Book an appointment with us, or search the directory to find the right lawyer for you directly through the app.
Find out moreIn May Law Update’s edition, we examined the continued relevance of English law across MENA jurisdictions and why it remains a cornerstone of commercial transactions, dispute resolution, and cross-border deal structuring.
From the Dubai Court’s recognition of Without Prejudice communications to anti-sandbagging clauses, ESG, joint ventures, and the classification of warranties, our contributors explore how English legal concepts are being applied, interpreted, and adapted in a regional context.
With expert insight across sectors, including capital markets, corporate acquisitions, and estate planning, this issue underscores that familiarity with English law is no longer optional for businesses in MENA. It is essential.
2025 is set to be a game-changer for the MENA region, with legal and regulatory shifts from 2024 continuing to reshape its economic landscape. Saudi Arabia, the UAE, Egypt, Iraq, Qatar, and Bahrain are all implementing groundbreaking reforms in sustainable financing, investment laws, labor regulations, and dispute resolution. As the region positions itself for deeper global integration, businesses must adapt to a rapidly evolving legal environment.
Our Eyes on 2025 publication provides essential insights and practical guidance on the key legal updates shaping the year ahead—equipping you with the knowledge to stay ahead in this dynamic market.
At the start of 2025, Oman made sweeping changes to modernise its banking law, which included the promulgation of a new Banking Law. One of the key changes introduced was the concept of “digital banks”, defined under the new Banking Law as a “Licensed Bank to conduct Banking through digital platforms or channels using modern technological techniques”. Article 9 of the new Banking Law provides that the Central Bank of Oman (CBO) will regulate digital banks in accordance with rules and provisions specified. The CBO has, on 1 June 2025, issued the regulatory framework (CBO Decision 25 of 2025) for digital banks (“Regulatory Framework”), which will be the key framework by which digital banks can operate in Oman. Digital banks will also be regulated by, amongst other laws, the new Banking Law in respect of any penalties or enforcement actions.
There are two types of digital banking licenses under the Regulatory Framework. The first is a Category 1 Digital Banking License which allows a digital bank to carry out banking business without limitations. This license requires a minimum paid up share capital of OMR 30 Million if it is a locally incorporated joint stock company, or if it is a branch of a foreign bank, such capital requirements as determined by the governor of the CBO. The second is a Category 2 Digital Banking License, which can carry out banking business with restrictions such as: (i) the maximum deposit from a single customer and their related parties not exceeding 1% of the deposit portfolio, (ii) credit facilities to large corporates not exceeding 40% of the banks overall lending portfolio, and (iii) not being allowed to carry out any proprietary trading activities). It is important to note that restrictions (i) and (ii) do not apply for the first 2 years from the commencement of the digital bank’s business. This license requires a minimum paid up share capital of OMR 10 Million if it is a locally incorporated joint stock company, or if it is a branch of a foreign bank, such capital requirements as determined by the governor of the CBO. Digital banks will also be required to meet Omanisation requirements, starting from 50% in the first year and increasing by increments of 10% up to the fifth year, when it is required to be 90%.
The CBO decides within 90 days from the date of notifying the applicant that the application is complete whether the application is granted or rejected. No response from the CBO within that period shall be deemed approval. The necessary procedures for establishment of the digital bank shall be completed within one year from the date of grant of in-principle approval from the CBO, unless an extension is granted.
Applicants are also required to prepare and submit an exit plan (covering the first 5 years at least) to ensure that the licensed digital bank is able to voluntarily unwind its business operations without any regulatory intervention and in an orderly manner without causing any disruption to its customers and the financial system. The Regulatory Framework sets out what must be included in the exit plan, which includes: (i) management triggers for exiting the business; (ii) steps to manage customer funds, ongoing business, and continuing service; (iii) options relating to business which minimizes disruption to customers and the financial system; (iv) impediments to exit options and preparatory measures to mitigate such impediments; (v) sources of funding and liquidity for the exit (excluding assistance from the CBO) and estimated timeframe for exit.
In today’s increasingly digital age, this is a new option for both local and foreign entities who wish to tap into the Omani market. This development would be particularly encouraging for the numerous digital banks set up across the GCC.
How can we help?
Al Tamimi’s Banking and Finance Team in Oman has significant experience dealing with and advising both local and foreign entities on the regulatory obligations of banks in Oman. We would be delighted to assist.
To learn more about our services and get the latest legal insights from across the Middle East and North Africa region, click on the link below.