Fintech 2026

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

it confirms that the existing licensing framework applies irrespective of the technology used to deliver any in-scope Licensed Financial Activity under the New CBUAE Law. As a result, the relevant question for fintech is whether a Licensed Financial Activity, as defined in Article 61 of the New CBUAE Law, is being carried on in or from Onshore UAE. The CBUAE’s FAQs also clarify that providers of purely technical services, such as software or infrastructure providers acting solely in a technical capacity, do not fall within scope of the CBUAE’s licensing regime solely by virtue of providing those services. Licensing requirements arise where the entity itself carries on, offers, issues or facilitates a Licensed Financial Activ - ity, rather than merely providing technology used by a licensed financial institution. Sanctions and penalties The New CBUAE Law also materially expands the range of administrative and financial penalties avail - able to the CBUAE. In particular, the maximum finan - cial penalty that may be imposed has increased from AED200 million under the 2018 CBUAE Law to AED1 billion under the New CBUAE Law. The New CBUAE Law also introduces express crimi - nal sanctions for carrying on Licensed Financial Activ - ities without a licence, including imprisonment and significant financial penalties. In addition, the New CBUAE Law introduces a sepa - rate financial penalty for promoting Licensed Financial Activities without a licence. These changes reflect a significant strengthening of the CBUAE’s enforcement powers and reinforce the importance of ensuring that regulated financial activi - ties are carried on only by appropriately licensed enti - ties. CBUAE Biometric Payments In January 2026, the CBUAE launched the UAE Bio - metric Payment System, a biometric authentication- based payment solution that enables users to make in-person payments using facial and palm recognition technology.

The UAE Biometric Payment System is designed to allow customers to authenticate transactions directly through their biometric identifiers, removing the need to present physical payment cards, mobile devices or other payment instruments at the point of sale. Based on the CBUAE’s press release, we understand that the UAE Biometric Payment System is: (i) cur - rently in the proof-of-concept stage and is being demonstrated at the Dubai Land Department, where customers can complete payments by verifying their identity using facial or palm biometrics; and (ii) being trialled through the CBUAE’s Regulatory Sandbox Programme. The launch within the CBUAE’s Regulatory Sandbox Programme allows the CBUAE to assess the opera - tional, security and regulatory implications of the bio - metric payment solution in a controlled environment prior to broader deployment. This enables the CBUAE to evaluate key considerations including authentica - tion reliability, fraud prevention, data protection com - pliance and integration with the UAE’s national pay - ment infrastructure, before determining whether the solution may be approved for wider rollout across government and private sector payment use cases. We understand that the solution is being enabled by Network International and powered by PopID. Finfluencers in the UAE In May 2025, the CMA (formerly the SCA) issued Resolution No 10 of 2025 concerning the Regulation of Finfluencers (the “Finfluencer Resolution”), creat - ing a formal registration and supervisory regime for finfluencers operating within Onshore UAE. A finflu - encer is defined as “any person who provides Finan - cial Recommendation, registered with the competent authority”. The concept of “Financial Recommendation” is con - strued broadly under the Finfluencer Regulation to capture both traditional investment commentary and modern social media-driven financial content. Specifi - cally, any content that directly or indirectly provides investment recommendations or opinions relating to financial products, virtual assets, financial services, or issuers, whether that content is disseminated

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