UAE Trends and Developments Contributed by: Muthmainur Rahman and Kajen Subramoney, Ankura Consulting Group LLC
ance (Q1 2026) – “Shadow agents” and AI-driven data leaks are the top emerging risks for 2026. To address these, organisations should evaluate and deploy cloud access security broker (CASB) solutions to block unauthorised AI ingestion and establish a cross-functional AI board to govern the use of AI, including the deployment of “agentic AI.” • Localise data strategy (ongoing) – The PDPL, DIFC, and ADGM laws heighten liability for cross-border transfers. Organisations should review cloud con - tracts to ensure strict data residency requirements are in place and ensure that “adequacy assess - ments” for DIFC transfers are thoroughly docu - mented and up to date. • Adopt phishing-resistant identity (Q2 2026) – Phishing attacks continue to surge, and AI voice clones are increasingly capable of defeating stand - ard multi-factor authentication (MFA). To address this, privileged users such as administrators and the C-Suite should transition to passwordless protocols like FIDO2 Security Keys, which rely on biometrics or external hardware keys for authenti - cation. This approach offers significantly stronger protection against the latest wave of AI-enabled phishing techniques compared to traditional MFA. • Prepare for private litigation – The DIFC Amend - ment Law No 1 allows claims for “distress,” making it essential for organisations to update their inci - dent response plans (IRP) to include specific legal workflows for mitigating “non-financial damage” claims. Fast, transparent communication after a breach is now a critical legal defence strategy.
By implementing the strategic recommendations outlined above, specifically the urgent eradication of legacy digital debt and the governance of agentic AI, organisations can pivot from a reactive defence pos - ture to a stable state of sovereign assurance. In doing so, they not only protect their own licences to operate under the new strict liability regimes of the CBUAE, DIFC and ADGM, but also actively contribute to the UAE’s ambition to become the world’s most secure digital economy.
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