Fintech 2026

UNITED ARAB EMIRATES Law and Practice Contributed by: Arnold Krutilins and Gabrielle Margerison (nee Lowe), White & Case LLP

reported that AI adoption among DFSA-authorised firms increased materially year-on-year, with genera - tive AI usage showing the largest increase, with the DFSA highlighting governance as a continuing focus area.

• “onshore UAE” – constituting the territories of the seven emirates of the UAE, including approximate - ly 45 economic free zones that are largely concen - trated in the emirate of Dubai; and • “offshore UAE” – constituting the financial free zones of the DIFC and the ADGM. Each of the financial free zones are, from a financial services regulatory perspective, separate jurisdictions from “onshore UAE”; each financial free zone has its own standalone rules and regulations that are largely premised on English common law and are based on benchmarking against the rules of lead - ing international financial centres. “Onshore UAE” – Payments In “onshore UAE”, the provision of payment services is generally regulated by the CBUAE pursuant to the regulations set out below. CBUAE Law The CBUAE Law came into effect on 16 September 2025. The CBUAE Law is relevant to fintech market participants as it expressly identifies certain activi - ties as “financial activities” requiring CBUAE licens - ing, including (among others) “providing open finance services” and “providing payment services using vir - tual assets”. The CBUAE Law also provides affected persons a one-year reconciliation period (until 16 Sep - tember 2026, subject to any extension by the CBUAE Board) to regularise their position. Large Value Payment Systems Regulation This framework sets out the conditions for obtaining and maintaining a licence to operate a large value pay - ment system, defined as “a clearing and settlement system that is designed primarily to process large value and/or wholesale payments typically among financial market participants (so-called wholesale pay - ments) or involving money market, foreign exchange or many commercial transactions, excluding bilateral clearing and settlement arrangements and relation - ships which do not constitute a ‘system’”. Retail Payment Systems Regulation This framework applies to designated retail payment systems providers, setting out (amongst other things):

2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models

The UAE’s fintech sector has continued to grow and mature following an increase in the adoption of digi - tal payments, e-commerce activity and an expanding digital banking landscape. A wide range of actors are active in the UAE’s fintech space, from mature businesses to start-ups that oper - ate across a wide range of sectors from open banking and equity crowdfunding through to insurtech, wealth - tech and regtech. The predominant verticals that apply in the UAE relate to virtual assets, cryptocurrencies, payments (including with respect to remittances which are of disproportionately large importance in the UAE given its large expatriate population) and blockchain technology (including tokenisation use cases, such as tokenisation of real-world assets and payment tokens/ stablecoins). A continued interest from large virtual asset companies considering whether to relocate to the UAE is expected, given the comparatively devel - oped regulatory landscape amid increasingly aggres - sive enforcement actions from Western (and other) regulators in this space. 2.2 Regulatory Regime Overview The UAE is a federation consisting of seven emirates, with Dubai largely seen as the UAE’s international commercial centre and Abu Dhabi being particularly important from a governmental and political perspec - tive. Each emirate is permitted to exercise all powers not assigned to the federal level. This includes being authorised to issue its own laws and regulations. From a financial services regulatory perspective, the UAE comprises two categories of jurisdiction:

910 CHAMBERS.COM