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Issue 002Sunday 18 October 2026The Rulebook
Issue 002 · The Rulebook · United Arab Emirates

Capital Market Authority: the one-year window to adjust status closes at the end of 2026

Federal Decree-Law No. (33) of 2025 gives firms within its scope one year from 1 January 2026 to adjust their status. The perimeter reaches free zone businesses and offshore firms targeting UAE clients, virtual asset activity included.

Sunday 18 October 20264 min readChecked against 3 official sources
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In one minute
What changedFederal Decree-Law No. (33) of 2025 gives firms within its scope one year from 1 January 2026 to adjust their status. The perimeter reaches free zone businesses and offshore firms targeting UAE clients, virtual asset activity included.
Who is affectedAnyone conducting an Article 3 activity onshore, in a non-financial free zone, or from outside the UAE towards UAE clients.
Key date1 January 2026Decree-Laws No. 32 and No. 33 enter into force
What to doIf you carry on any Article 3 Financial Activity in or into the UAE, outside the DIFC and ADGM, map your activities against the licence you hold and file or restructure before the period ends with 2026, unless the CMA Board announces an extension.
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Firms within the scope of the UAE's new federal capital markets law have until the end of 2026 to bring themselves into line. Federal Decree-Law No. (33) of 2025 on the Regulation of the Capital Market, issued in Abu Dhabi on 1 October 2025, entered into force on 1 January 2026 alongside Federal Decree-Law No. (32) of 2025 on the Capital Market Authority. Every entity and person within its scope must adjust their status within one year of that date (Article 83). Brokers, fund managers, custodians and virtual asset businesses have the most to check.

What the rules say

Decree-Law No. 32 replaces the Securities and Commodities Authority, set up under Federal Law No. (4) of 2000, with the Capital Market Authority (CMA). The CMA takes over its predecessor's rights and obligations, and the 2000 law is repealed.

Decree-Law No. 33 carries the substance. Article 83, headed "Adjustment of Status", provides that "All entities and Persons subject to the provisions of this Decree-Law and the Relevant Legislation shall adjust their status in accordance with its provisions within a period of one (1) year from the date of entry into force of this Decree-Law." It adds: "The Board may extend this period as it deems appropriate."

Articles 2 and 3 draw the perimeter.

Provision Effect
Article 2(1)(b) Applies to Financial Activities practised within the State or by any person in a free zone, whether conducted inside or outside the free zone
Article 2(1)(d) Applies to any person targeting clients within the State, even if the activity is conducted outside the State
Article 2(4) Excludes Financial Activities licensed by the Central Bank, Central Bank settlement infrastructure, Central Bank licensees (save for securities issuance and Article 3 activities) and Financial Free Zones
Article 3(1) Lists the Financial Activities, from operating a market to brokerage, custody, fund management, credit rating, investment-based crowdfunding and, at item (y), "Activities and services related to Virtual Assets"
Article 3(2) No person may carry out a listed activity in the State without a CMA licence or approval

The CMA has power to regulate the trading of virtual assets and related activities, subject to the Central Bank Law (Article 39). No virtual asset may be traded within the State unless it is admitted to the official list of a CMA-licensed platform operator and registered with the CMA. The CMA supervises virtual asset activity "within the State and within the Free Zones".

Enforcement sits in two articles. The CMA can impose fines of up to AED 200 million and suspend any Financial Activity conducted without a licence, approval or registration, with closure of the premises (Article 65). Unlicensed activity is also an offence (Article 71).

Who is affected

Anyone conducting an Article 3 activity onshore, in a non-financial free zone, or from outside the UAE towards UAE clients. If you held a licence from the former Securities and Commodities Authority, check that it covers what the new list calls your activity. Virtual asset businesses should read Article 39 closely.

The financial free zones, the DIFC and ADGM, are excluded (Article 2(4)(d)). Central Bank licensees sit outside the law except for securities issuance and Article 3 activities.

Key dates

Date Event
1 October 2025 Decree-Law No. 33 issued
1 January 2026 Decree-Laws No. 32 and No. 33 enter into force
End of 2026 One-year adjustment period under Article 83 runs out, unless the CMA Board extends it

What it means in practice

What counts is what a business does and for whom, not where it is registered. A free zone licence does not, by itself, take an activity outside the law, because Article 2(1)(b) reaches activities practised by persons in a free zone, inside or outside it.

Take a hypothetical company licensed in a commercial free zone that markets portfolio management services to residents of Dubai and Sharjah. On the text, that is a Financial Activity practised by a person in a free zone and directed at clients in the State. Before the adjustment period ends it would need a CMA licence or approval, or a firm view that an exclusion applies.

The practical exercise is a map. Set each service line against the Article 3 list and, where there is a gap, decide whether to apply, restructure or stop.

What we do not yet know

We have found no CMA Board decision on the CMA's website extending the Article 83 period. Earlier Cabinet and CMA resolutions stay in force until replaced (Article 82). The CMA has not published how it will treat firms that apply before the deadline but are not yet licensed. The Decree-Law does not name emirate-level virtual asset regulators, and the text itself does not address how Article 39 sits alongside existing emirate regimes.

What to do nowIf you carry on any Article 3 Financial Activity in or into the UAE, outside the DIFC and ADGM, map your activities against the licence you hold and file or restructure before the period ends with 2026, unless the CMA Board announces an extension.
Our readingThe federal perimeter is closing. For activities offered onshore, a free zone address does not settle the question, and the virtual asset provisions in Article 39 deserve a close read.
Sources
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This piece appeared in Jurisdicta, Issue 002. General information only; not legal, tax or investment advice.

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