UAE Crypto Regulation in 2026: What Changed and What Expired

A compliance manual is a dated document even when nobody puts a date on it. It reflects the rules that existed when somebody wrote it, and it keeps reflecting them until somebody checks.

For any company running or planning a digital asset operation in the UAE, that is a live problem this year. Between June 2025 and April 2026 the country replaced or substantially amended nearly every layer of the framework governing digital assets and financial crime. Eight changes across seven dates, coming from both financial free zone regulators, the federal capital markets regulator, and federal legislation itself.

None of this was hidden. Each change was announced, consulted on and published. The difficulty is cumulative rather than individual: a structure built in 2024 was built against a set of rules that has since been largely rewritten underneath it. Ape Law, a UAE-based crypto-native legal practice, spends a fair amount of time on exactly this kind of retrofit, and the recurring finding is that the documents lag the law by about a year.

Ten months, seven changes

The practical weight of this falls on companies that made structural decisions in 2024 or early 2025 and have not revisited them since. A business that picked a UAE base two years ago picked it against a different federal perimeter and a different set of free zone rules. That does not make the original choice wrong. It does mean the reasoning behind it deserves a second reading, and it is why setting up a crypto company in ADGM now runs through a different set of questions than it did eighteen months ago.

One date still ahead

Everything above has already happened. One deadline has not.

The Central Bank law that took effect in September 2025 gave entities caught by its widened licensing perimeter a one-year transitional period to bring their positions into line. That period runs to 16 September 2026. Article 62 extends the licensing requirement to anyone who carries on, offers, issues or facilitates a licensed financial activity regardless of the technology or form used, which is the provision that pulled payment infrastructure, virtual asset payment services and a range of technology enablers into scope. The Central Bank may extend the transitional period at its discretion, and has since published guidance addressing scope questions raised by Article 62.

The practical point for a business that concluded in 2024 that it sat outside the Central Bank’s perimeter is that the conclusion was reached under a law that no longer exists. Worth confirming while the window is open.

The clearest place to check first

Of everything on that list, the anti-money laundering change is the easiest to audit and the most likely to have been missed.

Federal Decree-Law No. 20 of 2018 was the UAE’s anti-money laundering law for seven years. It was repealed by Federal Decree-Law No. 10 of 2025, which the UAE’s legislation portal records as issued on 30 September 2025 and effective from 14 October 2025. Two months later, Cabinet Decision No. 134 of 2025 replaced the 2019 executive regulations that sat beneath the old law.

So both halves of the previous framework are gone. Any risk assessment, internal policy, onboarding procedure or staff training deck that still cites the 2018 law or the 2019 regulations is citing repealed legislation. That is a five-minute check, it requires no legal advice to perform, and it is the sort of thing a supervisor notices immediately.

The new law also widened who is caught. Virtual asset service providers are now expressly within scope rather than being pulled in by interpretation, and proliferation financing sits alongside money laundering and terrorist financing as a named concern.

What is worth re-reading

Four documents tend to carry the most stale assumptions.

The structure chart, because the entity that made sense under the old federal perimeter may sit differently under the new one. The AML policy, for the reasons above. Any cost model built from published fee guidance, because ADGM revised its fee treatment in June 2025 and a good deal of secondary commentary still describes the earlier arrangement. And any board paper that recommended a jurisdiction, because the comparison it relied on has moved on all sides.

There is a version of this that becomes an expensive rebuild and a version that is a morning’s work with counsel. The difference is usually how long the gap has been left.

Frequently asked questions

What changed in UAE crypto regulation between 2025 and 2026?

Seven significant changes took effect. ADGM amended its digital asset framework in June 2025. The Central Bank law was replaced in September 2025. The anti-money laundering law was replaced in October 2025 and its executive regulations in December 2025. Two federal capital markets laws took effect on 1 January 2026, creating the Capital Market Authority. The DFSA updated its crypto token rules on 12 January 2026. The CMA announced a Virtual Assets Framework on 13 April 2026.

Is the UAE’s 2018 anti-money laundering law still in force?

No. Federal Decree-Law No. 20 of 2018 was repealed by Federal Decree-Law No. 10 of 2025, effective 14 October 2025. Its executive regulations under Cabinet Decision No. 10 of 2019 were replaced by Cabinet Decision No. 134 of 2025, in force from 14 December 2025. Compliance documents still referencing the 2018 or 2019 instruments are out of date.

What happened to the Securities and Commodities Authority?

It was reconstituted as the Capital Market Authority under Federal Decree-Law No. 32 of 2025, which took effect on 1 January 2026 alongside Federal Decree-Law No. 33 of 2025 governing the capital market. The CMA carries a broader mandate than the SCA did, including virtual asset activities at federal level.

Do companies in ADGM or the DIFC need to review the federal changes?

Yes, at least to confirm where they stand. Activity conducted solely within ADGM or the DIFC sits with those centres’ own regulators. But the federal capital markets legislation reaches a person targeting clients in the UAE even where the activity is carried on from a financial free zone, so a free zone entity marketing into the wider UAE market should take advice rather than assume it is outside the perimeter.

Is there a UAE compliance deadline coming up?

Yes. Entities brought within the Central Bank’s licensing perimeter by Federal Decree-Law No. 6 of 2025 were given a one-year transitional period, running to 16 September 2026, to bring their positions into compliance. The Central Bank may extend that period at its discretion. A business that assessed its Central Bank position before September 2025 assessed it against a law that has since been replaced, which makes the assessment worth repeating.

This article is general information about UAE regulatory frameworks and does not constitute legal advice. Requirements depend on the specific activity, structure and client base involved. The position described reflects published rules as at August 2026.