CBUAE’s New Insurance Licensing Regulation Reshapes UAE Market Entry

On 14 August 2026, the Central Bank of the UAE’s (“CBUAE”) Insurance Company Licensing Regulation (Circular No. 4/2026) (the “New Regulation”) became applicable, repealing and replacing the Insurance Authority Board of Directors’ Resolution No. 2 of 2009, the executive regulation to the original Federal Law No. 6 of 2007 on insurance (the “Executive Regulation”). The New Regulation is issued under Federal Decree-Law No. 6 of 2025 regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business, and must be read alongside the CBUAE’s Corporate Governance, Risk Management, Fitness and Propriety, Takaful and Minimum Capital regulations, all of which now form part of the licensing baseline for insurers.

What Has Changed?

Single CBUAE rulebook: Insurance licensing now sits within the CBUAE’s integrated financial-sector supervisory framework, rather than under a standalone Insurance Authority regime.

No more agent-based licensing for foreign insurers: The New Regulation only contemplates licensing branches of Foreign Insurance Companies, including those incorporated in a Financial Free Zone. The Executive Regulation’s reference to a foreign insurer operating “through a branch or an insurance agent” is not carried forward.

Codified, stricter timelines: Applications are treated as formally received only once complete. Applicants have 60 business days to cure deficiencies, failing which the application lapses with a six-month bar on reapplying. The CBUAE must then decide within 60 business days and notify its decision, with reasons for any rejection, within 20 business days.

Expanded licensing and registration criteria: Refusal grounds now expressly include the Fit and Proper Process, business plan viability, and corporate governance and risk management readiness. Annex 1 significantly expands required documentation to cover Group structure, ICT and cybersecurity systems, outsourcing arrangements, Emiratisation plans and, for foreign branches, a bank guarantee under Article 95 of the Central Bank Law.

Broader, standing CBUAE powers: The CBUAE may amend, revoke or impose new licence conditions “at any time” as it deems necessary, and may close a UAE branch for false information, breach of approval conditions, non-compliance or 12 months of inactivity. Companies may also now formally apply to withdraw a licence in whole or in part.

Elevated individual accountability: Sanctions for breach are no longer confined to suspending the company’s licensed activity. The CBUAE may withdraw, replace or restrict the powers of Senior Management or Board members, impose interim management, or bar individuals from the UAE insurance sector altogether.

Continuity on products: The core insurance classes and types (life/family, health, personal accident, funds accumulation, property and liability) are substantially unchanged, so no product reclassification is required.

What Should Market Participants Do?

Insurance companies, branches of foreign insurers, and prospective market entrants should review their licensing, registration and branch/subsidiary expansion documentation against the New Regulation’s expanded requirements, particularly on governance, risk management, ICT/cybersecurity and Fit and Proper evidence. Boards and Senior Management should also note their heightened personal exposure to CBUAE enforcement action.

How can we help?

Our insurance team regularly advises insurers, foreign insurance company branches and prospective entrants on CBUAE licensing, registration and branch/subsidiary applications across the UAE. We can assist with gap analyses against the New Regulation, licence and registration applications, and governance and Fit and Proper readiness reviews.

For further information on how the New Regulation may affect your business, please contact our insurance team.