UNITED ARAB EMIRATES Trends and Developments Contributed by: Arnold Krutilins and Gabrielle Margerison (nee Lowe), White & Case LLP
Regulating Fiat-Referenced Tokens in the ADGM In September 2025, the FSRA issued Consultation Paper No 9 of 2025 (“CP 9 of 2025”) proposing to expand its regulatory framework for activities involving fiat-referenced tokens (“FRTs”), a form of fiat-backed stablecoin. Stablecoins are increasingly used within fintech eco - systems to facilitate payments, trading and settlement of digital assets. CP 9 of 2025 proposes to expand the regulatory framework to ensure that fintech firms engaging in custody, payment, intermediation and issuance activities involving FRTs are subject to appropriate regulatory oversight. In particular, CP 9 of 2025 proposes to expand the scope of existing Regulated Activities to capture the custody of FRTs and introduce a new limb under the Regulated Activity of Providing Money Services to capture the activity of “FRT Intermediation”. This would apply to firms that buy or sell FRTs to clients as part of a standalone business. The proposals also introduce conduct and safeguarding requirements for authorised persons holding or controlling FRTs on behalf of clients, including client asset segregation, disclosure and recordkeeping obligations.
CP 9 of 2025 further proposes amendments to the existing FRT issuance framework, including replac - ing certain prior approval requirements with notifica - tion and non-objection mechanisms and clarifying the FSRA’s supervisory powers in respect of FRT-related activities. In addition, the FSRA proposes to prohibit authorised persons from issuing Dirham-denominat - ed FRTs within the ADGM, reflecting the UAE Central Bank’s position on Dirham-denominated stablecoins. Overall, the proposals under CP 9 of 2025 reflect the growing role of stablecoins in fintech payment infrastructure and demonstrate the FSRA’s efforts to establish a comprehensive regulatory framework governing stablecoin-based financial services within the ADGM.
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