Two weeks to 15 September: The UAE financial licensing deadline.
DUBAI, UAE — ZIBCO Trade Intelligence | Regulatory Alert
On 16 September 2025, Federal Decree-Law No. 6 of 2025 came into force in the UAE. It repealed and replaced both the 2018 Central Bank Law and the 2023 Insurance Law, consolidating banking and insurance supervision under a single Central Bank of the UAE framework.
Entities that were already conducting financial or insurance activities without the proper authorisation were given one year to regularise their position. That year expires on 15 September 2026. The most consequential shift is jurisdictional. Insurance entities established in non-financial free zones are now expressly inside the CBUAE's perimeter and require either CBUAE authorisation or a No Objection Certificate.
That brings DMCC, JAFZA, RAKEZ, Meydan, SAIF Zone, IFZA and similar zones squarely into scope. Businesses that assumed their free zone licence was the whole of their regulatory story now have a second authority to answer to. DIFC and ADGM entities sit outside the CBUAE's direct remit, they are supervised by the DFSA and FSRA respectively. If you hold a DFSA or FSRA licence for the activity you are actually conducting, this does not apply to you.
The definition of a regulated financial activity under UAE law is considerably broader than most operators assume. The exposure rarely sits in a business that calls itself a financial services firm, but in activity that feels incidental to a main trading business:
Arranging insurance cover for clients or counterparties
Insurance brokerage, intermediation, agency or consultancy
Claims management
Trade credit or export credit insurance, or arranging it
Extending credit terms as a service, or introducing financing
Provision or arrangement of credit, including trade finance facilities
Banking, deposit-taking or payment services
Financial intermediation or advisory within the regulated perimeter
For a commodity trader, an agri-exporter or a logistics operator moving goods between Harare and Jebel Ali, several of these are ordinary commercial practice. That is precisely the problem because ordinary commercial practice is not a defence. And to be unambiguous about a point we see misunderstood often: holding a valid free zone trade licence for a related activity does not authorise regulated financial activity. These are two separate permissions from two separate authorities. The penalties for unlicensed financial activity under the new law run to imprisonment and fines between AED 50,000 and AED 500 million.
What to do before 15 September
Obtain specialist UAE regulatory legal advice on whether your current activities require authorisation.
Where authorisation is required, engage the CBUAE on the regularisation route, a licence, an NOC, or restructuring the activity.
Where activity can be brought outside the regulated perimeter, document the change and take advice confirming it.
Where DIFC or ADGM is the correct home rather than a non-financial free zone, begin that process and inform the CBUAE of your intention.
Contact ZIBCO for introductions to UAE regulatory counsel experienced in this area.
What the Council is doing
ZIBCO is seeking clarification from the CBUAE on the position of entities that regularise after the deadline, and a contact point for member queries. We are also making introductions to specialist UAE regulatory counsel for members who request them.
If this may apply to you, contact the Council now rather than after the deadline. Regularisation takes time, and demonstrated engagement with the regulator before 15 September is a materially different position to be in than discovery afterwards.
Drop us an email on info@zimbusinesscouncil-uae.org.
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