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A Broader Perimeter: The UAE’s New Dormant Accounts and Unclaimed Funds Regulation
4 min 40 sec
May 20, 2026 (Edited)
a.awad@tamimi.com 
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The Central Bank of the UAE issued on 10 November 2025 Circular No. 9/2025, titled the Dormant Accounts and Unclaimed Funds Regulation (the Dormancy Regulation), which repealed and replaced the Dormant Accounts Regulation previously set out in Circular No. 1/2020 (the 2020 Regulation).
Issued pursuant to Federal Decree-Law No. 6 of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business (Central Bank Law), the Dormancy Regulation took effect immediately upon publication in the Official Gazette. This article identifies the principal amendments introduced by the Dormancy Regulation as against its 2020 predecessor.
Broader regulatory perimeter
The most consequential change is the expansion of scope. The Dormancy Regulation now extends to all licensed financial institutions (LFIs), as defined in the Central Bank Law, expressly capturing exchange businesses and insurance companies alongside banks. Each category of LFI is now subject to tailored dormancy and unclaimed funds obligations calibrated to the nature of the activities it performs.
Consistent with this expansion, the regulation’s title has been revised to the Dormant Accounts and Unclaimed Funds Regulation. Its stated objective now encompasses the control and protection of dormant accounts and unclaimed funds and balances across all LFIs, and the enablement of customers or their legal heirs to reclaim such funds and balances.
New defined terms
The definitions section has been meaningfully expanded. New defined terms include: ‘exchange business’, ‘insurance company (insurer)’, ‘insurance policy’, ‘policyholder’, ‘interest’, ‘regulations’, ‘licensed financial activities’, ‘LFIs’, and ‘state’.
The definition of ‘interest’ is particularly notable: the treatment of ‘interest’ used in conventional finance applies equally to ‘profit’ used in Islamic finance, unless an exception is obtained from the Central Bank and the Higher Shari’ah Authority for Shari’ah compliance purposes.
The definition of ‘dormant customer’ has likewise been widened to encompass policyholders and beneficiaries of insurance policies, rather than being confined to account holders alone.
New categories of dormancy and unclaimed funds
The Dormancy Regulation preserves the pre-existing dormancy criteria applicable to bank deposit and investment accounts — the three-year trigger for demand, fixed-term and investment accounts remains unchanged — but introduces the following new categories of unclaimed funds.
- Exchange businesses: Funds received by an exchange business, including funds intended for onward delivery to a specified beneficiary that are made available but not collected or claimed, and where the customer cannot be located, within a period of one year.
- Insurance companies: The Dormancy Regulation introduces three operative limbs addressing:
- insurance of persons and fund accumulation operations where amounts payable to the customer or the customer’s legal heirs remain unclaimed for three years after becoming payable;
- property and liability insurance as well as insurance of persons and fund accumulation operations, where claims or refunds approved by the insurer remain unclaimed for three years after the claim is made or the refund is approved; and
- funds held in an insurance pool or pools without an active insurance policy that remain unclaimed for three years.
- Residual catch-all: Any funds and balances held by LFIs and not otherwise specified are to be treated as if they were individual or corporate savings, call, current or similar accounts, capturing product types that may fall outside the enumerated categories.
Safe deposit boxes: Updated statutory reference
The 2020 Regulation cross-referenced the now-superseded Federal Law No. 18 of 1993 on Commercial Transactions. The Dormancy Regulation updates this reference to Federal Decree-Law No. 50 of 2022 on the Issuance of the Commercial Transactions Law, which replaced the 1993 law. The Dormancy Regulation expressly requires judicial supervision when accessing or disposing of safe deposit-box contents in cases where the customer is absent or unresponsive.
A tripartite claims structure
The Dormancy Regulation now provides three distinct claims pathways in place of the single pathway under the 2020 Regulation. For LFIs excluding exchange businesses and insurance companies, claims are to be settled within one month, consistent with the 2020 position. Exchange businesses are subject to a new and notably shorter window of 14 days, while insurance companies should settle claims within one month.
Each pathway sets out prescribed record-keeping tables tailored to the transaction type: exchange businesses should record both sender and beneficiary identifying details, while insurance companies should record policy number, type, and claimant identifiers.
The Dormancy Regulation also refers expressly to ‘legal heirs’ throughout the claims provisions, clarifying the standing of successors to submit claims.
Prohibition on income recognition by exchange businesses
Exchange businesses are now prohibited from recognising unclaimed funds as income under any circumstances, and any unclaimed funds that were recognised as income during any financial year prior to the issuance of the Dormancy Regulation must be reversed.
The 2020 Regulation contained no analogous provision. The retroactive component of this obligation will require exchange businesses to revisit prior accounting treatments and effect any necessary restatements.
Transfer mechanics and new central bank holding accounts
The Dormancy Regulation preserves the five-year transfer threshold for traditional bank dormant account balances and related instruments, as well as the existing ‘unclaimed balances account – dormant accounts’ held at the Central Bank. It adds two new dedicated holding accounts:
- the ‘unclaimed balances account – unclaimed funds with exchange businesses’, to which exchange businesses must transfer, on a quarterly basis, funds that remain unclaimed for three years; and
- the ‘unclaimed balances account – unclaimed insurance funds”, to which insurance companies must transfer payable amounts that remain unclaimed for five years.
Non-bank LFIs are required to submit quarterly reports on transferred accounts and amounts through return forms and reporting systems prescribed by the Central Bank, rather than through the banking return forms used by banks.
The Dormancy Regulation prescribes new movement register formats for both exchange businesses and insurance companies and preserves the requirement to convert foreign currency balances to AED at the LFI’s published customer rates on the date of transfer.
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Dormancy Regulation introduces a prohibition that is both forward-looking and retroactive: exchange businesses are prohibited from recognising unclaimed funds as income under any circumstances, and any unclaimed funds that were recognised as income during any financial year prior to the issuance of the Regulation must be reversed.
Commencement
The Dormancy Regulation came into effect immediately upon its publication, compressing the transition period and requiring prompt operational readiness from LFIs — particularly exchange businesses and insurance companies — whose activities were not previously within the scope of the dormant accounts framework.
Conclusion
The Dormancy Regulation represents an evolution rather than a rewriting of the UAE’s dormant funds framework. For banks, much of the operating architecture established in 2020 remains intact.
However, for exchange businesses and insurance companies, the Dormancy Regulation marks a significant extension of regulatory perimeter: tailored dormancy triggers, dedicated transfer accounts at the central bank, bespoke claims timelines, and — in the case of exchange businesses — a retroactive prohibition on income recognition that will require historic ledger adjustments.
LFIs should audit their product inventories, customer communication protocols, reconciliation processes, and (where applicable) prior income recognition of stale balances against the amended framework without delay.
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