Two clocks are running for UAE digital-asset businesses. Different authorities, different instruments, different dates.
The Central Bank. Federal Decree-Law No. 6 of 2025 has been in force since 16 September 2025.
Article 62 is the one to read. Anyone carrying on, offering, issuing or facilitating a licensed financial activity falls under the Central Bank's jurisdiction, "regardless of the medium, technology, or form employed." The article then names what it means: virtual asset payment tokens, decentralised finance, dApps, protocols, supporting infrastructure. Article 61 puts payment services using virtual assets on the list of licensed activities outright.
The timeline sits in Article 184. Persons subject to the law have one year from entry into force to "reconcile their respective positions with its provisions." That falls on 16 September 2026. The same article lets the Board of Directors extend it.
Scope is set in Article 2: the law does not apply to the Financial Free Zones, or to institutions regulated by their authorities.
The CMA. The Capital Market Authority, formerly the Securities and Commodities Authority, has replaced its virtual assets framework. Resolution No. 04/Chairman of 2026 covers virtual asset service providers and alternative trading system operators, and abrogates SCA Decision No. 26/RM/2023.
The CMA's regulations listing records it as issued on 12 February 2026 and active from 27 February 2026. Its announcement of 13 April describes an integrated regime: five core modules, eight regulated activities, with modules covering licensing and accreditation, conduct of business, capital adequacy and AML/CFT.
If you are planning around a specific date, confirm it with the CMA.
Register moves. VARA's register now lists 54 licensed VASPs, alongside 21 in-principle approval entries, of which 19 are live and two withdrawn. An in-principle approval permits nothing: no virtual asset activity, no clients, until it converts.
Two licences were granted on 7 August, to Flowdesk Omega FZE for broker-dealer services and to DIMENT VA Exchange Services DMCC. Flipster FZE was licensed for exchange services on 14 July.
The register has also started showing CMA registration numbers next to VARA licence references. Flipster carries one. Flowdesk does not. It is the first visible trace of how the two regimes are recorded against a single firm, and worth watching as entries update.
Enforcement. VARA publishes 37 fines, and a separate list of 38 firms found operating without a licence. The most recent entry, from 13 January, concerns advertising and marketing virtual asset activities in Dubai without authorisation, met with cease-and-desist orders and financial penalties.
The pattern is worth noting. A significant share of published actions concern marketing and promotion rather than trading.
Abu Dhabi. ADGM granted 29 new Financial Services Permissions in Q1 2026, up 45% on the same quarter last year, alongside 22 in-principle approvals. Its financial services population reached 365, from 281 a year earlier.
Dates that matter. 16 September 2026, the Article 184 reconciliation period falls due, subject to extension by the Central Bank's Board.
The Read. The licensing race is over. What comes next is the cost of staying licensed: capital floors, resident accredited officers, conduct and capital adequacy modules, whole rulebooks where there used to be a category.
Those costs are largely fixed, which means they land hardest on the smallest names on the register. Nineteen firms hold approvals they cannot yet use. Fifty-four hold licences they now have to afford.
The number worth watching this year is not how many licences get granted. It is how many get handed back.
Sources. CBUAE Rulebook, Federal Decree-Law No. (6) of 2025, Articles 2, 61, 62 and 184. VARA public register and enforcement lists. UAE Capital Market Authority regulations listing and announcement of 13 April 2026. ADGM announcement of 18 May 2026. All verified 12 August 2026.
The Gulf Ledger is published weekly by Cadenx and written by Arpit Sharma. Regulatory intelligence, not legal advice. Verify current status with the relevant regulator or counsel. Corrections: reply to this email.