October 2025
On 16 September 2025, Federal Decree-Law 6 of 2025 (the New Banking Law) came into force replacing UAE Federal Decree-Law 14 of 2018. The New Banking Law represents a comprehensive modernisation of the UAE’s financial regulatory framework, expanding the supervisory remit of the Central Bank of the United Arab Emirates (CBUAE) to cover a broader range of financial and (for the first time) extending CBUAE remit to include technology service providers that support the provision of financial services in and from the UAE.
Licensed financial activities
The New Banking Law broadens the scope of what constitutes regulated financial services, and notably now includes:
– so called “open finance services”; and
– payment services using virtual assets.
Article 62 of the New Banking Law provides that any person carrying on, offering, or facilitating a licensed financial activity regardless of the technology or platform used is subject to CBUAE licensing. Article 62 therefore covers: (1) virtual assets payment tokens or other digital or physical instruments used in connection with the licensed activities, and (2) digital infrastructure providers, platforms, and decentralised applications that enable access to financial services such as payments, remittances, and investments.
The digital dirham and virtual-asset payments
The New Banking Law grants the CBUAE clear authority to issue and regulate the digital dirham and confirms its status as legal tender to provide legal certainty around the use of digital money in the UAE.
Implications for businesses
The New Banking Law significantly expands the regulatory landscape for banks, fintechs, and technology service providers involved in payments, tokenisation, and open finance. Entities operating or planning to operate in these sectors should assess whether their services fall within the CBUAE’s expanded regulatory perimeter. The New Banking Law contemplates a grace period of one year, meaning that businesses that need to adjust their license status to comply with the New Banking Law have till September 2026 to comply.
Given the one-year grace period granted under the New Banking Law, businesses are encouraged to begin their internal reviews and prepare for upcoming implementing regulations. Afridi & Angell is well placed to assist with any required internal gap analysis, as well as the licensing process contemplated by the New Banking Law. ■
