UAE’s New Banking Law Expanded the Digital Perimeter. It Did Not Licence Every Fintech App

Updated 10 September 2026: the original version of this article overstated Article 62 of Federal Decree-Law No. 6 of 2025. The new Central Bank law did expand and modernise the regulatory perimeter, but it did not create a rule that every app, API, aggregator or technology provider touching finance automatically needs a CBUAE licence.

The Central Bank of the UAE has now published a detailed official FAQ clarifying the point. Article 62 does not create new categories of licensed financial activity. It says that activities already listed in Article 61 remain subject to CBUAE licensing and supervision when they are carried on through technology, whether directly or indirectly.

What Article 62 Actually Does

Article 62 says a person carrying on, offering, issuing or facilitating a Licensed Financial Activity remains within CBUAE’s licensing and supervisory jurisdiction regardless of the medium, technology or form used.

The law specifically mentions virtual-asset payment tokens, decentralised finance, dApps, protocols and technological infrastructure. But the technology is not the regulated activity by itself. The provision follows the underlying financial activity.

Start With Article 61, Not the App Store Category

Article 61 currently includes activities such as taking deposits, providing credit or funding, open finance, currency exchange, money transfer, stored value, retail payments, digital money, payment services using virtual assets, and arranging, promoting or marketing licensed financial activities. Insurance and related professions are also included in the consolidated framework.

That is the starting point. If none of those activities is being carried on by the technology company, Article 62 does not magically turn ordinary SaaS into banking.

Pure Technical Providers Are Not Automatically Licensed

This is the largest correction to the July article.

CBUAE’s current FAQ says Article 62 does not aim to regulate, license or prohibit technology-service providers in that capacity. Providers of software, infrastructure, purely technical solutions or emerging technology remain outside the licensing perimeter unless they themselves engage in, present themselves as engaging in, offer, issue or facilitate an Article 61 financial activity.

The FAQ goes further. Where a technology provider supplies software, infrastructure or technical solutions exclusively for the benefit of a licensed financial institution, that provision by itself is not treated as practising, offering, issuing or facilitating the financial activity.

So the old Robius examples — an API aggregator, payment integration or platform connecting to a bank — cannot be declared licensed or unlicensed from architecture alone. The contractual and operational role of the company matters.

Where Technology Companies Can Still Enter the Perimeter

The opposite mistake would be equally bad: assuming the word “software” creates an exemption.

A company deserves closer review when it itself operates a payment or wallet service, issues or controls stored value, provides or arranges credit, moves money, offers open-finance services, or otherwise professionally offers or facilitates a licensed financial activity. Article 61 also expressly includes arranging, promoting and marketing Licensed Financial Activities.

Decentralised infrastructure is not automatically outside the perimeter either. Article 62 was designed precisely so that the underlying regulated activity does not escape supervision merely because it is delivered through a protocol, token or new technical form.

The September 2026 Reconciliation Window Is Real

The law entered into force on 16 September 2025. Article 184 gives persons subject to the Decree-Law one year to reconcile their positions, and allows the CBUAE Board to extend that period.

CBUAE’s current legislation FAQ, checked on 10 September 2026, still describes the period as ending one year after the effective date and does not announce a general extension on that page.

There is a small public interpretation difference over whether the final calendar boundary is 15 or 16 September 2026. A business whose compliance depends on that distinction should not wait for the last day. Confirm the applicable deadline directly with CBUAE or qualified UAE regulatory counsel and document the position now.

The AED 1 Billion Penalty Needs Context

The original article placed the AED 1 billion maximum next to the deadline in a way that could be read as an automatic consequence. It is not.

CBUAE’s current FAQ describes Article 168 as providing a range of administrative and financial sanctions, including financial penalties from AED 100,000 up to AED 1 billion in applicable cases. Criminal offences under other provisions have their own requirements and penalty ranges.

The consequence depends on the conduct, the activity, the applicable obligation and the enforcement provision. “Miss the September date and receive a AED 1 billion fine” is not the law.

A Better Compliance Test for UAE Fintech

The Bottom Line

The 2025 Central Bank law is a significant modernisation of UAE financial regulation, and Article 62 is important because regulated financial activities remain regulated when technology changes the way they are delivered.

But the original Robius article overstated that principle into a broader claim that technology providers facilitating finance were generally pulled into licensing. CBUAE’s own clarification is narrower and more useful: identify the Article 61 activity, identify what the technology company itself does, then determine whether it is a regulated financial participant or a technical provider.

That distinction matters even more as UAE fintech apps increasingly combine banks, card issuers, payment institutions and software providers behind one interface. Regulate the activity and legal entity, not the logo.

Sources

• Central Bank of the UAE — Legislation FAQ: official clarification that Article 62 does not create new licensed-activity categories and that pure technical providers are not automatically subject to licensing — centralbank.ae

• CBUAE Rulebook — Article 61: current list of Licensed Financial Activities — rulebook.centralbank.ae

• CBUAE Rulebook — Article 62: licensed financial activities carried on through emerging technologies — rulebook.centralbank.ae

• CBUAE Rulebook — Article 184: one-year reconciliation period and Board power to extend — rulebook.centralbank.ae

Checked 10 September 2026. This article is general information, not a legal opinion on whether any particular business requires a CBUAE licence.

Robius.news — Dubai, UAE — 2026 | Built to be first. Built to be trusted.