Dubai Redraws Crypto Rulebook, Shifts Responsibility to Firms

The revised rules, which also enhance investor safeguards, refine conduct requirements and align the regime with international standards, are aimed at strengthening the region’s digital asset oversight and follow a consultation period in late 2025. They also reflect three years of supervisory experience since the regime’s original launch in 2022.

Responsibility shifts to firms

Under the updated framework, firms providing financial services involving crypto tokens, including trading, custody, asset management and advisory services, must now conduct their own documented suitability assessments for each token they handle, replacing the previous DFSA-led “Recognised Crypto Tokens” list. 

The whitelist of approved tokens will no longer be published.  The DFSA said the shift is designed to give firms greater clarity and flexibility while maintaining robust market integrity and transparency as digital asset markets evolve.

Earlier this month, a Dubai civil court explicitly recognised cryptocurrency as protected financial property under UAE law, ordering full compensation plus 5% annual interest in a high-profile theft case. 

That ruling removed the lingering ambiguity around crypto holdings, placing them on a similar footing to fiat currency and physical property.

Separately, the UAE has begun testing the Digital Dirham through limited government payments conducted on the BIS-led mBridge platform. While the pilot remains small in scope, it signals parallel progress on state-backed digital money infrastructure, particularly for settlement and cross-border use cases.

Crypto Regulation in the Dubai International Financial Centre (DIFC) 

• November 2022: DFSA launches its original Crypto Token Regime, requiring DFSA recognition for tokens and establishing a regulator-maintained list of recognised assets. 
   
• June 2024: Regulatory enhancements expand token treatment, fund investment rules, custody standards and token recognition criteria, including stablecoins.
   
• October 2025: DFSA issues a consultation (CP168) proposing reforms to shift towards firm-led token suitability assessment.
   
• December 2025: Updated framework finalised and published ahead of enactment, eliminating a central recognised tokens list.
   
• January 2026: New Crypto Token Regulatory Framework comes into force, placing suitability responsibility with regulated firms.