ADOC shadow billing is the mandatory test phase for the Abu Dhabi Outpatient Classification (ADOC), the new payment system for outpatient care. Since 1 July 2026, ADOC-classified claims data must be submitted through Shafafiya, without affecting usual claims settlement, payment, or approvals. Under DOH Circular 76/2026, the phase covers DOH-licensed outpatient providers, insurers, and TPAs, except dental providers and pharmacies. ADOC is scheduled to become the primary reimbursement mechanism for outpatient services on 1 January 2027.
For the ADOC Abu Dhabi rollout, this is the stage built for finding problems. Coding gaps and classification mistakes found now can be fixed before official implementation.
This guide covers who must take part in ADOC shadow billing, who is exempt, the key dates, what to submit, and how to prepare before go-live. Every date and rule comes from Circular 76/2026 and the DOH Shafafiya Prices page.
What Is ADOC Shadow Billing Under Circular 76/2026?
ADOC shadow billing is a trial run of Abu Dhabi’s new outpatient payment system. Claims data is classified under ADOC and submitted through Shafafiya, but the phase must not affect usual claims settlement, payment, or approvals. Circular 76/2026, issued by the Department of Health on 14 May 2026, made this phase mandatory from 1 July 2026.
The circular builds on an earlier DOH circular, 226/2024. It moves ADOC to its next step as the payment method for outpatient care, as part of the DOH’s wider shift toward value-based healthcare.
The circular sets three aims for the shadow phase:
- Test readiness. Check that the systems and processes of providers, insurers and TPAs are ready for ADOC.
- Standardise submission. Bring claims submission into one consistent process and confirm that classification and calculation are accurate.
- Fix problems early. Find and resolve issues before ADOC is officially implemented.
Shadow claims must follow the ADOC Definitions Manual and the approved calculation rules published on the DOH Shafafiya Prices page. For billing teams, this makes the period a live test of coding and documentation, without changing current payments.
Who Must Submit ADOC Shadow Billing Data?
ADOC shadow billing is mandatory for outpatient healthcare providers, health insurance companies, and third-party administrators (TPAs) licensed by the DOH to operate in the health insurance field. Dental service providers and pharmacies are the only exclusions the DOH names for this phase.
Outpatient providers
All outpatient healthcare providers licensed by the DOH in the health insurance field fall within the ADOC Abu Dhabi shadow phase. The phase requires shadow billing data to be submitted through Shafafiya. Taking part is not optional, since the DOH describes the phase as mandatory.
Insurers and TPAs
Health insurance companies and TPAs are also in scope. The phase tests their systems and processes for ADOC, not only those of providers. The DOH has also told them to keep normal claims settlement, payment, and approvals running as usual throughout shadow billing.
Are dental providers and pharmacies exempt?
Yes, for the shadow phase. The DOH excludes dental service providers and pharmacies from mandatory shadow billing. The circular gives no reason for this. It also does not say whether the exclusion continues after ADOC goes live on 1 January 2027, so dental and pharmacy operators should confirm their position directly with DOH Health System Financing Regulation.
ADOC Abu Dhabi Timeline: Key Dates From July 2026 to January 2027
Shadow billing started on 1 July 2026, and ADOC is scheduled to become the primary reimbursement mechanism for outpatient services in Abu Dhabi on 1 January 2027. The months between those two dates are the shadow period, when ADOC data is submitted without affecting usual claims settlement, payment, or approvals.
| Date | What happens | Who it affects |
| 14 May 2026 | The DOH issued the circular announcing mandatory shadow billing | Providers, insurers and TPAs |
| May to June 2026 | The DOH planned to share more details on draft pricing and run orientation workshops on ADOC | Providers, insurers and TPAs |
| 1 July 2026 | Shadow billing data submission begins through Shafafiya, following the ADOC Definitions Manual and approved calculation rules | Outpatient providers, insurers and TPAs, except dental providers and pharmacies |
| July to December 2026 | Shadow period. Claims are settled, paid, and approved as usual | All in-scope parties |
| 1 January 2027 | ADOC is scheduled to become the primary reimbursement mechanism for outpatient services | Outpatient care across the emirate |
The ADOC January 2027 go-live is the date that matters most for revenue. From then, ADOC is scheduled to be the primary reimbursement mechanism for outpatient services, so coding or data problems left unfixed during shadow billing could start to affect reimbursement.
Pricing is also worth watching. The circular referred to draft pricing, so confirm the status and version of the price files on the Shafafiya Prices page before using them for financial planning.
What Must Be Submitted Through Shafafiya Shadow Billing?
Shafafiya shadow billing requires outpatient claims data to be classified under ADOC and submitted through the DOH Shafafiya platform. Submissions must follow the ADOC Definitions Manual and the approved calculation rules, both published on the DOH Shafafiya Prices page.
The ADOC v1.3 files on the Shafafiya Prices page
The DOH lists these files under its “Outpatient and Emergency Care Reimbursement Reform” heading:
- Rules and Materials for ADOC Shadow Billing
- ADOC v1.3 Definitions Manual
- ADOC v1.3 Counting Rules
- ADOC v1.3 Draft Claims & Adjudication Rules
- ADOC v1.3 Price List
- ADOC v1.3 P-Series Inclusions & Exclusions
The Definitions Manual is the one file the circular names directly for shadow submissions. Some files open through the Shafafiya portal and may ask for a login, so billing teams should confirm their access early.
How shadow data runs beside current claims
Shadow data does not replace your current billing. The DOH has told insurers and TPAs that shadow billing must not change normal claims settlement, payment or approvals. Today’s claims process therefore continues as usual.
The circular does not set out the technical format for shadow submissions. For those requirements, check the Rules and Materials for the ADOC Shadow Billing file or contact the DOH directly.
Why the file version matters
ADOC files carry version numbers, and the Prices page currently lists the v1.3 file set. The Prices page also lists a separate Mandatory Tariff ADOC Service Codes Update, so billing teams should check whether it affects their current ADOC coding tables. Before each ADOC shadow billing submission, check that your coding tables match the latest files on the Prices page. Otherwise, errors in shadow data may come from outdated files rather than real coding problems.
Does ADOC Shadow Billing Affect Claim Payments in 2026?
No. The DOH has instructed insurers and TPAs that shadow billing must not affect the usual processes for claims settlement, payment, or approvals. Throughout the shadow period, outpatient claims continue through these processes as normal.
The shadow data serves a different purpose. The DOH uses this phase to test system readiness, standardise claims submission, and check classification and calculation accuracy before go-live.
The position changes on 1 January 2027. From that date, ADOC is scheduled to become the primary reimbursement mechanism for outpatient services in Abu Dhabi.
If a payer delays or questions a claim and links it to shadow billing, providers can point to the DOH instruction. They can raise the case with DOH Health System Financing Regulation at HealthSystemFinancing@doh.gov.ae.
How Should Providers Prepare for the ADOC January 2027 Go-Live?
Providers should use the rest of the shadow period to check coding against the ADOC v1.3 rules, estimate revenue under ADOC prices, and catch claim errors before submission. Problems found during ADOC shadow billing can be corrected before official implementation. Left unfixed, the same problems could affect reimbursement once ADOC goes live on 1 January 2027.
Check coding against the Definitions Manual and Counting Rules
Shadow submissions must follow the ADOC Definitions Manual, so it is the first document your coders should know well. Review a sample of recent outpatient claims against the Definitions Manual and the Counting Rules. Look for services recorded in the medical notes but missing from the claim, and for codes that do not match the documentation.
Share the findings with clinicians as well as coders. Many coding gaps start with incomplete documentation.
Estimate revenue using the ADOC v1.3 Price List
Map a typical month of outpatient activity to the ADOC v1.3 Price List and compare the result with what you are paid today. This shows which services or departments may gain or lose under ADOC. Treat the figures as estimates only. The circular referred to draft pricing, so confirm the status of the Price List and repeat the exercise whenever it is updated.
Validate claims before they reach Shafafiya
A short pre-submission routine can help catch avoidable errors:
- Check each claim against the Rules and Materials for the ADOC Shadow Billing file.
- Match codes to the latest ADOC service code files on the Prices page.
- If Shafafiya returns errors on shadow submissions, fix the underlying cause, not just the single claim.
- Confirm that your billing system or vendor can handle ADOC data well before 1 January 2027.
Where to Find Official ADOC Abu Dhabi Guidance
Official ADOC Abu Dhabi guidance comes from the Department of Health (DOH). The three main sources are the DOH Shafafiya Prices page, Circular 76/2026, and the DOH Health System Financing Regulation team.
- DOH Shafafiya Prices page. This holds the Rules and Materials for ADOC Shadow Billing and the full ADOC v1.3 file set. Check it regularly for amendments, replacement files, and tariff updates.
- Circular 76/2026. Dated 14 May 2026, it sets out the scope, exemptions, and key dates for Shafafiya shadow billing. It is listed on the DOH Circulars page.
- DOH Health System Financing Regulation. For questions the published files do not answer, the DOH directs inquiries to HealthSystemFinancing@doh.gov.ae.
Many vendors and consultants now publish ADOC summaries. Treat these as secondary. When a detail matters for a claim, confirm it against the latest files on the DOH Prices page.
ADOC Shadow Billing FAQs
Is ADOC shadow billing mandatory in Abu Dhabi?
Yes. Under Circular 76/2026, shadow billing for the Abu Dhabi Outpatient Classification became mandatory on 1 July 2026. It applies to outpatient healthcare providers, health insurance companies, and TPAs licensed by the DOH to operate in the health insurance field. Dental service providers and pharmacies are excluded.
Are dental clinics and pharmacies part of the shadow phase?
No. The DOH excludes dental service providers and pharmacies from the mandatory shadow phase. The circular does not say whether this exclusion continues after ADOC goes live on 1 January 2027, so these providers should confirm their position with the DOH.
What changes with the ADOC January 2027 go-live?
On 1 January 2027, ADOC is scheduled to become the primary reimbursement mechanism for outpatient services in the Emirate of Abu Dhabi. This marks the move from the shadow phase to official implementation.
Will shadow billing affect my insurance payments in 2026?
No. The DOH has instructed insurers and TPAs that shadow billing must not affect normal claims settlement, payment, or approvals. Outpatient claims in 2026 continue through these processes as normal.
Where can I download the ADOC v1.3 files?
The ADOC v1.3 files are published on the DOH Shafafiya Prices page, under the “Outpatient and Emergency Care Reimbursement Reform” heading. They include the Definitions Manual, Counting Rules, Draft Claims & Adjudication Rules, Price List, and P-Series Inclusions & Exclusions. Some files open through the Shafafiya portal and may ask for a login.
