New rules governing delivery platforms are drawing attention to the records behind each sale, from commissions and refunds to the money that eventually reaches a restaurant’s account.
A delivered meal produces more than a receipt. For the restaurant that prepared it, there is also a financial record: the order value, any deductions, a possible refund and the amount eventually paid by the platform. Kuwait’s latest delivery regulations have brought that less visible side of the business into sharper focus.
Ministerial Decision No. 109 of 2026, published in July, introduced a framework covering the relationship between intermediary platforms, merchants and consumers. The September 1 deadline for aligning existing arrangements has now passed, subject to an exception for contracts whose commissions already fall within the prescribed ceiling.
Alongside the widely discussed fee limits, the framework addresses access to financial information. That makes the connection between a delivery app and a restaurant’s own records a business issue extending well beyond getting an order into the kitchen.
The decision also replaced the earlier regulation dealing with restaurant and ready-made food delivery. Its broader coverage reflects a distinction in the rules themselves: the regulated relationship is between an intermediary platform and a licensed merchant, rather than being confined to the sale of meals.
The numbers behind the order
Under the framework, platform charges to merchants are capped at 17 per cent of an order’s value before the consumer’s delivery fee, falling to 10 per cent where the merchant handles delivery. As Wefaq Law Firm explains in its summary of the regulation, the ceiling covers several categories of charges, including advertising and paid placement. Consumer delivery fees are capped at KD1 per order.
The arithmetic is straightforward; interpreting a settlement requires more detail. On a hypothetical KD10 order, 17 per cent represents KD1.70. That calculation alone says nothing about the restaurant’s ingredient costs, packaging, staffing or premises. A ceiling on platform charges therefore cannot be read as a guarantee of a particular restaurant margin.
It also makes the distinction between sales and receipts important. A record showing that a meal was sold answers one question. A record explaining the amount transferred to the restaurant, and the deductions behind it, answers another. Comparing the two is the basis of checking whether a settlement matches the agreed terms.
Where the software meets the platform
One local example of that connection is TMBill’s work with Keeta. In a public company post, TMBill described a meeting between its Kuwait team, identified as Huzefa and Hakim, and Ebrahim Hameed, identified in the post as Keeta’s head of small and medium-sized businesses in Kuwait.
The company said the discussion concerned expanding their partnership in the Kuwait market and described an existing integration with Keeta for online order management. The announcement documents a relationship between the two businesses; it does not establish how many Kuwaiti restaurants use the connection or quantify its effect on their operations.
TMBill, whose Kuwait team uses the Instagram account @softwareskuwait, operates in the part of restaurant technology that sits behind the customer-facing app. Its published software offering includes billing, inventory, accounting and delivery-platform integrations.
The distinction between these functions matters. Transferring an order into a restaurant system is one task; reconciling the eventual payment is another. An integration announcement should not, by itself, be treated as evidence that every deduction, refund or settlement is automatically reconciled. Those are separate capabilities requiring their own evidence.
Records become part of the relationship
According to GLA & Company’s analysis, the regulation requires platforms to supply merchants with free financial records and reports that allow orders and payments to be tracked. It also provides for settlement within 14 days of fulfilment and access to usable data when a contractual relationship ends.
Those provisions address an important distinction: access to customers through a platform does not necessarily give a restaurant a complete, portable account of its own trading activity.
Consider a restaurant comparing a platform report with its internal sales records. An order cancelled before preparation, a completed sale and a refunded purchase have different financial consequences. A single total cannot explain all three. The useful information is the sequence of entries that shows how the final payment was calculated.
Data access also matters when a relationship changes. Ending a platform contract does not remove the need to explain earlier transactions. The ability to retrieve usable records gives the merchant a basis for reviewing that history after the commercial relationship has ended.
A court ruling changes the enforcement picture
The framework has already faced a legal challenge. On September 27, Kuwait’s Administrative Court annulled Article 15, which established the regulation’s administrative penalties, in a case brought by Talabat.
Wefaq’s subsequent legal update says the reported judgment concerns that penalties provision, while the commission ceilings and contractual rules remain. It also notes that the first-instance ruling is open to appeal.
That distinction matters for any account of what changed. The judgment should not be described as abolishing the entire delivery framework. Equally, the original list of sanctions should not be repeated as though the court had made no ruling.
For restaurant operators, the practical question remains specific: can each completed order be followed through to the amount received? The regulations, platform contracts and software connections all touch that question. Its answer lies in the transaction record, where the price paid by a customer becomes the revenue retained by the business that made the meal.
