A licensed financial activity in the United Arab Emirates is any activity on the list in Article 61 of Federal Decree-Law No. 6 of 2025, carried on in or from within the State by a person the Central Bank has licensed for it. The list has ten entries, the Board of Directors of the Central Bank may add to or remove from it after consulting the Financial Stability Board, and Article 62 extends the same licensing jurisdiction to every medium and technology through which those activities are offered. The decree-law is recorded in the Central Bank rulebook as effective from 16 September 2025 and in force.
Symbol Consulting treats this decree-law as the entry gate rather than as one rulebook among several: it repealed the 2018 central bank law and the 2023 insurance law outright, and it set a single date by which everyone subject to it must have reconciled their position. This material describes the gate — the list, the authority, the applicant, the individual, and the boundary of the regime. It does not set out capital thresholds, which the law delegates to Board regulations, and it does not count how many institutions currently hold a licence.
The ten licensed financial activities and who can change the list
Article 61(1) lists the activities that require a Central Bank licence. The list runs from deposit-taking to insurance and is written to cover both conventional and Shari’ah-compliant forms of the same business, so the compliant version of an activity is not a separate category but the same entry read differently (per Federal Decree-Law No. 6 of 2025, as published in the CBUAE Rulebook, as of 22 August 2026).
| Entry in Article 61(1) | What it covers on its face |
|---|---|
| Deposits | Taking deposits of all types, including Shari’ah-compliant deposits |
| Credit | Providing credit facilities of all types |
| Funding | Providing funding facilities of all types, including Shari’ah-compliant funding |
| Open finance | Providing open finance services |
| Exchange and transfer | Currency exchange and money transfer, including instant transfer services |
| Virtual asset payments | Providing payment services using Virtual Assets |
| Stored value and retail payments | Stored value services, retail payments and digital money services |
| Distribution | Arranging, promoting and marketing for licensed financial activities |
| Principal dealing | Acting as principal in financial products affecting the institution’s own position |
| Insurance | Insurance, reinsurance and insurance-related professions, including Takaful |
Two clauses of the same article control how the list moves. Article 61(2) lets the Board classify and define the activities and the practices attached to them, and add, delete or amend entries after consulting the Financial Stability Board in the State. Article 61(3) points the other way: an institution that wants to carry on an activity licensed by a regulator inside or outside the State, or in a financial free zone, other than the activities on this list, must obtain Central Bank approval before it obtains that other licence.
Article 60 sets what the list means in practice. Licensed financial activities may only be carried on in or from within the State by licensed persons; promotion of those activities and of financial products may only be carried on in or from the State in accordance with the decree-law, and promotion is defined broadly as any form of communication, by any means, aimed at inviting or offering to enter into a transaction. A licensed institution must stay within the scope of its own licence, and no person may present itself as a licensed institution when it is not.
The Central Bank as licensing authority: the decision clock
An application is filed under Article 63, and the Board issues the regulations that set the conditions attached to it, including fit and proper criteria, minimum capital requirements, the resources needed for the activity, and control and monitoring systems. The Central Bank may add further requirements at its own discretion where it considers this necessary to safeguard the public interest.
Article 64 puts a clock on the answer, and its second sentence is the one worth reading twice. The decision on a licensing application, or on an extension of its scope, is to be taken within a period not exceeding sixty working days from the date on which all conditions and requirements are met. The expiry of that period without a response constitutes an implicit rejection of the request. Silence is refusal, not approval.
Two further limits sit alongside it. The Central Bank may reject an application on the basis of the capacity of the financial sector in the State and the needs of the local market, and a decision on that ground is final and not subject to appeal before the Grievances and Appeals Committee. And the applicant is to be notified officially of the decision within a period not exceeding twenty working days from the date the decision is issued.
Article 68 adds a step that is easy to miss between the licence and the first transaction. An electronic Register of Licensed Financial Institutions is kept at the Central Bank, licensing decisions are published in the Official Gazette, and the register is published on the Central Bank website. A licensed institution may not commence any licensed financial activity until its name has been entered in that register.
The applicant: legal form, ownership and the sixty percent floor
Article 69 fixes the corporate form. Banks and reinsurance and insurance companies take the form of public joint-stock companies, unless their incorporating law or decree permits otherwise; branches of foreign banks, specialised banks and branches of foreign insurance and reinsurance companies operating in the State are exempt on the rules the Board sets. Other financial institutions may be joint-stock companies or limited liability companies.
Article 71 fixes ownership, and it does so with a hard floor for one category. For banks incorporated in the State, the Board determines the conditions and controls for shareholding and ownership in capital, and in all cases the national shareholding shall not be less than sixty percent. For insurance and reinsurance companies and for other financial institutions incorporated in the State, the article leaves the conditions to the Board without naming a figure.
Capital itself is not in the decree-law. Article 70 requires the Board to establish regulations on minimum capital, on the conditions and instances of increase or decrease, on risk-based capital requirements and on what happens in the event of a shortfall. Any figure quoted as the minimum capital for a UAE financial licence therefore comes from a regulation, not from the law, and has to be traced to that regulation before it is relied on.
Two adjacent articles complete the corporate picture. Article 72 requires a licence for any institution established outside the State or in a financial free zone to run a representative office within the State. Article 73 requires prior Central Bank approval for amendments to the memorandum or articles of association, with a decision due within fifteen working days of submission and a final Board decision where the applicant objects to a refusal.
The individual: designated functions need their own authorisation
The licence covers the institution. Article 107 covers the people inside it. The Board may specify by regulation which functions are designated functions subject to Central Bank authorisation, and which individuals must obtain that authorisation, including the fit and proper conditions and the cases in which those conditions are waived.
Without prejudice to that power, the article states that designated functions include those carried on by members of the boards of directors of licensed financial institutions, by their chief executive officers, and by other authorised individuals. No individual may undertake a designated function without prior Central Bank authorisation, the institution must take all measures to ensure none of its officers or representatives does so, an authorised individual must stay within the limits stated in the authorisation, and no individual may present himself as an authorised individual unless authorised.
The consequence of ignoring this is set out on the penalty side. Article 178 provides for imprisonment of not less than one year and a fine of not less than AED 500,000 for violating Article 107, with an additional daily fine of AED 50,000 for each day of continuing breach, capped in total at AED 10,000,000.
Where the regime stops, and where it deliberately does not
Article 2 draws the outer boundary in a single sentence: the decree-law applies to the Central Bank, financial institutions, insurance business, financial activities and the persons subject to it, and does not apply to the financial free zones in the State or to financial institutions regulated by the authorities of those zones. An entity regulated inside such a zone is outside this law and inside its own zone framework.
Article 62 pushes in the opposite direction on technology. Any person carrying on, offering, issuing or facilitating a licensed financial activity, directly or indirectly and regardless of the medium, technology or form employed, falls under the licensing, regulatory and oversight jurisdiction of the Central Bank. The article names virtual asset payment tokens, decentralised finance and other emerging technology, and it names the offering or operation of platforms, decentralised applications, protocols and technological infrastructure that facilitate, intermediate or enable payments, credit, deposits, money exchange, remittances or investment services.
The penalty attached to operating outside the gate is wide by design. Article 170 provides for imprisonment and a fine of not less than AED 50,000 and not more than AED 500,000,000, or either of those, for carrying on an activity under Article 61 without a licence or authorisation. Article 177 attaches a fine of not less than AED 500,000 and not more than AED 10,000,000 to breaches of the restriction on the words «Bank» and «Masraf» in Article 67 and to breaches of Article 121 on branches.
Two regulations that show how an entry is filled in
The list in Article 61 is short because the detail lives in regulations. Two of them, both in the Central Bank rulebook, show what an entry becomes once it is written out, and they also show that the rulebook has to be read with its status line rather than by title alone.
The Payment Token Services Regulation is recorded as C 2/2024, effective from 31 August 2024, and in force. It lays down the rules and conditions for granting a licence or a registration for the provision of payment token services, and it splits those services into three categories: payment token issuance, payment token conversion, and payment token custody and transfer (per the Payment Token Services Regulation, CBUAE Rulebook, as of 22 August 2026).
The Open Finance Regulation is recorded as C 7/2023, effective from 15 April 2024, and its status line reads repealed. The page states that the circular has been repealed and replaced by Circular No. 03/2025 regarding Open Finance Regulation. The replacement is named but was not reproduced in that section of the rulebook on the date checked, so the operative text a licensee has to work from is not the one carried there (per the Open Finance Regulation, CBUAE Rulebook, as of 22 August 2026).
What the repealed text does show is the shape of the obligation: an open finance framework made up of a trust framework, an API hub and common infrastructural services, with participation mandatory for all licensees in respect of the products and services within its scope. Article 183 of the decree-law keeps regulations issued under the repealed 2018 and 2023 laws in force until replacements are issued, which is why a rulebook page can carry an older instrument and still matter.
The reconciliation period closes on 16 September 2026
Article 184 gives all agencies and persons subject to the decree-law one year from its entry into force to reconcile their positions with its provisions, and allows the Board to extend that period as it deems appropriate. The rulebook records entry into force as 16 September 2025, which puts the unextended limit at 16 September 2026 — twelve days after this material is published.
No decision extending that period was located on the Central Bank site as of 22 August 2026, which is a statement about what was found and not a prediction that no extension will come. Article 185 makes the stakes of the date plain: it repeals Decretal Federal Law No. 14 of 2018 and Federal Decree-Law No. 48 of 2023 outright, so the reconciliation is against a framework that has already replaced the one many internal documents still cite (per the Legislation section of the Central Bank of the UAE, as of 22 August 2026).
What to check before the date
The following checks all resolve against provisions quoted above, and each of them can be answered from documents an institution already holds rather than from an external opinion. They are ordered from the question that is cheapest to answer to the one that takes longest, and none of them depends on a regulation that has yet to be issued.
- Whether every activity actually carried on maps to an entry in Article 61(1), including activities carried on only through a platform, an application or a protocol, which Article 62 brings inside the same jurisdiction.
- Whether the name and the marketing material stay clear of the words «Bank» and «Masraf» where Article 67 does not permit them, and whether any communication meets the broad definition of promotion in Article 60(3).
- Whether the entry in the Register of Licensed Financial Institutions covers the activity in fact being carried on, since Article 68(2) ties the start of activity to the register rather than to the licence decision.
- Whether every board member, chief executive and other authorised individual holds a current Central Bank authorisation for the designated function performed, as Article 107 requires.
- Whether internal policies and contracts still cite Decretal Federal Law No. 14 of 2018 or Federal Decree-Law No. 48 of 2023, both repealed by Article 185, and whether the regulations they rely on have since been replaced under Article 183.
- Whether shareholding in a bank incorporated in the State meets the sixty percent national floor in Article 71(1), and whether any planned change in a controlling interest has been put to the Central Bank first.
This material is a general analysis of published rules. It is not legal, tax, immigration or financial advice.