Fintech companies operating in the UAE have until roughly 16 September 2026 to meet the reconciliation deadline under a Central Bank Law that took effect exactly one year earlier. The transitional window closing has formally extended licensing requirements to open finance, money transfer and stored-value providers.
Federal Decree-Law No. (6) of 2025 replaced the UAE’s 2018 Central Bank Law, and Article 184 gave affected entities a one-year reconciliation period to regularise their position, a window that now has roughly two weeks left to run, according to , corroborated by and .
What the law changes
Article 61 is the operative section for fintechs. It names open finance, money transfer, virtual-asset payment services and stored-value or digital money services as licensed financial activities in their own right, formalising categories that had previously operated with less explicit regulatory definition. Article 62 closes an obvious workaround: it states that the use of a particular technology or business model does not, by itself, remove an activity from the Central Bank’s regulatory perimeter, language that legal analysis from Hadef & Partners notes explicitly captures decentralised finance platforms and decentralised applications.
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The law does not apply retroactively. Article 132 protects contracts and finance arrangements executed before the relevant implementing regulation was issued, meaning existing agreements remain valid. That protection covers agreements already in place, not ongoing operations, a company running a now-regulated activity without a licence does not gain an exemption for that activity simply because it began before the law changed.
A deadline with a live date discrepancy
Sources differ by a single day on the exact deadline. Hadef & Partners’ own analysis states the reconciliation period closes 15 September 2026, while several other legal-update sources put the date at 16 September 2026, one year to the day after the law’s 16 September 2025 effective date. None of the law firms cited have obtained direct confirmation from the Central Bank of the UAE on which date is operative, a detail worth resolving before treating either date as exact.
Who falls inside the newly defined perimeter
The reach extends beyond licensed banks. Companies described by Hadef & Partners as potentially in scope include fintechs, technology providers enabling regulated financial activity, and e-commerce retailers offering embedded financial services, in addition to licensed financial institutions already under Central Bank supervision.
Implementing regulations have arrived through 2026 rather than all at once: an Operational Risk and Operational Resilience Regulation and an Insurance Company Licensing Regulation in February, a Telemarketing Regulation on 31 March, and a Remuneration Regulation for banks and insurers in April. The September reconciliation deadline is the point at which compliance with the accumulated framework is due.
Penalties for missing it are substantial. Fines range from AED 50,000 to AED 500 million for conducting a licensed financial activity without authorisation, with potential imprisonment and personal liability extending to management. The Central Bank’s Board retains discretion to extend the reconciliation period, though no general extension had been announced as of the sources checked.
