UAE Central Bank Licensees Permitted to Conduct CMA-Regulated Virtual Asset Activities

In June 2026, the Chairman of the Board of Directors of the UAE Capital Market Authority (the CMA) issued Resolution No. (16/Chairman) of 2026 (the Resolution).

The Resolution permits entities licensed by the Central Bank of the UAE (the CBUAE), other than insurance companies, to conduct the virtual asset activities regulated by the CMA, subject to obtaining the relevant CMA authorisations.

Background

The CMA is the successor to the Securities and Commodities Authority and operates under Federal Decree-Law No. (32) of 2025 and Federal Decree-Law No. (33) of 2025. Virtual asset activities within its remit are regulated by Resolution No. (04/Chairman) of 2026 concerning the Regulation of Virtual Assets Service Providers and the Alternative Trading System Operator (Resolution No. 4). Depending on the business model, that framework can cover trading, brokerage, custody and the operation of an alternative trading system.

The CBUAE’s virtual asset remit is more limited. Under Article (61)(1) of Federal Decree-Law No. (6) of 2025 (the CBUAE Law), the CBUAE licenses the provision of payment services using virtual assets, which it regulates principally through its Payment Token Services Regulation. Activities beyond that perimeter remain with the CMA.

As a result, CBUAE licensees that wished to offer CMA-regulated virtual asset services have generally established a dedicated CMA-licensed vehicle and put in place group arrangements to support that structure.

The Resolution

Eligible CBUAE licensees may, in principle, undertake both their existing CBUAE-regulated business and CMA-regulated virtual asset activities in a single legal entity.

The Resolution extends to CBUAE-licensed entities generally, including banks, finance companies, exchange houses and payment service providers. Insurance companies, which are also licensed by the CBUAE, are excluded. An insurer that wishes to offer CMA-regulated virtual asset services will therefore still need a separately licensed entity.

The Resolution is confined to onshore UAE activity within the CMA’s remit. It leaves untouched the virtual asset regimes of the Dubai International Financial Centre, the Abu Dhabi Global Market and the Virtual Assets Regulatory Authority in Dubai.

Implementation

Further guidance is expected from the CMA and the CBUAE on how the permission will operate in practice, including the form of CMA authorisation, the allocation of supervisory responsibility, and the capital, custody, client-asset and governance standards that will apply, including for deposit-taking institutions.

Institutions considering the Resolution will also need to take account of Article (61)(3) of the CBUAE Law, which requires a CBUAE licensee that wishes to carry on activities licensed by another regulatory authority to obtain CBUAE approval before seeking a licence from that authority. Given that most Resolution No. 4 activities sit outside the CBUAE’s own licensed activities, that approval process is expected to form part of any application pathway.

Practical considerations

The Resolution is a significant development for the onshore market. It suggests that established CBUAE-regulated institutions are intended to participate in CMA-regulated virtual asset activity directly, and it may in time allow groups to simplify structures that currently rely on a separate CMA-licensed affiliate.

CBUAE licensees assessing the opportunity should map the Resolution No. 4 activities relevant to their business and consider the capital, custody, governance and risk-management implications of undertaking those activities in the same entity. Groups that already operate a CMA-licensed affiliate may wish to review whether a single-entity model would be advantageous once the framework is clarified, and whether existing intra-group arrangements would need to be revisited.

How we can help

Clyde & Co’s financial regulatory team in the UAE advises banks, payment service providers, finance companies and other CBUAE licensees on virtual asset perimeter questions, licensing strategy, CBUAE and CMA authorisations, and the design of operating models.

If you would like to discuss what the Resolution means for your institution, please contact Tom Bicknell, Barkha Doshi and Anna Diós.