The UAE's finfluencer regime: What the firms that engage them need to know

Since May 2025, the UAE has operated the Middle East's first dedicated licensing regime for "finfluencers", individuals who share financial recommendations with the public on social media.

Issued as Chairman of the Board of Directors' Resolution No. (10/R.M) of 2025 (the "Resolution"), the regime took immediate effect on 29 May 2025 and now sits with the Capital Markets Authority (the "CMA"). 

What has changed?

1. The Resolution creates a new regulated category, the "Finfluencer" - defined as a natural person who provides financial recommendations to the public via a public medium (social media, blogs, podcasts, webinars or in-person seminars) concerning the purchase, sale or retention of financial products, virtual assets or CMA-regulated services, whether relating to UAE or foreign issuers.
2. Registration with the CMA is mandatory before publishing this type of content. Eligibility is tied to defined thresholds: holding a CFA charter or CMA-accredited financial analyst status, a minimum of 1,000 followers on the relevant platform, and at least six months of demonstrated financial or technical experience.
3. To encourage early registration, the regulator waived registration, renewal and legal consultation fees for the first three years of the regime, an incentive that continues to apply as the framework transitions to the CMA.
4. Registered Finfluencers are subject to ongoing content and disclosure obligations: recommendations must clearly separate fact from opinion, be based on current and properly sourced data, and carry appropriate risk disclaimers. Any compensation, sponsorship or affiliation with an issuer or licensed entity, including where content is republished or adapted from a third-party recommendation must be disclosed, together with the date and time of publication.
5. The Resolution reaches beyond individual creators. Issuers and CMA-licensed entities that engage or contract with Finfluencers for promotional purposes fall within scope, and firms may face regulatory exposure where they engage or promote a Finfluencer who is not properly registered.
6. Narrow carve-outs apply: republication of information already approved by the CMA or a licensed market, licensed financial consultants and analysts acting within their authorised scope, and materially individuals providing financial recommendations from within a UAE financial free zone such as the DIFC or ADGM.

Interaction with other UAE regimes

The Resolution operates alongside, rather than in place of, other applicable frameworks. Content aimed at a Mainland audience but published from the DIFC or ADGM is not directly caught by the Resolution, but the Dubai Financial Services Authority maintains its own parallel regime for financial promotions, investment advice and marketing activity directed at DIFC-based clients under the DFSA Rulebook (including the General Module, the Conduct of Business Module and the Financial Promotions regime). Firms operating across the Mainland and the financial free zones should not treat the free zone carve-out as a general exemption, content that reaches a Mainland audience can still trigger CMA obligations regardless of where it originates.

Financial content also intersects with the UAE's broader media regulation. Separately from CMA registration, individuals monetising content in the UAE, including finance content, generally require an influencer or media activity permit issued by the relevant media regulator, and Cabinet Decision No. 42 of 2025 sets out a tiered penalty framework for media content violations that applies across both Mainland and free zone entities. A financial content creator earning from sponsored or promotional content will typically need both the media permit and CMA registration; the two obligations are cumulative, not alternatives.

Who should care?

The regime is directly relevant to: individual content creators and commentators operating from the UAE Mainland who discuss investing, trading or virtual assets; issuers and CMA-licensed firms that sponsor, brief or otherwise engage Finfluencers as part of their marketing or investor relations activity; and DIFC- or ADGM-based firms whose promotional content, or whose engaged creators, may reach a Mainland audience. Free zone companies structuring a content creation, media or digital marketing business — including through structures such as those available via UAE free zones, should factor CMA registration into their compliance planning from the outset if any part of the content touches financial products, investment themes or virtual assets.

What to watch for next

Now that the Resolution sits within the CMA's expanded federal mandate, firms should expect further implementing guidance as the CMA consolidates its rulebook following the SCA transition, together with more visible enforcement activity as the regime matures beyond its first eighteen months. Engagement letters, influencer marketing agreements and content approval workflows should be reviewed to confirm they capture CMA registration status, disclosure obligations and media permit requirements as a condition of engagement.

Our team advises clients on UAE financial promotions, virtual asset and digital content regulation across the Mainland and financial free zones. If you would like to discuss how the finfluencer regime may affect your business, please get in touch with Tom Bicknell, Barkha Doshi or Anna Dios.