UAE Central Bank Points New Central Bank Law Consolidating Financial Sector Regulation

Client Alert  |  November 13, 2025

This replace summarises essentially the most vital reforms launched by the New CBUAE Law and the implications for monetary establishments working within the UAE.

On 15 September 2025, the Federal-Decree Law No. 6 of 2025 Regarding the Central Bank Regulation of Financial Institutions and Activities and Insurance Business (the New CBUAE Law) was issued within the Official Gazette and have become legally efficient as of 16 September 2025 (Art.188). The New CBUAE Law repeals and replaces each Federal Decree Law No. 14 of 2018 (the “2018 Law”), which beforehand ruled the Central Bank of the United Arab Emirates (CBUAE) and onshore monetary establishments, and Federal Decree Law No. 48 of 2023, which regulated insurance coverage actions.

The New CBUAE Law represents a major overhaul of the monetary regulatory framework of the United Arab Emirates (UAE). It consolidates the regulation of banks, cost service suppliers, and insurers beneath a single legislative umbrella, introduces new licensing necessities for emerging-technology suppliers, and imposes enhanced penalty and enforcement provisions.

We have summarised under essentially the most vital reforms launched by the New CBUAE Law and the implications for monetary establishments working within the UAE.

Criminal Sanctions Introduced for Unlicensed Financial Activities

Under the 2018 Law, the prohibition on finishing up monetary actions with no license lacked corresponding sanctions. While the earlier legislation established that no individual may interact in regulated monetary actions with no license from the CBUAE, it didn’t specify felony penalties for breaches. The New CBUAE Law addresses this and the strategy is now in line with what we see in different jurisdictions, the place partaking in regulated monetary actions with out authorisation constitutes a felony offence.

Article 60 reaffirms the overall prohibition on conducting any regulated actions with out an applicable license. It gives that solely individuals or entities duly licensed in accordance with the Law, along with its implementing rules and choices, could interact in or provide such actions throughout the State.

The key improvement lies in Article 170, which now expressly criminalises the conduct of finishing up unlicensed monetary actions. Article 168 gives that, with out prejudice to different penalties or measures, the CBUAE could impose administrative penalties and fines the place an individual is engaged in any of the actions specified within the legislation with no license.

Article 170 introduces a brand new felony penalty for such conduct. Persons that interact in a licensed monetary exercise with no license could face imprisonment and/or a advantageous between AED 50,000 and AED 500 million, representing a major enhance over the penalties accessible beneath the 2018 Law. This is a notable improvement, and we may even see elevated enforcement in mild of this new framework.  Importantly, this transformation displays the UAE’s dedication to strengthening the deterrent framework for unlicensed monetary actions.

The prohibition on partaking in monetary actions with no license applies to these entities working outdoors the UAE and to these working within the monetary free zones such because the Dubai International Finance Centre and Abu Dhabi Global Market. Accordingly, any agency focusing on UAE retail prospects — even when licensed by a monetary free zone regulator— could also be topic to felony sanctions beneath the Federal framework. Pursuant to Article 4 of Federal Decree Law No. 8 of 2004 such monetary free zones stay topic to all federal legal guidelines (except federal civil and business legal guidelines) and the New CBUAE Law shall take priority within the occasion of any battle.

Express Prohibition on Unlicensed Communications Extends CBUAE’s Regulatory Perimeter

The New CBUAE Law additionally introduces some fully new provisions, considered one of which is an specific prohibition on conducting, or speaking in relation to, licensed monetary actions with out correct authorisation. This is a major improvement that materially broadens the CBUAE’s regulatory perimeter to incorporate promotional and advertising and marketing communications directed at UAE residents.

By advantage of Article 61(1)(h), promoting, advertising and marketing or selling a licensable monetary exercise is expressly outlined as a licensed monetary exercise in its personal proper. Accordingly, any individual partaking in such actions should maintain an applicable license from the CBUAE. Article 60(3) reinforces this precept by stipulating that licensed monetary actions and merchandise could solely be provided or performed from throughout the UAE in compliance with the provisions of the Law and its implementing rules.

The New CBUAE Law defines “communication” broadly, encompassing any type of communication or invitation, together with by phone, fax, electronic mail, web or cell phone, in addition to invites to enter into or conclude transactions referring to licensed actions.

Given this expansive definition, the New CBUAE Law captures not solely conduct going down throughout the UAE, but additionally communications comprised of overseas to individuals within the UAE. As a end result, unlicensed overseas corporations that market or promote monetary services or products to UAE residents, whether or not via on-line platforms or different digital means, now fall throughout the regulatory perimeter and danger breaching the New CBUAE Law’s prohibitions. Firms working outdoors the UAE ought to due to this fact assess whether or not their distant or on-line communications may represent the carrying on of a licensed exercise into the State and whether or not native licensing or authorisation is required.

Regulatory Perimeter Extended to Virtual Assets and Facilitation of Decentralised Platforms

Another fully new provision is Article 62, which expands the CBUAE’s regulatory perimeter to seize actions performed via rising applied sciences, together with digital property and decentralised finance (DeFi) fashions.

Article 62 extends the scope of the licensing framework by offering that, topic to current licensed actions, any one that engages in, presents, points, or facilitates a licensed monetary exercise – by any means or via any medium – is topic to the licensing, regulatory, and supervisory authority of the CBUAE.

Importantly, this goes past merely prohibiting the finishing up of regulated actions with no license; it now expressly captures the facilitation of such actions, both immediately or not directly. This implies that entities offering technological infrastructure, platforms, protocols, or digital instruments that allow or assist the supply of monetary companies could themselves fall throughout the regulatory perimeter, even when they don’t immediately provide the underlying monetary services or products.

By explicitly capturing facilitation, the New CBUAE Law ensures that corporations can not keep away from regulatory oversight by characterising themselves solely as know-how suppliers. Going ahead, know-how corporations, cost processors, and DeFi operators might want to consider whether or not their enterprise fashions may very well be deemed to facilitate licensed actions and due to this fact set off a licensing requirement beneath the brand new framework.

Expanded Obligations for Licensed Financial Institutions (LFIs)

The New CBUAE Law additionally units out an built-in framework of prudential, conduct, and client safety obligations for all LFIs.

Under Articles 114 and 130, LFIs should adjust to all rules, requirements, and circulars issued by the CBUAE, together with these governing capital adequacy, liquidity, governance, danger administration, and related-party exposures. The CBUAE has authority to problem detailed governance and fit-and-proper guidelines for board members and senior administration, strengthening accountability and oversight throughout the sector. The New CBUAE Law makes clear that the CBUAE could take all crucial measures and procedures and use all means crucial to make sure the right functioning of LFIs.

On the conduct aspect, Articles 148 via 152 introduce a devoted client safety regime, requiring LFIs to deal with buyer complaints via impartial channels, preserve clear product disclosures, implement anti-fraud measures, and promote monetary literacy and inclusion.

Articles 183 and 184 affirm that through the transitional interval, current prudential and conduct rules issued beneath the repealed 2018 Law proceed to use till changed, guaranteeing regulatory continuity whereas the CBUAE phases in new requirements beneath the up to date framework (please check with “Transitional Provisions and Legal Continuity” under).

Enhanced Resolution and Recovery Framework

Articles 142 via 146 of the New CBUAE Law introduce a complete decision and restoration regime for LFIs and insurers, positioning the UAE according to main worldwide requirements on monetary stability and systemic danger mitigation. Under these provisions, the CBUAE is empowered to intervene early in instances of monetary misery, impose corrective measures, and, the place crucial, provoke decision proceedings via a newly established Settlement and Resolution Authority. The framework gives the CBUAE with in depth instruments, starting from administration alternative and capital restructuring to the switch or sale of property and liabilities, with a view to make sure the orderly continuity of important features and shield depositors and policyholders. Article 144 codifies a transparent creditor precedence and loss allocation system while Articles 145 to 146 set up transparency obligations and oversight till full wind down. Any decision, dissolution, or liquidation choice requires public notification via official channels, together with publication within the Official Gazette and native newspapers, with a minimal three-month discover interval to permit prospects and collectors to safeguard their pursuits. The provisions additionally mandate the appointment and disclosure of the designated decision or liquidation administrator, who’s answerable for implementing the decision plan and coordinating with affected stakeholders. The CBUAE retains supervisory authority over establishments all through the decision and liquidation course of.

Collectively, these reforms mark a significant step towards a danger based mostly, internationally aligned decision framework that underpins confidence within the UAE’s monetary system.

Enforcement and Settlement

The New CBUAE Law introduces, for the primary time, a negotiated settlement mechanism throughout the CBUAE’s enforcement framework. Under Article 168(6), the CBUAE could, at its discretion, enter into settlements with regulated entities or people in respect of administrative penalties and fines, in accordance with procedures and rules to be issued in the end. We anticipate that the implementing rules (as soon as issued) will set out the factors, documentation, and approval course of for such settlements.

This provision creates a proper authorized foundation for the CBUAE to resolve supervisory breaches via proportionate, risk-based settlements, quite than solely via the imposition of fastened penalties. The new strategy aligns the UAE’s enforcement framework with worldwide greatest follow, permitting the regulator to recognise cooperation, remedial motion, and the size of impression when figuring out outcomes, whereas nonetheless preserving regulatory deterrence.

Transitional Provisions and Legal Continuity

Articles 183 to 185 of the New CBUAE Law set up a transparent framework to make sure regulatory continuity and an orderly transition from the repealed laws. All rules, circulars, pointers and choices issued beneath the earlier frameworks shall stay in full drive and impact till expressly changed by new devices issued beneath the New CBUAE Law, with current definitions and technical phrases retaining their which means through the interim interval. Regulated establishments should regularise their place inside one 12 months from the Law’s efficient date to align with the brand new necessities (though observe that this one 12 months interval is extendable on the CBUAE’s discretion). At the identical time, any provisions beneath the previous framework which can be inconsistent with the New CBUAE Law are repealed.

Collectively, these articles safeguard authorized certainty and market stability whereas the CBUAE implements the brand new regulatory framework and points up to date prudential and conduct rules.

Conclusion

Entities captured beneath the New CBUAE Law have one 12 months from 16 September 2025 to carry their operations into compliance, and this one 12 months could also be prolonged as CBUAE deems applicable. The new framework marks a major shift within the UAE’s regulatory panorama, underscoring that the CBUAE and UAE authorities are taking enforcement and supervision severely throughout all segments of the monetary sector, starting from unlicensed monetary actions to rising applied sciences.

If you’ve got any considerations about how the New CBUAE Law could have an effect on your corporation, please contact your common Gibson Dunn advisor or any member of our UAE workforce.

The following Gibson Dunn attorneys ready this replace: Renad Younes, Mohammed Bashir, Sameera Kimatrai, Aliya Padhani, and Holly Alderton.

Gibson Dunn’s attorneys can be found to help in addressing any questions you might have concerning these developments. If you want to talk about any of the issues set out above, please contact any member of Gibson Dunn’s Financial Regulatory workforce, together with the next members in Dubai:

Sameera Kimatrai (+971 4 318 4616, [email protected])

Aliya Padhani (+971 4 318 4625, [email protected])

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