DFSA folds prudential forms into B110 and revises credit rating agency rules
From 2 October 2026, DFSA prudential reporting forms B120 and B180 fold into a redesigned form B110, following Consultation Paper No. 174. More principles-based conflict of interest rules for credit rating agencies follow on 1 January 2027.
From 2 October 2026, every authorised firm in the Dubai International Financial Centre (DIFC) reports prudential data on one redesigned form, B110, which absorbs the data previously reported in forms B120 and B180. That is the first of two sets of targeted rule changes the Dubai Financial Services Authority (DFSA) has made following Consultation Paper No. 174. The second, from 1 January 2027, moves credit rating agencies to a more principles-based approach to conflicts of interest. The DFSA announced both on 5 October 2026, alongside a Feedback Statement on the consultation.
What the rules say
Consultation Paper No. 174, titled "Miscellaneous changes", was released on 9 July 2026, with comments invited until 24 August 2026. The DFSA says the Feedback Statement covers the proposals on credit rating agencies and prudential reporting. Proposals in the same paper on crypto and investment tokens will be considered at a later stage.
The rule-making instruments were published on 1 October 2026, according to the DFSA. The amendments sit in two modules of the DFSA Rulebook.
| Module | Change | In force |
|---|---|---|
| PIB (Prudential, Investment, Insurance Intermediation and Banking Business Module) | Data previously reported in forms B180 and B120 folded into a redesigned form B110 | 2 October 2026 |
| Conduct of Business Module (COB) | Amendments applying to credit rating agencies | 1 January 2027 |
On prudential reporting, the DFSA says form B110 applies to all authorised firms and that each firm completes only the data items relevant to it. The DFSA presents the change as a simplification of the reporting framework.
For credit rating agencies, the DFSA describes three elements. The first is a more principles-based approach to assessing relationships that may cause, or be perceived as causing, a conflict of interest. The second removes disclosure requirements it considered duplicative or unnecessarily prescriptive. The third keeps the overarching obligation to give users enough information to understand how a rating was determined.
Who is affected
Every DFSA authorised firm is caught by the prudential reporting change, since the DFSA says form B110 applies to all of them. Firms that used to file B120 or B180 separately feel it most, because that data now sits inside B110.
Only firms authorised by the DFSA as credit rating agencies are affected by the second part of the package.
Both changes are made to the DFSA Rulebook and concern DFSA authorised firms only.
Key dates
| Date | Event |
|---|---|
| 9 July 2026 | Consultation Paper No. 174 released |
| 24 August 2026 | Consultation closed |
| 1 October 2026 | Rule-making instruments published |
| 2 October 2026 | PIB amendments, including form B110 changes, in force |
| 5 October 2026 | DFSA announcement and Feedback Statement |
| 1 January 2027 | COB amendments for credit rating agencies in force |
What it means in practice
For most authorised firms the immediate job is operational. Finance and regulatory reporting teams should confirm that the next prudential return is prepared on the redesigned B110, that data previously routed to B120 or B180 is captured in the new form, and that reporting software and templates have been updated. If you use a third-party reporting provider, check that it has adopted the new form.
Take a hypothetical DIFC investment firm that has filed a separate B120 alongside its B110 each period. From its first return due after 2 October 2026, it would expect to complete the relevant data items within B110 alone. Reconciling that first new-format return against the previous period's filings is a sensible control.
For credit rating agencies, a principles-based conflicts regime puts more weight on the firm's own analysis of its relationships. Review your conflicts policies before 1 January 2027, and record how you assess relationships that could create real or perceived conflicts.
For a business weighing the DIFC, the package is a modest sign that the DFSA will cut reporting load where it considers data duplicated.
What we do not yet know
We could not review the text of the rule-making instruments or the Feedback Statement directly, because they are hosted on the DFSA's external rulebook platform. So we do not describe here which COB rules were amended, what the redesigned B110 contains, or any changes made in response to consultation comments. The DFSA has not announced when it will return to the deferred crypto and investment token proposals.
This piece appeared in Jurisdicta, Issue 002. General information only; not legal, tax or investment advice.