UAE Trends and Developments Contributed by: Irina Heaver and Zainab Kamran, NeosLegal
around 6,300 BTC remaining in government-linked wallets, placing the UAE among the largest sovereign Bitcoin holders globally. On the allocation side, Q4 2025 13F filings disclosed combined holdings of over USD1 billion in Black- Rock’s iShares Bitcoin Trust (IBIT) across two Abu Dhabi sovereign vehicles, namely Mubadala Invest- ment Company, with 12.7 million shares valued at approximately USD631 million, and Al Warda Invest- ments, an Abu Dhabi Investment Council vehicle, with 8.2 million shares valued at approximately USD408 million. These positions reflect a deliberate, layered approach to digital assets, integrating energy infrastructure, sovereign capital and long-term strategic positioning. Stablecoins integration in the UAE ’ s economy The UAE has rapidly built one of the most diverse reg- ulated stablecoin markets globally, anchored by three complementary frameworks divided along currency lines: the CBUAE’s Payment Token Services Regula- tion (PTSR), introduced in June 2024, which governs the issuance of AED-backed payment tokens and the registration of foreign-currency-backed tokens for use within the UAE; ADGM’s Fiat-Referenced Tokens (FRT) framework, supervised by the FSRA, which regulates the issuance of non-AED fiat-referenced tokens by entities licensed in the Abu Dhabi financial free zone; and VARA’s Fiat-Referenced Virtual Asset rules under its Virtual Assets Issuance Rulebook, which permit Dubai-licensed issuers to issue non-AED fiat-refer- enced tokens. The first regulated AED stablecoin, AE Coin, issued by AED Stablecoin LLC, received in-principle CBUAE approval in October 2024. Throughout 2025 and into 2026, the issuer base expanded materially: in November 2025, Zand, the UAE’s first fully digital bank, secured CBUAE approval to launch Zand AED, a regulated multi-chain AED stablecoin on public blockchains; in January 2026, RAKBANK became the first conventional UAE bank to receive in-principle CBUAE approval for an AED-backed stablecoin under the PTSR, with audited smart contracts and real-time reserve attestations; on 29 January 2026, the CBUAE registered USDU, issued by ADGM-regulated Univer-
sal Digital, as the first foreign payment token under the PTSR, providing the first compliant USD settle- ment option for digital-asset transactions in the UAE, with reserves held 1:1 across Emirates NBD, Mashreq and Mbank; and in May 2026, the CBUAE approved DDSC, a dirham-backed stablecoin developed by IHC, Sirius International Holding and First Abu Dhabi Bank operating on the UAE-built ADI Chain, intended for institutional settlement, cross-border payments and trade finance. In parallel, ADGM’s Fiat-Referenced Tokens frame- work, supervised by the FSRA, continues to operate as a distinct regulated activity within the financial free zone, requiring full reserve backing, rigorous govern- ance and operational transparency, with Paxos Issu- ance MENA and Universal Digital among the licensed FRT issuers. The CBUAE has also continued the phased rollout of its own retail and wholesale Central Bank Digital Cur- rency, the Digital Dirham, with a federal law passed in November 2025 granting the Digital Dirham equal legal status to physical cash. Together, these devel- opments have rapidly assembled one of the most diverse regulated stablecoin markets globally, inte- grating AED-pegged tokens, foreign-currency-pegged tokens and a sovereign CBDC within a single coherent supervisory architecture. Focus on artificial intelligence The UAE has positioned itself at the forefront of AI adoption, recognising AI’s transformative potential across various sectors, including its synergies with the blockchain and virtual assets industry. The UAE National Strategy for Artificial Intelligence 2031 sets out an ambitious plan to position the country as a glob- al leader in AI by 2031, in alignment with the broader UAE Centennial 2071 vision. The strategy targets an additional AED335 billion in economic contribution, by promoting the adoption of AI across key sectors such as energy, logistics, tourism, healthcare and cyber- security, and is supported by initiatives including the Dubai AI Campus in DIFC and the DMCC AI Centre. During 2025 and 2026, the strategy has moved from policy to visible execution. The convergence between AI and digital assets is increasingly explicit, with
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