UNITED ARAB EMIRATES Law and Practice Contributed by: Arnold Krutilins and Gabrielle Margerison (nee Lowe), White & Case LLP
1. Fintech Market 1.1 Evolution of the Fintech Market
2025 concerning the Capital Market Authority (the “CMA Law”), alongside Federal Decree-Law No (33) of 2025 concerning the Regulation of the Capital Market (the “Capital Markets Law”). In September 2025, Federal Decree-Law No (6) of 2025 regarding the Central Bank and Organisation of Financial Institutions and Activities (the “CBUAE Law”) came into effect, expressly expanding the scope of regulated activities to include, among other things, providing open finance services and payment services using virtual assets. In April 2024, the Central Bank of the UAE (the “CBUAE”) published two key regulations on open banking and fintech innovation. The first was the Open Finance Regulation, which introduced an “Open Finance Framework” in which CBUAE-licensed finan - cial institutions are mandated to apply for licences. Under this arrangement, open finance providers (ie, the licensed financial institutions) will gain access to customer data and will be permitted to initiate trans - actions on customer accounts and products. The sec - ond was the Sandbox Conditions Regulation, which was issued to facilitate the testing of technologically innovative financial business models, products, ser - vices and solutions which may benefit consumers and/or the wider industry for a duration determined by the CBUAE without participants being required to obtain a full regulatory licence. Over the course of 2025, the Open Finance Framework has continued to progress, including through the development of Open Finance Standards and a centralised API hub and trust framework. In June 2024, the CBUAE published the Payment Token Services Regulation (the “PTS Regulation”) which established a comprehensive framework for licensing and supervising digital payment services and covers: • payment token issuance; • payment token conversion; and • payment token custody and transfer. Artificial intelligence models, including generative AI, are increasingly being used in fintech products and services in the UAE. The DFSA’s AI Survey 2025
Any views expressed in this publication are strictly those of the authors and should not be attributed in any way to White & Case LLP . In 2025, the UAE has continued to reinforce its posi - tion as not just a regional, but also a global, financial services hub with an even stronger push to develop and grow the UAE’s fintech landscape. There has been significant investment in fintech start-ups in recent years and the UAE now hosts a quarter of all fintech companies in the Middle East and North Africa (MENA) region. According to industry reports, the potential impact of artificial intelligence (AI) in the Middle East is expected to be USD320 billion by 2030, with the UAE set to see the largest impact of close to 14% of 2030 GDP. The growth in the UAE’s fintech space has largely been driven by initiatives from the UAE’s two financial free zones: the Dubai International Financial Centre (the “DIFC”) and the Abu Dhabi Global Market (the “ADGM”). Both the ADGM and the DIFC have set up their own fintech hubs: the ADGM Regulation Lab (the “ADGM RegLab”) and the DIFC Innovation Hub. The ADGM RegLab and the DIFC Innovation Hub give fin - techs access to an extensive network of investors, marketing and PR exposure, bespoke regulatory frameworks and regulatory sandbox schemes, as well as networking events. In the words of the DIFC Inno - vation Hub, its objective is to “raise unicorns”. The success of the UAE’s fintech market can also be attributed to the continued entrepreneurialism of the UAE’s regulatory authorities to position the UAE as a regional and international virtual assets leader. This is demonstrated by the actions of the Dubai Vir - tual Assets Regulatory Authority (the “VARA”) which released its all-encompassing regulatory framework for virtual assets in February 2023 and the UAE’s Securities and Commodities Authority (the “SCA”), now the Capital Market Authority (“CMA”) with effect from 1 January 2026, which issued Guidelines Relat - ing to the Regulation of Virtual Assets and Virtual Assets Service Providers in July 2024. The CMA was established under Federal Decree-Law No (32) of
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