simultaneously.

Phone Recording vs. In-Person Recording

Bahrain's legal framework treats phone recordings and in-person recordings with equal severity, but the applicable statutes overlap differently depending on the medium.

Phone and Electronic Communications

Recording a phone call falls squarely under Article 4 of the Cybercrime Law (Law No. 60/2014), which covers interception of data transmitted between IT systems. The Telecommunications Law (Decree-Law No. 48/2002) provides the regulatory framework for the telecoms industry and has been used by the Telecommunications Regulatory Authority (TRA) to mandate data retention by service providers.

For individuals, the rule is straightforward: you cannot record a phone call unless all parties to the call know about and agree to the recording. The same applies to video calls, voice messages, and any form of electronic communication transmitted through digital networks.

In-Person Conversations

Recording a face-to-face conversation is governed primarily by the Penal Code (Articles 370 and 372, as amended by Law No. 25/2025) and the PDPL. The amended Article 370 specifically targets eavesdropping and recording in private settings without consent.

The expectation of privacy matters. A conversation between two people in a home or private office carries a strong expectation of privacy. Even a conversation in a semi-public setting, such as a restaurant, may be considered private if the participants took reasonable steps to keep their discussion confidential.

Text Messages and Digital Communications

Written electronic communications are also protected. The Cybercrime Law covers the interception of any data transmitted between IT systems, which includes text messages, emails, and messaging app conversations. Accessing someone else's messages without authorization is prosecutable under the same framework as audio interception.

Recording in Public Spaces

Recording in public spaces in Bahrain occupies a legal gray area that depends heavily on what is being recorded and whether the recording captures private communications.

General Photography and Filming

Bahrain does not broadly prohibit photography or filming in public spaces. However, recording identifiable individuals without their consent implicates the PDPL, since the footage constitutes personal data. The amended Penal Code also criminalizes filming people in private or compromising situations without their knowledge, even if the filming occurs in a technically public location.

Filming Accident Victims

Law No. 25/2025 (the 2025 Penal Code amendments) specifically addressed the practice of filming accident victims without consent. This is now a criminal offense under the amended Article 370, reflecting parliamentary concern about bystanders recording vulnerable individuals and sharing the footage online. The provision applies regardless of where the accident occurs: a public road, a shopping center, or any other location.

Government and Military Locations

Recording near government buildings, military installations, and other sensitive locations is restricted. Bahrain's security laws prohibit unauthorized photography and recording in areas designated as security zones. Violating these prohibitions can trigger charges that go beyond the Penal Code's privacy provisions and into national security legislation.

Recording Police Officers

Bahrain has no statute expressly granting individuals a right to record police officers, law enforcement personnel, or government officials. This absence is significant and distinguishes Bahrain from jurisdictions that have codified a public right to document government activity.

No Explicit Right to Film Police

In the absence of a statutory right to record, the general rules of Bahraini law apply. The Cybercrime Law, Penal Code privacy provisions, and national security legislation all remain operative when a recording involves police or government officials.

The practical risk is substantial. Bahrain's government has, in documented cases, used cybercrime and public-order statutes to prosecute individuals who posted content critical of authorities online. The US State Department's 2024 Bahrain Human Rights Report and Freedom House's Freedom on the Net 2024 assessment both noted that individuals have been summoned for questioning and prosecuted for social media posts and online commentary. The same legal apparatus applies to recordings.

Specific Risks Under Existing Law

A person who records a police officer performing a public duty faces several potential exposure points:

Under the Cybercrime Law, if the recording involves capturing data transmitted through electronic means (for example, recording a radio communication), Article 4 applies. Under the Penal Code, if the recording is of a private confrontation rather than a purely public act, Articles 370 or 372 could be invoked. Under national security law, recording near security facilities or of personnel in sensitive operations could trigger charges separate from the Penal Code framework.

Practical Guidance

This is an area of high legal risk for journalists, human rights observers, and members of the public. Anyone considering recording police activity in Bahrain should consult a lawyer licensed to practice in Bahrain before doing so. The absence of a statutory right means there is no safe harbor for such recordings, even when the intent is to document potential misconduct.

Watch out: Sharing a recording of police activity on social media or messaging apps adds a separate layer of liability under Article 372 of the Penal Code (disclosure of communications) and the Cybercrime Law (distribution of electronic content). The act of distribution is a distinct offense from the original recording.

Voyeurism and Secret Filming

The 2025 Penal Code amendments (Law No. 25/2025) addressed voyeurism and secret filming with new specificity that was absent from the 1976 original text.

Conduct Covered by the Amended Provisions

The amended Article 370 now expressly criminalizes recording individuals in private settings without their knowledge. The provision covers:

Eavesdropping on private conversations without the participants' awareness. Recording individuals in intimate or compromising situations without consent. Filming people in locations where they have a reasonable expectation of privacy, including private residences, changing areas, and bathrooms. Capturing images or video of individuals without their consent in ways that damage their dignity or privacy interests.

The 2025 amendments responded directly to growing parliamentary concern about the rapid dissemination of intimate recordings through social media. MP Mohammed Al Ma'arafi described the revision as "a wider push to improve legal protection for privacy" in a digital environment where a single recording can reach thousands of people within minutes.

Penalties for Voyeurism Offenses

Penalties for violations of the amended Article 370 depend on what the offender does after making the recording:

Basic offense (recording without consent): BHD 500 to BHD 1,000 fine plus imprisonment. Aggravated offense (publicly sharing or publishing the recording): BHD 1,000 to BHD 3,000 fine plus imprisonment. Most severe cases (sharing material of an intimate nature or relating to personal honor): up to BHD 5,000 fine plus up to five years imprisonment under Article 372.

The penalties are not alternatives: the prosecution can charge both the original recording offense and the disclosure offense for the same course of conduct, making the combined exposure significant.

Intimate Image Abuse

The distribution of intimate images without consent is covered by the intersection of Articles 370 and 372. A person who records an intimate image and then shares it faces prosecution under both provisions. The 2025 amendments did not create a standalone revenge-porn statute, but the amended penalty structure under Article 372 for "matters related to honour" functions similarly.

Deepfake and AI-Generated Content

Proposed Article 10 (bis): Status as of May 2026

In November 2025, members of the Bahrain Shura Council proposed adding a new Article 10 (bis) to the Cybercrime Law (Law No. 60/2014). As of May 2026, this proposal had been approved by the Shura Council's Legislative and Legal Affairs Committee and forwarded to the Foreign Affairs, Defence and National Security Committee for primary study. The bill had not yet been enacted into law.

The proposers included First Deputy Chairman Jamal Fakhro, Ali Al Shehabi, Dr. Mohammed Ali Hassan, Khalid Al Maskati, and Dalal Al Zayed. The Legislative and Legal Affairs Committee found the bill constitutionally and legally sound before forwarding it.

What the Proposed Law Would Cover

The proposed Article 10 (bis) would criminalize producing or falsifying visual or audio material through any technological means where the person intends to circulate, distribute, send, publish, or otherwise make the material available and where the act:

Renders another person liable to contempt or punishment. Affronts honor or injures the reputation of families. Pursues an unlawful purpose.

The bill specifically targets the phenomenon of "deepfakes": AI-generated hyper-realistic videos or voice files that imitate specific individuals. The legislation extends beyond political deepfakes to cover any AI-generated content designed to harm reputation or honor.

Proposed Penalties

Under the proposed Article 10 (bis), offenders would face imprisonment and/or fines of BHD 3,000 to BHD 10,000 (approximately USD 8,000 to USD 26,500 at current exchange rates).

Current State of the Law

Because the bill has not been enacted, Bahrain does not currently have a deepfake-specific criminal provision. However, existing law provides partial coverage:

A deepfake audio file used to deceive a call recipient could constitute interception or electronic fraud under the Cybercrime Law. A deepfake video distributed to damage someone's reputation could engage the Penal Code's disclosure and privacy provisions (Articles 354, 370, and 372). The PDPL's consent requirements apply to any processing of a person's voice or likeness in identifiable form.

If Article 10 (bis) is enacted, it would become a more targeted and administratively simpler provision than relying on the patchwork of existing laws.

Watch out: Businesses and content creators using AI tools to generate audio or video content involving real individuals should monitor Bahraini legislative developments closely. If the proposed Article 10 (bis) is enacted, liability could attach even if the AI-generated content does not directly constitute wiretapping or interception under the current Cybercrime Law.

Criminal Penalties: Summary Table

Bahrain imposes penalties under multiple statutes. A single act of unauthorized recording can trigger prosecution under several laws simultaneously.

Cumulative Prosecution

These penalties are not mutually exclusive. A person who secretly records a phone call and shares it online could face charges under the Cybercrime Law (for the interception), the Penal Code (for the recording and disclosure), and the PDPL (for processing personal data without consent). The combined fines and prison terms can be devastating. Bahraini courts can impose sentences under multiple statutes arising from the same act.

Business Compliance: Recording Calls in Bahrain

Businesses operating in Bahrain that need to record calls for quality assurance, compliance, or training purposes must navigate all three statutory frameworks simultaneously.

Step 1: Obtain Explicit Consent

Before any recording begins, secure written, explicit consent from all parties who will be recorded. For customer calls, this typically means playing a clear announcement at the start of the call that states the call is being recorded, the purpose of the recording, the legal basis, and how to decline. If a customer declines, you must provide an alternative service channel.

For employee calls, include recording consent provisions in employment contracts and internal policies. The consent must be specific, not buried in general terms and conditions.

Step 2: Notify the Personal Data Protection Authority

Under the PDPL, any organization processing personal data (including voice recordings) must notify the PDPA before beginning processing. If you are using automated surveillance systems, you need prior written authorization under Article 15 before deploying them.

Step 3: Implement Data Protection Safeguards

Recorded data must be stored securely, with access limited to authorized personnel. Establish a clear retention policy specifying how long recordings are kept. The PDPL's storage limitation principle means you cannot retain recordings indefinitely; retention periods must be proportionate to the purpose.

Step 4: Honor Data Subject Rights

Under the PDPL, recorded individuals have the right to request access to their recordings, request corrections or deletion, object to further processing, and request non-automated review of decisions made using their data. Businesses must respond to access requests within 15 working days, free of charge.

Step 5: Restrict Cross-Border Transfers

If your organization stores call recordings outside Bahrain, you must verify the destination country provides adequate data protection. The PDPA published Resolution No. 42 of 2022 establishing an Adequacy List of 83 jurisdictions that meet Bahrain's data protection standards. Transfers to those jurisdictions do not require separate PDPA approval. Transfers to countries not on the Adequacy List require either prior PDPA permission or the data subject's explicit consent to the specific transfer.

Step 6: Appoint a Data Protection Coordinator

Organizations processing significant volumes of personal data should designate an internal data protection coordinator to manage compliance, respond to data subject requests, and liaise with the PDPA.

Workplace Recording and Surveillance

Bahrain does not have a standalone workplace surveillance statute comparable to some European countries. Instead, workplace recording is governed by the intersection of the PDPL, the Penal Code, and general employment law.

Employer Obligations Under the PDPL

Any employer that records employees, whether through CCTV cameras, call monitoring systems, or other means, is processing personal data. The PDPL requires written, explicit consent from each employee before such processing begins. The employer must also notify the Personal Data Protection Authority of the processing activity.

Employers cannot broadly claim implied consent. The PDPL's standard demands specific, informed agreement from individuals who understand exactly what will be recorded, how the recordings will be used, and how long they will be stored.

CCTV in the Workplace

Employers installing CCTV cameras must comply with Article 15 of the PDPL, which requires prior authorization from the PDPA for surveillance using visual recording systems. Installations must also respect the privacy of areas where employees have a reasonable expectation of privacy, such as restrooms and changing areas.

Homeowners and businesses installing CCTV cameras must inform people about the presence of cameras, store captured data securely, use footage only for its stated security purpose, and refrain from sharing footage publicly without consent. Residential installations must also notify neighbors, per the 2025 CCTV guidance.

Employee Monitoring of Social Media

Monitoring employees' social media activity outside of work is not permitted under Bahraini law. While pre-employment background checks are allowed, ongoing surveillance of employees' personal online activities falls outside the scope of legitimate employment purposes under the PDPL.

AI and Automated Monitoring

Any AI-based monitoring system that processes personal data must comply with the PDPL, including the consent and transparency requirements. Automated decision-making systems that use voice recordings or video footage to evaluate employee performance require PDPA notification and, where the processing is sensitive, pre-authorization. The pending deepfake legislation, if enacted, would also be relevant to employers who use AI to generate or manipulate audio or video content.

How Bahrain Compares to Its Neighbors

Bahrain's all-party consent requirement and heavy penalties place it among the stricter jurisdictions in the Gulf region.

United Arab Emirates also requires all-party consent. The UAE's Federal Decree-Law No. 34/2021 on Combating Rumors and Cybercrimes prohibits recording private conversations without consent, with penalties including imprisonment and fines up to AED 500,000.

Saudi Arabia criminalizes unauthorized recording under the Anti-Cybercrime Law (Royal Decree No. M/17, 2007). Recording private conversations or intercepting communications without consent carries up to one year imprisonment and fines up to SAR 500,000.

Kuwait has strict recording prohibitions under its Penal Code and Electronic Crimes Law. Unauthorized recording of private communications can result in imprisonment and fines.

Qatar prohibits unauthorized recording under the Cybercrime Prevention Law (Law No. 14/2014). Recording someone without consent in a private setting carries penalties of up to three years imprisonment.

For businesses operating across the Gulf Cooperation Council (GCC), the consistent theme is clear: all-party consent is the regional norm. Recording without consent in any GCC country carries serious criminal consequences.

Lawful Interception: When the Government Can Record

Bahrain's laws carve out exceptions for government surveillance conducted under lawful authority. The Telecommunications Law (Decree-Law No. 48/2002) requires telecommunications service providers to maintain a "lawful access capability plan" allowing security forces to access communications metadata when authorized.

Since 2009, the TRA has mandated that all telecommunications companies retain records of customers' phone calls, emails, and website visits for up to three years. This data retention requirement operates independently of the restrictions on private recording.

The PDPL specifically exempts processing related to public security carried out by the Ministry of Defense, Ministry of Interior, National Guard, National Security Service, or other security bodies in the Kingdom. This means that government security agencies operate under a different legal framework than private individuals and businesses.

Lawful interception by law enforcement requires proper authorization through the judicial system, consistent with the constitutional protections in Article 26. The judiciary's role as a check on interception authority reflects the constitutional requirement that any lawful interception proceed "in accordance with procedures and under guarantees prescribed by law."

Filing a Complaint

Legal complaints for unauthorized recording can only be filed by the victim, their legal guardian, or their heirs. The Public Prosecution may intervene in cases where no guardian exists or where conflicts of interest arise.

Victims can report cybercrimes, including unauthorized recording, to the General Directorate of Anti-Corruption and Economic and Electronic Security under the Ministry of Interior. For PDPL violations, complaints are filed directly with the Personal Data Protection Authority (pdp.gov.bh). The PDPA has enforcement powers that include issuing stop orders on unlawful processing, conducting investigations, and referring cases for criminal prosecution.

There is no mandatory reporting obligation for individuals or corporations who become aware of recording offenses. Reporting is voluntary unless the organization is subject to separate mandatory data breach notification requirements under the PDPL's ministerial resolutions.

Disclaimer

This article provides general legal information about recording and surveillance law in Bahrain. It does not constitute legal advice and does not create any attorney-client relationship. The laws discussed are cited as of May 15, 2026. Laws may change; always verify the current version of any statute through the Bahrain Legislation and Legal Opinion Commission (lloc.gov.bh) or the Personal Data Protection Authority (pdp.gov.bh). For advice specific to your situation, consult a lawyer licensed to practice in the Kingdom of Bahrain.

Frequently Asked Questions

Is it legal to record a phone call in Bahrain without the other person knowing?

No. Bahrain requires all-party consent for recording any communication. Recording a phone call without the knowledge and agreement of every participant violates Article 4 of the Cybercrime Law (Law No. 60/2014), which carries penalties of imprisonment and fines up to BHD 100,000 (approximately USD 265,000). The recording also violates the Penal Code privacy provisions (Articles 370 and 372, as amended by Law No. 25/2025) and the Personal Data Protection Law (Law No. 30/2018).

What is the maximum penalty for illegal recording in Bahrain?

The maximum fine under a single statute is BHD 100,000 (approximately USD 265,000) under Article 4 of the Cybercrime Law, combined with imprisonment. However, penalties stack across multiple laws. A person who records and shares a private conversation could face charges under the Cybercrime Law (BHD 100,000 fine), the Penal Code under Article 372 (up to five years prison and BHD 5,000 fine), and the PDPL (up to BHD 20,000 additional fine for individuals, BHD 40,000 for corporations), all from the same act.

Can my employer record my phone calls at work in Bahrain?

Only with your written, explicit consent. Under the PDPL (Law No. 30/2018), employers must obtain specific, informed consent before recording employees. This consent should be included in your employment contract or a separate recording policy. The employer must also notify the Personal Data Protection Authority and cannot retain recordings indefinitely. Employers who record calls without your knowledge and consent violate both the PDPL and the Penal Code.

Are CCTV cameras legal in Bahrain?

Yes, but with restrictions. CCTV systems require prior authorization from the Personal Data Protection Authority under Article 15 of the PDPL. Camera operators must inform people about the presence of cameras, store footage securely, use it only for its stated security purpose, and avoid sharing footage publicly without consent. Residential installations must respect neighbors' privacy and homeowners must inform neighbors about the cameras. Workplace CCTV also requires written employee consent under the PDPL consent standard.

Can a secretly recorded conversation be used as evidence in Bahrain?

Using a secretly recorded conversation in court is problematic because the recording itself is a criminal act under Article 4 of the Cybercrime Law and Articles 370 and 372 of the Penal Code. Presenting illegally obtained evidence could expose the person submitting it to prosecution. Bahraini courts generally do not admit evidence obtained through criminal activity. The person attempting to use such a recording risks facing charges that carry heavier penalties than whatever dispute they were trying to prove.

Is it legal to record police officers in Bahrain?

There is no statute in Bahrain expressly granting the right to record police officers or government officials. The general recording laws apply equally to recordings of police activity. Given that Bahrain has used cybercrime and public-order statutes to prosecute individuals for online expression critical of authorities, filming a police encounter carries significant legal risk under the Cybercrime Law and the Penal Code. Anyone considering recording police activity in Bahrain should consult a Bahraini lawyer before doing so.

Is deepfake content illegal in Bahrain?

As of May 2026, Bahrain does not have a deepfake-specific criminal statute. However, Shura Council members proposed adding Article 10 (bis) to the Cybercrime Law (Law No. 60/2014) in November 2025. The proposal would criminalize producing or falsifying audio-visual content to damage reputation or honor, with fines of BHD 3,000 to BHD 10,000 plus imprisonment. As of May 2026, the bill was at committee stage and not yet enacted. Existing law covers some deepfake scenarios: distribution of fake audio or video to damage reputation can engage the Penal Code's privacy and disclosure articles.

What is the PDPA adequacy list and does it affect recordings stored abroad?

The Personal Data Protection Authority published Resolution No. 42 of 2022 establishing an Adequacy List of 83 countries that meet Bahrain's data protection standards. Personal data, including voice recordings, can be transferred to those 83 countries without separate PDPA approval. Transfers to countries not on the list require either prior PDPA written permission or the explicit consent of the individual whose data is being transferred. Organizations that store call recordings in foreign data centers must verify the country is on the list or obtain a specific authorization.

What is voyeurism under Bahraini law and what are the penalties?

Bahrain's Penal Code, as amended by Law No. 25/2025, criminalizes recording individuals in private settings without their knowledge under Article 370. This covers eavesdropping on private conversations, filming people in intimate or compromising situations, and recording in locations where individuals have a reasonable expectation of privacy. The penalty for the basic offense is BHD 500 to BHD 1,000 plus imprisonment. Distributing the recording escalates the fine to BHD 1,000 to BHD 3,000. If the material relates to personal honor, Article 372 applies and penalties can reach five years imprisonment and a BHD 5,000 fine.