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United Arab Emirates (AE)

MENA · Lead regulator: CBUAE

Opportunity score
56.8High73
Norms tracked
32
LLM-analyzed
27
84% coverage
CertiK services
11/14
Maturity
Medium
4/6 dimensions
Next deadline

Regulatory coverage

Which of the six core regulatory dimensions this jurisdiction's norms actually address. Coverage is detected from the source text — not a structural heuristic.

Token issuanceCovered
CustodyCovered
Market abuseNot detected
AML / KYTCovered
TaxationNot detected
Consumer protectionCovered

Data confidence — four components

Breakdown of the confidence badge shown above. Each component is independent and they sum (weighted) to the overall score.

Analysis coverage
84%
Share of tracked norms that have been LLM-analyzed.
Coverage breadth
67%
Share of the six regulatory dimensions that this jurisdiction's norms address.
Regulator diversity
92%
How many distinct regulators contribute to the tracked norms.
Evidence density
52%
Share of LLM-extracted fields backed by a verbatim source quote (Phase 1).

Regulators

CBUAE (lead)MOECUAE CabinetFTAVARADFSA

CertiK services triggered

Green = triggered by at least one norm in this jurisdiction.

Security Auditing

Smart Contract Audit1n
L1 Chain Audit1n
Penetration Testing3n
Formal Verification

Compliance & Monitoring Products

SkyInsights — AML / KYT7n
Skynet — Threat Monitoring3n
Proof of Reserves1n
Skyshield — Bug Bounty
Performance Testing
Due Diligence1n
Incident Response3n

Advisory & Certification

Independent Certification1n
Security Guidance3n
Regulatory Compliance Support3n

Underlying norms

32 norms with regime, scope, gaps and verbatim evidence quotes. Scroll for more.

Decretal Federal Law No. (14) of 2018 Regarding the Central Bank & Organization of Financial Institutions and Activities
statute · · 2018-09-18

Scope: The provided text is a '404 Page Not Found' error from the UAE Central Bank website and contains no substantive regulatory information.

source ↗
Consumer Protection Regulation (Circular No. 8/2020)
regulation · CBUAE · 2020-11-25

Scope: The provided text is a 404 'Page Not Found' error from the regulator's website. It does not contain the substantive text of the regulation.

Gap or ambiguity: The regulatory text is missing from the source document. Therefore, no gaps or ambiguities can be identified.

source ↗
Cabinet Decision No. (74) of 2020 Regarding Terrorism Lists Regulation and Implementation of UN Security Council Resolutions on the Suppression and Combating of Terrorism, Terrorist Financing, Countering the Proliferation of Weapons of Mass Destruction and its Financing and Relevant Resolutions
regulation · UAE Cabinet · 2020-10-27· 1/2 anchored
In force

Scope: This decision establishes the framework for implementing terrorism lists and UN Security Council resolutions. It focuses on combating terrorist financing and proliferation financing.

Gap or ambiguity: The text provides a general AML/CFT framework but lacks specific guidance for the crypto-asset sector. The application of these rules to decentralized or unhosted environments remains ambiguous.

SkyInsights — AML / KYT
Evidence (1) — verbatim quotes from the source
  • Status
    Cabinet Resolution No. 74 of 2020 regarding the Terrorism Lists System and the Implementation of Security Council Resolutions
source ↗
DIFC DFSA Crypto Token regime (Rulebook 2022/2023) — extends DFSA financial regime to Crypto Tokens; maintains list of Recognised Crypto Tokens (only listed tokens may be used in DIFC); recognition with transparency, security and AML criteria
regulation · DFSA / DIFC · 2022-11-01· 0/3 anchored
LicensingIn force

Scope: The regulation extends the DFSA's financial services regime to Crypto Tokens. It establishes a list of 'Recognised Crypto Tokens' which are the only ones permitted for use within the DIFC.

Gap or ambiguity: The rule requires tokens to meet 'transparency' and 'security' criteria for recognition, but the specific technical standards are not detailed in the provided text. This creates an opportunity for certifiers to help define and attest to these standards.

SkyInsights — AML / KYT
source ↗
Retail Payment Services and Card Schemes Regulation (Circular No. 15/2021)
regulation · CBUAE · 2021-06-06

Scope: The provided text is a '404 Not Found' error page from the regulator's website. It does not contain the substantive content of the regulation.

Gap or ambiguity: The substantive text of the regulation is missing, making any analysis of its content, gaps, or ambiguities impossible.

source ↗
UAE Federal Decree-Law No. 47 of 2022 on Corporate Tax (effective June 2023, amended by Decree-Law 28/2025) — 9% corporate tax on taxable profit above AED 375,000; crypto companies taxed like any business; free-zone entities (e.g. ADGM) may pay 0% on qualifying income if they meet Qualifying Free Zone Person conditions
statute · FTA / Ministry of Finance · 2022-12-09· 0/1 anchored
In force

Scope: This law establishes a general corporate tax regime in the UAE, treating crypto companies like any other business. It applies a 9% tax on taxable profits exceeding AED 375,000.

Gap or ambiguity: The definition of 'qualifying income' for crypto-asset businesses in free zones is a key ambiguity. This creates an opportunity for advisory services to help firms meet the conditions for a 0% tax rate.

source ↗
Dormant Accounts Regulation (Circular No. 1/2020)
regulation · CBUAE · 2020-01-15

Scope: The provided text is a 404 error page from the regulator's website. The regulation's title, 'Dormant Accounts Regulation', suggests it does not pertain to crypto-assets.

source ↗
Federal Decree-Law No. (31) of 2021 On the Promulgation of the Crimes and Penalties Law (Penal Code)
statute · null · 2021-09-20

Scope: The provided text is a '404 Page Not Found' error from the UAE Ministry of Justice website. It does not contain the content of the specified Penal Code.

Gap or ambiguity: The source text is a website error page and contains no regulatory information, so no gaps or ambiguities can be identified.

source ↗
Federal Decree-Law No. (32) of 2021 on Commercial Companies
statute · MOEC · 2021-09-20
source ↗
VARA Compliance and Risk Management Rulebook — cross-activity compliance, governance, risk management for VARA-licensed entities
regulation · VARA · · 4/6 anchored
LicensingImplementing2025-06-19

Scope: This rulebook establishes comprehensive compliance, risk management, and AML/CFT obligations for entities licensed by VARA. It includes specific rules for handling client money and client virtual assets.

Gap or ambiguity: The provided text is a table of contents and lacks specific technical standards for custody or IT security. The 'Client Virtual Assets Rules' section implies requirements that are not detailed, creating an opportunity for certifiers to help define and attest to best practices.

Incident ResponsePenetration TestingSecurity GuidanceSkyInsights — AML / KYTSkynet — Threat Monitoring
Evidence (4) — verbatim quotes from the source
  • Regime
    B. Requirement to Obtain Prior Approval
  • Status
    (Effective From: 19 June 2025)
  • Principal deadline
    (Effective From: 19 June 2025)
  • Deadline type
    (Effective From: 19 June 2025)
source ↗
Cabinet Resolution on the Organisational Structure of the Ministry of Economy
regulation · MOEC · 2023-XX-XX

Scope: This resolution concerns the organizational structure of the Ministry of Economy (MOEC), designating it as the competent regulator.

Gap or ambiguity: The text defines the responsible regulator but provides no specific technical or operational requirements for the crypto-asset sector.

source ↗
DFSA Regulatory Framework for Investment Tokens
regulation · DFSA · 2021-10-25· 2/2 anchored
LicensingIn force

Scope: The framework regulates Investment Tokens, defined as Security Tokens or Derivative Tokens on DLT. It applies to firms marketing, issuing, trading, or holding these tokens in or from the DIFC.

Gap or ambiguity: The framework explicitly excludes exchange tokens (cryptocurrencies), utility tokens, and stablecoins, which are subject to future consultation. The announcement lacks specific technical requirements for licensed firms.

Evidence (2) — verbatim quotes from the source
  • Regime
    The Investment Tokens regulatory framework applies to persons interested to market, issue, trade or hold Investment Tokens in or from the Dubai International Financial Centre (DIFC) and Authorised Firms wishing to undertake Financial Services relating to Investment Tokens
  • Status
    The Dubai Financial Services Authority (DFSA) has today launched its regulatory framework for Investment Tokens.
source ↗
Cabinet Decision No. (52) of 2017 on the Executive Regulation of the Federal Decree-Law No. (8) of 2017 on Value Added Tax
regulation · FTA · 2017-11-26

Scope: The provided text is a website error message ('Page not found') and does not contain the substantive content of the regulation. The regulation's title indicates it concerns Value Added Tax.

Gap or ambiguity: The substantive legal text is missing from the provided body. No regulatory analysis is possible.

source ↗
Cabinet Resolution No. (99) of 2024 Concerning the List of Violations and Administrative Penalties for Acts Violating the Provisions of Cabinet Resolution No. (111) of 2022 Regulating Virtual Assets and its Service Providers
regulation · UAE Cabinet · 2024-09-06

Scope: This resolution establishes a list of violations and administrative penalties for non-compliance with Cabinet Resolution No. (111) of 2022, which regulates virtual assets and their service providers.

Gap or ambiguity: The provided text is a generic webpage and does not contain the actual articles of the resolution. It is impossible to determine specific technical requirements, standards, or ambiguities from the available information.

source ↗
Consultation Paper No. 168 – Enhancements to the Regulation of Crypto Tokens
guidance · DFSA · 2025-10-01· 4/4 anchored
Under consultationUnder consultation2025-10-31

Scope: This consultation paper proposes enhancements to the regulation of crypto tokens in the Dubai International Financial Centre (DIFC).

Gap or ambiguity: The document is a high-level notice, not the full consultation paper. The specific technical requirements are not detailed, creating an opportunity to influence the final rules during the consultation period.

Evidence (4) — verbatim quotes from the source
  • Regime
    The DFSA has released the following for consultation: Consultation Paper No 168 – Enhancements to the Regulation of Crypto Tokens
  • Status
    The DFSA has released the following for consultation: Consultation Paper No 168 – Enhancements to the Regulation of Crypto Tokens
  • Principal deadline
    The deadline for providing comments on this Consultation Paper is 31 October 2025.
  • Deadline type
    The deadline for providing comments on this Consultation Paper is 31 October 2025.
source ↗
Guiding Principles for the Financial Services Regulatory Authority's Approach to Virtual Asset Regulation and Supervision
guidance · FSRA · 2022-09-12

Scope: The provided text is a generic webpage from the ADGM website and does not contain the content of the specified regulatory guidance. The scope cannot be determined.

source ↗
Federal Decree-Law No. (8) of 2017 on Value Added Tax
statute · FTA · 2017-08-23

Scope: The provided text is a website error message, not the content of the specified law. No regulatory information could be extracted.

Gap or ambiguity: The legal text is missing from the provided body, which contains only a website error message.

source ↗
VARA Custody Services Rulebook — licensable activity of custody for virtual assets (Dubai)
regulation · VARA · · 3/4 anchored
LicensingImplementing2025-06-19

Scope: This rulebook defines the requirements for the licensable activity of providing custody services for virtual assets in Dubai.

Gap or ambiguity: The provided text is a cover page and does not contain the substantive articles of the regulation. Specific technical, security, or operational requirements are not detailed.

Evidence (3) — verbatim quotes from the source
  • Status
    (Effective From: 19 June 2025)
  • Principal deadline
    (Effective From: 19 June 2025)
  • Deadline type
    (Effective From: 19 June 2025)
source ↗
UAE Cabinet Decision No. 111 of 2022 on Regulating Virtual Assets and their Service Providers — federal foundation (in force 2023-01-14); designates SCA as competent federal authority; prohibits operating VASP activities (platform, exchange, transfer, custody, broker-dealer) without SCA or local-authority licence (e.g., VARA)
regulation · UAE Cabinet · 2022-12-15· 2/2 anchored
LicensingIn force

Scope: The law establishes the Dubai Virtual Assets Regulatory Authority (VARA) to license and regulate VASP activities in the Emirate of Dubai. Activities like exchange, transfer, and custody services require prior authorization from VARA.

Gap or ambiguity: This high-level text establishes the licensing requirement but does not specify the detailed technical or security standards for approval. This leaves an opportunity for certifiers to help firms demonstrate compliance with expected international standards.

Regulatory Compliance Support
Evidence (2) — verbatim quotes from the source
  • Regime
    VARA will be responsible for licensing and regulating the sector across Dubai’s mainland and the free zone territories (excluding DIFC).
  • Status
    VARA will be responsible for licensing and regulating the sector across Dubai’s mainland and the free zone territories (excluding DIFC).
source ↗
Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation
regulation · UAE Cabinet · 2025-10-29

Scope: The provided text is a general webpage from the UAE Ministry of Economy. It lists categories of legislation, including AML, but does not contain the substantive text of the regulation itself.

Gap or ambiguity: The full text of the regulation is not present in the provided content. The content is a general webpage, not the legal instrument.

SkyInsights — AML / KYT
source ↗
Cabinet Resolution on the Organisational Structure of the Ministry of Economy
regulation · MOEC · 2020-07-05· 0/1 anchored
In force

Scope: This resolution defines the organizational structure of the UAE's Ministry of Economy. It does not establish any regulations for crypto-assets or other economic activities.

Gap or ambiguity: The provided text is administrative and does not contain any substantive rules regarding crypto-assets, virtual assets, or related services.

source ↗
Cabinet Resolution No. (20) of 2020 regarding Services Fees Provided by the Ministry of Economy
regulation · MOEC · 2020-01-01

Scope: This resolution pertains to the service fees charged by the Ministry of Economy. The provided text does not contain any specific regulations for crypto-assets.

source ↗
Federal Law No. (7) of 2017 on Tax Procedures
statute · FTA · 2017-06-11

Scope: The provided text is a website error message (page not found) and does not contain the content of the referenced law.

source ↗
CBUAE Payment Token Services Regulation (PTSR) — Circular No. 2 of 2024 (effective Aug 2024) — stablecoin regime; distinguishes Dirham Payment Token (AED-backed, CBUAE-licensed issuer) from Foreign Payment Token (non-AED, CBUAE-registered issuer); licences issuance, custody/transfer, conversion; bans algorithmic stablecoins and privacy tokens as means of payment; 100% reserves; applies UAE-wide except DIFC/ADGM (but reaches VARA entities)
regulation · CBUAE · 2024-08-01· 5/9 anchored
LicensingIn force2024-08-31

Scope: This regulation establishes a licensing and registration framework for payment token (stablecoin) services in the UAE. It covers issuance, custody, and conversion, distinguishing between AED-backed tokens (licensed) and foreign currency-backed tokens (registered).

Gap or ambiguity: The regulation requires an independent assessment report from a 'competent and qualified assessor' (Art. 6.5-6) as a licensing prerequisite. However, it does not specify the standards or accreditation for these assessors, creating an opportunity for certifiers.

Due DiligenceIncident ResponseIndependent CertificationL1 Chain AuditPenetration TestingProof of ReservesRegulatory Compliance SupportSecurity GuidanceSkyInsights — AML / KYTSkynet — Threat MonitoringSmart Contract Audit
Evidence (5) — verbatim quotes from the source
  • Regime
    No Person shall perform any Payment Token Service within the UAE or directed to Persons in the UAE, unless such Person is Licensed or Registered by the Central Bank to perform such Payment Token Service.
  • Status
    C 2/2024 Effective from 31/8/2024Status: In-Force
  • Principal deadline
    Effective from 31/8/2024
  • Deadline type
    Effective from 31/8/2024
  • Requires independent certification
    The Applicant is required to submit an independent assessment report not older than six (6) months assessing how it will comply with Article (6)3, covering at least the following key areas:
source ↗
VARA Marketing Regulations 2024 — applies to ALL entities (domestic and foreign, licensed or not) promoting VAs in Dubai; utility-token issuers must register white paper with VARA ≥ 7 business days in advance
regulation · VARA · 2024-01-01· 1/2 anchored
RegistrationIn force

Scope: The regulation governs the marketing, advertising, and promotion of Virtual Assets in Dubai. It applies to all entities, whether domestic or foreign, licensed or not.

Gap or ambiguity: Utility token issuers must register a white paper with VARA prior to promotion. The specific technical or disclosure standards for these white papers are not detailed, creating a potential role for independent review.

Evidence (1) — verbatim quotes from the source
  • Status
    All Entities must comply with the Regulations on the Marketing of Virtual Assets and Related Activities 2024, issued by VARA, and as may be amended from time to time (“Marketing Regulations”), at all times.
source ↗
UAE VAT exemption for virtual assets (Cabinet Decision of 2024, effective 2024-11-15, RETROACTIVE to 2018-01-01) — transfer and conversion of virtual assets exempt from VAT (previously 5%); amendment to VAT Executive Regulation under Federal Decree-Law 8/2017; NFTs and some utility tokens may not qualify; mining for UAE-based third parties may attract VAT
regulation · FTA · 2024-11-15· 0/1 anchored
In force

Scope: This regulation amends the UAE's VAT Executive Regulation. It makes the transfer and conversion of virtual assets exempt from VAT, with retroactive effect.

Gap or ambiguity: The regulation states that NFTs and some utility tokens may not qualify for the VAT exemption. The specific criteria for this distinction are not defined.

source ↗
Outsourcing Regulation for Banks (Circular No. 14/2021)
regulation · CBUAE · 2021-05-31

Scope: The provided text is a '404 Page Not Found' error from the regulator's website and contains no substantive information about the regulation.

source ↗
Federal Law No. 15 of 2020 on Consumer Protection
statute · MOEC · 2020-11-10

Scope: This is a general consumer protection law. The provided text contains no substantive articles and does not mention crypto-assets.

Gap or ambiguity: The provided text is only metadata and internal notes, not the actual content of the law. It is impossible to determine its applicability or specific requirements for crypto-assets.

source ↗
Federal Decree-Law No. (36) of 2021 on Trademarks
statute · MOEC · 2021-09-20

Scope: This text concerns trademark law in the United Arab Emirates. It does not contain any provisions related to crypto-assets or virtual asset service providers.

source ↗
Federal Decree-Law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations
statute · MOJ · 2018-09-23

Scope: This decree-law establishes the framework for Anti-Money Laundering and Combating the Financing of Terrorism in the UAE. It aligns with FATF recommendations, including the Travel Rule.

Gap or ambiguity: The provided text does not contain the full regulation, making it impossible to identify specific gaps or ambiguities in its requirements.

SkyInsights — AML / KYT
source ↗
Dubai Law No. 4 of 2022 — Regulating Virtual Assets in the Emirate of Dubai; creates VARA (Virtual Assets Regulatory Authority); first dedicated VA regulator in the world; covers Dubai and its economic free zones except DIFC
statute · Government of Dubai · 2022-02-28· 3/4 anchored
LicensingIn force

Scope: This law establishes the Virtual Assets Regulatory Authority (VARA) and a mandatory licensing regime for Virtual Asset Service Providers (VASPs) in Dubai, excluding the DIFC.

Gap or ambiguity: The law delegates specific technical requirements to various Rulebooks (e.g., Technology and Information, Custody Services). The detailed standards for IT security, audits, and custody are not in this text, creating an opportunity for certifiers to address the specific controls mandated in those documents.

Incident ResponsePenetration TestingRegulatory Compliance SupportSecurity GuidanceSkyInsights — AML / KYTSkynet — Threat Monitoring
Evidence (3) — verbatim quotes from the source
  • Regime
    No Entity may carry out any VA Activity by way of business, or purport to do so, in the Emirate, unless it is— a. authorised and Licensed by VARA for the VA Activity;
  • Status
    The Dubai Virtual Assets Regulatory Authority (“VARA”) was established and authorised by Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai (“Dubai VA Law”) to regulate Virtual Assets and Virtual Asset Service Providers ("VASPs”).
  • Requires AML / KYT
    VASPs must comply with all Federal AML-CFT Laws as well as all other legislation, regulatory requirements, these Regulations, Rules and Directives in respect of AML/CFT as may apply to its VA Activities, businesses or operations in any jurisdiction at all times
source ↗
Stored Value Facilities (SVF) Regulation (Circular No. 6/2020)
regulation · CBUAE · 2020-09-30

Scope: The provided text is a 404 error page and does not contain the content of the regulation.

source ↗

Connected frameworks

How this jurisdiction inherits, is inspired by, or cites other regulatory texts.

Direct implementation

Binding transposition of a supranational anchor.

No edges.

Soft inspiration (9)

Non-binding alignment with standards or foreign law.

  • INTL-FATFRECS-2025
    relação tipada extraída do body (inline Dataview)
  • INTL-FSBGSCRECS-2023
    relação tipada extraída do body (inline Dataview)
  • EU-MICA-2023
    relação tipada extraída do body (inline Dataview)

Cross-citations (16)

Explicit citations in the body of norms.

  • AE-UAECR111-2022
    relação tipada extraída do body (inline Dataview)
  • AE-CP168-2025
    relação tipada extraída do body (inline Dataview)
  • AE-ADGMCFI2025462-2026
    relação tipada extraída do body (inline Dataview)
  • AE-AEMOECORG
    relação tipada extraída do body (inline Dataview)
  • AE-CBL14-2018
    relação tipada extraída do body (inline Dataview)
  • AE-CPR8-2020
    relação tipada extraída do body (inline Dataview)
  • AE-DAR1-2020
    relação tipada extraída do body (inline Dataview)
  • AE-OUTSRCREG14-2021
    relação tipada extraída do body (inline Dataview)
  • AE-RPSCSREG15-2021
    relação tipada extraída do body (inline Dataview)
  • AE-SVFREG6-2020
    relação tipada extraída do body (inline Dataview)
  • AE-VASPREG111-2022
    relação tipada extraída do body (inline Dataview)
  • AE-MOECORGSTRUCTURE
    relação tipada extraída do body (inline Dataview)
  • AE-MOECSERVICEFEES
    relação tipada extraída do body (inline Dataview)
  • AE-CABDEC111-2022
    relação tipada extraída do body (inline Dataview)
  • AE-CABDEC74-2020
    relação tipada extraída do body (inline Dataview)
  • AE-CABRES99-2024
    relação tipada extraída do body (inline Dataview)