UAE banks must give SMEs a Key Facts Statement and 60 days' notice of changes
The Central Bank's SME Customer Protection Regulation has applied since 13 September 2026. It gives small and medium-sized business customers consumer-style rules on disclosure, fees and complaints.
Banks and finance companies licensed by the Central Bank of the UAE must now give SME customers a Key Facts Statement before providing a product, and at least 60 calendar days' written notice of changes to terms or fees. The Central Bank's Small and Medium-Sized Enterprises (SME) Customer Protection Regulation, issued as Circular C 2/2026, took effect on 13 September 2026. It replaces the SME Market Conduct Regulation of 2021 and gives small and medium-sized businesses that bank in the UAE formal protections.
What the rules say
The regulation covers banks and finance companies licensed by the Central Bank, Islamic institutions included, for the activities in Article 61 of the Central Bank Law. Its main obligations are:
| Article | Requirement |
|---|---|
| 3.2 | Information available in English and Arabic |
| 3.4(a) | Key Facts Statement before the product is provided; customer acknowledges receipt before signing |
| 3.7 | Copy of the signed contract within a reasonable time |
| 3.9 | Clear information on all fees, with a copy of the fee schedule |
| 3.10 | At least 60 calendar days' written notice of changes to terms and conditions, including fees |
| 3.11 | For contracts that renew automatically each year, notice at least 30 calendar days before renewal, explaining how to cancel |
| 3.12 | Reasons for rejecting an application given in writing, unless financial crime concerns or the law prevent it |
| 4.43 to 4.45 | No fees for legally required updates such as ID documents, none for paper statements, and no closing fee once an account has been open six months or more |
| 6.5 and 6.9 | Complaints acknowledged in writing within two business days; final written response within 30 business days |
The regulation defines the Key Facts Statement as a concise, plain-language summary of a product's key features and risks. Disclosure has to cover risks, including the risk of pledging collateral. Fees must be fair, reasonable and proportionate to the institution's actual cost, and must stay within any maximum the Central Bank sets.
Responsible conduct is covered too, including tied selling, suitability and the correction of errors. Arrears are to be handled with early support and without excessive pressure, and the customer must be told in writing if a collection agent is appointed. Unresolved complaints can go to Sanadak, the financial ombudsman unit. An institution in breach can face supervisory action, financial sanctions or measures against senior management.
Who is affected
A customer is an SME, sole proprietors included, if it obtains or may obtain financial products for business needs. The size test comes from Cabinet Resolution No. 22 of 2016 and turns on sector, headcount and revenue. The top band covers medium enterprises with revenue of up to AED 250 million in trading and manufacturing, and up to AED 200 million in services.
The rules bind Central Bank licensees, whether the customer company is licensed on the mainland or in a free zone. Because the scope stops at Central Bank licensees, firms regulated only in the DIFC or ADGM financial free zones are not covered.
Key dates
| Date | Event |
|---|---|
| 26 January 2021 | SME Market Conduct Regulation (Circular No. 1/2021) issued, now cancelled |
| 13 September 2026 | SME Customer Protection Regulation in force, six months after publication in the Official Gazette |
What it means in practice
If you are comparing banks before opening an account or taking a facility, the Key Facts Statement gives you a standard summary of costs and risks to set side by side. Ask each bank for it before you sign. That is now a reasonable request.
The 60-day rule gives you time to react to repricing. A hypothetical example: a Sharjah trading company with a working capital line is told on 1 November 2026 that its monthly account maintenance fee will rise. Under Article 3.10 the increase can take effect no earlier than 31 December 2026, so the company has two months to negotiate or move. If the account has been open six months or more, the bank cannot charge a closing fee (Article 4.45).
If you have been declined, Article 3.12 provides for the reasons in writing in most cases. That helps you decide whether to fix a gap in your documents or approach another lender.
What we do not yet know
The Central Bank can set maximum fees (Article 4.41), but we found no published SME fee caps under the new regulation. The Rulebook page does not give the circular's issue date.
This piece appeared in Jurisdicta, Issue 001. General information only; not legal, tax or investment advice.