Dubai, UAE: UAE financial businesses operating from commercial free zones or serving mainland investors are facing a changing regulatory landscape as the new Capital Market Authority (CMA) framework takes shape. Federal Decree-Law No. 32 of 2025 established the CMA, while Federal Decree-Law No. 33 of 2025 provides the wider framework for regulating capital-market activities in the UAE.
The development is important for businesses that provide or plan to provide regulated financial services outside the UAE’s Financial Free Zones. The new framework defines a “Free Zone” separately from Financial Free Zones, meaning DIFC and ADGM should not be treated in the same way as commercial free zones under this federal framework.
For businesses assessing a new structure or financial activity, tax and compliance should be reviewed alongside the relevant regulatory requirements.
Free-Zone Structure Does Not Replace Regulatory Review
The key point for businesses is that choosing a commercial free zone as a business location does not, by itself, determine whether a financial activity is regulated.
Businesses involved in securities, investment services, funds, virtual assets or other capital-market activities need to understand the rules that apply to their specific activity. The CMA framework gives the federal regulator a role in supervising financial activities within its defined scope, including activities connected with free zones outside the Financial Free Zones.
This makes due diligence services important for businesses considering a free-zone structure or expanding their services to UAE investors. The focus should be on the actual activity, the relevant license and the regulatory requirements that apply.
Virtual Asset Rules Add a Major 2026 Development
A major current development is the CMA’s Virtual Assets Framework, issued on 13 April 2026. The framework creates an integrated regulatory structure with five core modules covering general requirements, conduct of business, alternative trading systems, anti-money laundering and counter-terrorist financing, and prudential requirements.
It also expands regulated virtual-asset activities from three to eight. These include dealing in virtual assets as principal or agent, custody, arranging custody, arranging investment deals, investment advice, portfolio management, and operating a multilateral trading facility.
The framework is relevant to businesses operating within the federal CMA regulatory perimeter. It should not, however, be presented as replacing the separate regulatory systems that apply in DIFC and ADGM.
What Should Financial Businesses Do Now?
Businesses should review their tax compliance position, licensing structure, and financial activities before expanding into regulated services. They should also check whether their services involve securities, investment products, funds, or virtual assets and identify the regulator and rules that apply.
Clear business planning and strategy can help firms assess whether their proposed structure and activities fit their regulatory requirements. Businesses should also keep accurate bookkeeping records and supporting financial information as part of their wider financial processes.
Ignoring applicable regulatory requirements can expose a business to regulatory issues and may affect its ability to conduct regulated activities lawfully. The right response is to review the structure and activities before launching or expanding a financial service.
For businesses dealing with complex UAE regulatory and financial requirements, business tax advisory can provide support when reviewing the wider financial and compliance position. Dubai Business and Tax Advisors (DBTA) help businesses assess their financial, tax and business requirements while adapting to changing UAE regulations.
The CMA’s evolving framework shows why financial businesses cannot rely only on where a company is registered. For firms operating between commercial free zones and the mainland market, the next step is to understand the activity, identify the applicable regulatory requirements, and prepare before expanding their financial services.
