Insurance Licensing in UAE : DMCC issues Circular on NOC requirement from UAE Central Bank

The Dubai Multi Commodities Centre (DMCC) has issued a circular (“Circular”) on 1 July 2025 directing all DMCC-licensed entities engaged in insurance and insurance-related activities to obtain the necessary approvals from the Central Bank of the UAE (“Central Bank”).

The Circular applies to all entities operating within DMCC that are licensed to undertake any of the following insurance-related activities:

• Insurance Consultancies
• Insurance Brokerage
• Reinsurance Services
• Insurance Claims Settlement Services

It has now been clarified that entities currently licensed for any of the above activities must obtain a formal No Objection Certificate (NOC) from the Central Bank to continue operations lawfully within the DMCC.

This directive aligns with the broader federal regulatory framework governing insurance activities in the UAE. The Central Bank is the principal supervisory authority for the insurance sector and regulates insurance operations primarily under the provisions of Federal Law No. 48 of 2023 on the Regulation of Insurance Activities (“Insurance Law”). The Insurance Law clearly sets out (a) what it regulates and (b) who does it regulate.

The Central Bank exercises regulatory oversight across the entire UAE, with the sole exception of the financial free zones—namely, the Dubai International Financial Centre (DIFC) and the Abu Dhabi Global Market (ADGM)—which operate under their own independent financial services regulatory regimes. Importantly, this exemption does not extend to non-financial free zones, such as DMCC. As a result, all insurance and insurance-related activities carried out in the UAE, including those in all non-financial free zones, fall within the jurisdiction of the Central Bank and must comply with its licensing and registration requirements. The issuance of the Circular reaffirms the existing regulatory position and makes clear that entities engaged in insurance consultancy, brokerage, reinsurance, and claims settlement services must obtain the necessary approvals from the Central Bank to lawfully continue their operations.

The Circular directs the DMCC-entities to regularise their status with the Central Bank by applying for their no objection to carry out insurance or its related activities within 30 days from the date of the Circular and provide the proof of such application to the DMCC within 30 days.  In our view, whether or not similar circular is issued by other non-financial freezones, similar restriction/requirement apply to those carrying out insurance activities from such freezones and the Central Bank is likely to start enforcing these requirements.

For DMCC entities engaged in insurance, the deadline to submit the copy of the no objection issued by the Central Bank is 31 December 2025, or at the time of license renewal of the DMCC entity whichever is earlier. Failure to meet these deadlines may result in regulatory sanctions, from DMCC as well as Central Bank, including suspension of the DMCC licence and/or the imposition of financial penalties.

How can we help?

Our team of insurance experts brings unrivalled experience in advising on licensing and regulatory compliance within the UAE insurance sector. We offer comprehensive, end-to-end support—covering the assessment of the Central Bank’s regulatory framework, preparation and submission of licensing applications, and liaison with the relevant regulatory authorities, and can assist with advising on these requirements and also with obtaining the NOCs.

For any further information, advice, or assistance with applications, please contact Anand Singh.