The UAE regulatory landscape at mid-year: resilience, accountability and continued growth

The first half of 2026 has seen a steady stream of regulatory developments across the UAE’s financial sector. Looking back, one theme stands out above all others: resilience.

Yet resilience and regulatory maturity are closely linked. The market's ability to sustain its growth increasingly depends on firms maintaining credible governance, meaningful substance, and operating models that can withstand disruption.

Despite a complex geopolitical backdrop and heightened regional uncertainty, confidence in the region has remained strong. This is reflected in the continued growth of the DIFC, where the number of active registered companies exceeded 10,000 and the number of regulated financial firms increased by 16% compared with the same period last year¹. At the same time, regulators have continued to advance reforms, while firms already established in the DIFC and ADGM have largely maintained their investment and growth plans.

From a regulatory perspective, three themes have stood out during the first half of 2026.
 

The pace of regulatory development

The DFSA’s revised Conduct Principles framework, the FSRA’s enhancements to its AML framework and the DFSA’s consultation paper updates to the existing funds regime have all progressed at speed, reflecting regulators’ willingness to evolve frameworks as the market evolves.

Alongside formal rulemaking, regulators have also demonstrated a practical and proactive approach to supervision. Recent months have brought greater focus on operational resilience, business continuity planning and firms’ ability to navigate periods of disruption.

Firms have also reported active engagement with the regulators, including outreach exercises designed to assess their operational readiness and determine where additional support may be needed.

Together, these developments point to a regulatory approach that extends beyond introducing new rules. The emerging emphasis is on implementation, whether firms can demonstrate that their governance, controls and operational arrangements work effectively in practice.
 

The direction of travel: accountability and substance

Looking across the regulatory developments of the year so far, a clear direction emerges: higher governance standards, stronger senior management accountability and a greater emphasis on substance.

Regulators are encouraging firms to think more carefully about who holds responsibility for critical activities and whether governance arrangements are appropriate for their size, complexity and growth ambitions.

At the same time, the focus on substance continues to intensify. As the DIFC and ADGM mature into globally recognised financial centres, expectations are naturally rising.

A physical presence, on its own, is not enough. Firms need to show that they have the right local capabilities, clear decision-making responsibilities and governance arrangements that reflect what they actually do in the UAE.

Firms can expect an increasing emphasis on operational sophistication, meaningful local presence and governance frameworks that reflect international best practice.
 

Operational resilience moves to centre stage

While resilience has been a regulatory priority for some time, recent events have accelerated attention on firms’ ability to withstand disruption, maintain critical operations and support clients through periods of uncertainty. The regulatory response over the past six months has demonstrated that resilience is no longer viewed as a standalone compliance exercise. It is increasingly being treated as a core component of governance, risk management and long-term business sustainability.

For regulated firms, this means ensuring that business continuity plans are not simply documented, but tested, understood and capable of functioning under real-world conditions.
 

Looking ahead to the second half of 2026

For the remainder of the year, we expect continued supervisory focus on conduct and culture, alongside attention to how firms implement the FSRA’s enhancements to their AML frameworks and respond to increased scrutiny of substance requirements. In the DIFC, the DFSA’s Consultation Paper No. 173 on proposed enhancements to the Collective Investment Fund framework will be a key development to watch, with proposals aimed at aligning regulatory requirements more closely to the risk profile of funds and investors, improving clarity, and reducing unnecessary regulatory burden.

Governance, accountability and operational resilience are also likely to remain high on the supervisory agenda. As firms continue to grow, greater attention is likely to be paid to senior management responsibilities, prescribed roles and whether governance arrangements remain fit for purpose. Additionally, firms’ ability to maintain operational and financial resilience in a fast-moving and uncertain environment is likely to come under closer examination.  

The first half of 2026 has tested the UAE’s financial ecosystem, but its foundations remain strong. Regulatory expectations continue to rise, but the market itself is also becoming more sophisticated. Firms that build regulatory requirements into the way they operate will be better placed to grow sustainably.

The question now is whether firms’ governance, local capabilities and operational infrastructure can keep pace with their growth.

How Ocorian can help

We work across regulatory licensing, outsourced mandatory functions and fund administration, giving us direct insight into how these developments are affecting firms entering and expanding across the UAE. If the second half of 2026 raises questions about your firm’s regulatory readiness, we would welcome the conversation.

About the author

Veena Karuthasen is the consulting lead for UAE Regulatory & Compliance Services at Ocorian. She advises asset managers, financial institutions and founders on regulatory strategy, licensing, governance and compliance across the DIFC, ADGM and wider UAE, translating complex requirements into practical, commercially aligned solutions.
 

¹ DIFC, DIFC records industry leading achievement in H1 2026, 28 July 2026.