The Securities and Commodities Authority continues to develop implementing regulations under Cabinet Decision No. 111 of 2022, progressively building the operational detail required for comprehensive onshore VASP licensing and supervision. This brief tracks the development trajectory and current status.
implementation context
Cabinet Decision No. 111 establishes the federal mandate for VASP regulation but delegates operational detail to implementing regulations published by the SCA. The implementing regulations cover licensing procedures and application requirements, capital adequacy standards for different VASP activities, technology governance and cybersecurity requirements, client asset protection and custody standards, and reporting obligations. The SCA’s approach involves phased publication, with regulations released progressively as they are finalized through internal review and stakeholder consultation.
current status
As of March 2026, the SCA has published several categories of implementing regulations. Licensing regulations establishing the application process and assessment criteria for VASP licensing are in place. AML/CFT compliance regulations building on the federal framework are operational. Additional categories including detailed capital adequacy standards, technology governance requirements, and enhanced client asset protection rules continue in development.
The SCA’s regulations listing provides the official publication record. The authority’s FinTech Regulatory Sandbox continues to operate, providing a pathway for innovative virtual asset firms to test compliance before full licensing.
timeline indicators
The SCA reported record growth in January 2026, and its December 2025 announcement about developing an “innovative risk-assessment methodology” suggests investment in enhanced supervisory capabilities. The authority’s engagement with international organizations — including hosting the AMERC Plenary Meeting in November 2025 and partnering with the DFSA on an October 2025 MoU — demonstrates active institutional development.
The implementing regulations timeline is influenced by several factors including the pace of market development in onshore UAE, coordination requirements with VARA, ADGM FSRA, and DFSA on cross-jurisdictional consistency, and international regulatory developments including EU MiCA implementation.
implications for market participants
Firms considering onshore VASP licensing should engage with the SCA early to understand the current state of implementing regulations and the expected timeline for completion. The federal vs free zone comparison examines the strategic choice between SCA onshore licensing and free zone regulatory frameworks. The multi-authority licensing strategy guide provides practical guidance.
For official updates, monitor the SCA website and the regulatory framework tracker dashboard. The token classification framework provides context for how the implementing regulations address different token categories. The CBUAE payment token regulation covers complementary federal regulatory development.
regulatory instrument categories
The implementing regulations under Cabinet Decision No. 111 address several distinct regulatory categories, each at different stages of development.
licensing and authorization regulations
The licensing regulations establish the application process and assessment criteria for onshore VASP licensing. These regulations define the activities that require SCA licensing, the application submission requirements and assessment procedures, the fitness and propriety standards for key personnel, the corporate governance requirements for licensed entities, and the conditions under which licenses may be granted, conditioned, suspended, or revoked. The SCA’s FinTech Regulatory Sandbox operates alongside the licensing framework, providing a structured testing environment for innovative firms not yet ready for full licensing.
capital adequacy regulations
Capital adequacy regulations establish minimum capital requirements for different VASP activity types, calibrated to the risks associated with each activity. The capital requirements are expected to reflect the SCA’s assessment of the financial resources necessary to absorb operational losses, meet ongoing obligations to clients, and maintain orderly wind-down capability. These requirements will provide a reference point for firms comparing onshore SCA licensing with free zone alternatives — the VARA vs ADGM vs DFSA comparison examines capital requirement differences across authorities.
technology governance regulations
Technology governance regulations address the cybersecurity, operational resilience, and distributed ledger technology governance standards that licensed VASPs must maintain. These regulations cover information security management, penetration testing and vulnerability assessment requirements, incident response and disaster recovery planning, smart contract governance and audit requirements, and third-party technology risk management. The SCA’s December 2025 announcement about developing an innovative risk-assessment methodology suggests that technology governance assessment may incorporate advanced analytical tools.
client asset protection regulations
Client asset protection regulations establish the standards for segregation, custody, and insurance of client assets held by licensed VASPs. These regulations address the segregation of client assets from proprietary assets, the custody governance framework including key management and access controls, insurance requirements for client asset protection, and the procedures for client asset return in the event of VASP insolvency. Client asset protection is a critical regulatory priority given the history of industry failures where inadequate client asset segregation resulted in customer losses.
aml/cft compliance regulations
The AML/CFT compliance regulations build on the federal framework established by Federal Decree-Law No. 20 of 2018, applying SCA-specific requirements for onshore VASPs. These regulations integrate the enhanced requirements developed during the FATF grey list remediation and reflect the ongoing monitoring expectations of the FATF.
international regulatory context
The SCA’s implementing regulations development occurs within an international context where comprehensive VASP regulation is becoming the global norm. The EU’s MiCA framework, Hong Kong’s VASP licensing regime, and Singapore’s Payment Services Act all provide reference points for the SCA’s regulatory design. The SCA’s engagement with IOSCO and other international organizations ensures that the implementing regulations reflect international best practices. The international regulatory developments brief tracks how global developments influence UAE regulatory design.
institutional development indicators
Several institutional developments signal the trajectory of implementing regulations development. The SCA reported record growth in January 2026, indicating expanding market development under its supervision. The authority’s partnership with the DFSA through the October 2025 MoU demonstrates cross-authority coordination capacity. The SCA’s engagement with the UAE Sustainable Finance Working Group (fourth statement published December 2025) suggests that implementing regulations may address sustainable finance-related tokenization.
The AMERC Plenary Meeting hosted by the SCA in November 2025 demonstrated international regulatory leadership. The Financial Market Pioneers Program (third edition launched November 2025) builds the human capital needed to support the expanding regulatory framework.
market conduct regulations
The implementing regulations are expected to establish market conduct standards for onshore VASPs covering fair dealing obligations requiring VASPs to treat customers fairly and honestly in all interactions. Disclosure requirements mandate clear communication of fees, risks, and material terms before customers enter into virtual asset transactions. Marketing and advertising standards prohibit misleading claims about virtual asset investments and require balanced presentation of risks and potential returns. Conflict of interest management requires VASPs to identify, manage, and disclose conflicts of interest arising from their operations. Complaints handling procedures establish minimum standards for receiving, investigating, and resolving customer complaints.
These market conduct standards will align with international best practices while addressing the specific characteristics of virtual asset operations. The consumer protection cross-emirate analysis examines how consumer protection standards compare across UAE jurisdictions.
stakeholder engagement and consultation
The SCA’s approach to implementing regulations development involves stakeholder engagement through multiple channels. Draft regulations are published for public consultation, allowing industry participants to provide feedback on proposed requirements. The SCA’s digital consultations platform facilitates this engagement. Industry associations and professional bodies provide collective feedback representing the interests of market participants.
The SCA’s December 2019 launch of the Community Participation in Zero Bureaucracy initiative (expanded through UAE Government initiative in December 2025) reflects the authority’s commitment to accessible and responsive regulatory engagement. Market participants should actively participate in consultation processes to influence the final form of implementing regulations.
competitive impact of implementing regulations
The finalization of implementing regulations will clarify the SCA’s competitive positioning within the UAE’s multi-authority landscape. A comprehensive and well-designed onshore framework could attract firms that currently operate in free zones due to the absence of a developed federal licensing pathway. The SCA’s jurisdiction covers the broadest geographic scope — all onshore UAE — providing the widest potential market access among UAE regulators.
However, the regulations’ competitiveness will depend on several factors including capital requirements relative to free zone alternatives, the licensing timeline from application to operational authorization, the flexibility of the regulatory approach compared to the principles-based ADGM framework and the activity-based VARA framework, and the tax treatment of onshore operations compared to zero percent rates in free zones.
The federal vs free zone comparison examines these competitive dynamics. The multi-authority licensing strategy guide provides practical guidance on evaluating the SCA pathway against free zone alternatives.
For the broader federal context, see the Cabinet Decision No. 111 analysis and the cross-emirate regulatory arbitrage analysis.