TRW & Co · Banking, Finance & Capital Markets
Financial Promotions in the UAE
Financial promotions in the UAE are policed by several regulators at once: the new Capital Market Authority onshore, the Central Bank for banking and insurance, the DFSA and FSRA in the free zones, and VARA for crypto. With a new Capital Market Law in force since January 2026 and finfluencers now regulated, the route to market matters as much as the message.
Key pointA DIFC or ADGM licence does not authorise marketing to onshore residents: the Capital Market Law in force since 1 January 2026 expressly reaches free zone and offshore firms that target onshore clients.
At a glance
New onshore regulator
Since 1 January 2026 the Capital Market Authority has replaced the SCA, and promotion is a licensed activity under Federal Decree-Law No. 33 of 2025.
Local promoter required
Foreign issuers and fund managers market onshore through a CMA-licensed local promoter, and foreign funds generally need CMA registration before promotion starts.
Free zones are separate
The DFSA and FSRA each restrict financial promotions in or from their zones; authorisation there does not extend to onshore UAE investors.
Finfluencers now regulated
SCA Resolution No. 10 of 2025 requires social media financial recommenders to register, and creators also need a federal advertiser permit.
Crypto marketing rules
VARA marketing regulations in force since October 2024 require licensed-provider approval, mandatory risk warnings and eight years of marketing records.
Swipe or scroll →
What financial promotions in the UAE cover
Financial promotions in the UAE are any communication that invites or induces someone to buy a financial product or use a financial service: a fund factsheet emailed to a family office, a LinkedIn post about a new bond, a webinar on structured notes, a paid creator video about a trading app, or a banner advertising a credit card. The law looks at the effect of the message, not the format, so a WhatsApp voice note can be a promotion just as much as a glossy brochure.
The question becomes legal the moment a firm wants to reach UAE residents. A London manager raising a new fund, a Singapore broker onboarding expatriate clients, an Indian wealth platform targeting non-resident Indians in Dubai or a crypto exchange sponsoring a football club all face the same first issue: who is allowed to communicate this, to whom, and with what approvals?
There is no single UAE rule. Onshore securities and funds, onshore banking and insurance, the two financial free zones and virtual assets each have their own perimeter and their own regulator, and a general media law sits on top of all of them. Getting the map right is most of the work.
Who regulates financial promotions in the UAE
The starting point is to identify the product and the audience, then match them to the regulator. The table below is the map we use at the outset of most mandates.
| Product or audience | Regulator | Core rule | Typical route for a foreign firm |
|---|---|---|---|
| Securities, investment funds, portfolio management and advice to onshore investors | Capital Market Authority (CMA), formerly the SCA | Promotion is a licensed activity under the Capital Market Law | Appoint a CMA-licensed local promoter; register foreign funds before promotion |
| Bank accounts, loans, cards, insurance and payment services onshore | Central Bank of the UAE (CBUAE) | Only licensed institutions may offer regulated services; consumer protection standards govern advertising | Partner with a CBUAE-licensed institution or obtain a licence |
| Anything marketed in or from the DIFC | DFSA | Financial promotion restriction under DIFC legislation and the DFSA Rulebook | DFSA-authorised firm, or a recognised exemption |
| Anything marketed in or from ADGM | FSRA | Financial promotion restriction under the Financial Services and Markets Regulations | FSRA-authorised firm, or a recognised exemption |
| Virtual assets in or from Dubai (outside the DIFC) | VARA | Marketing Regulations 2024 | Marketing by, or approved by, a VARA-licensed provider |
| Paid or sponsored content by individuals | National Media Authority | Federal media law and advertiser permit | Creators hold an advertiser permit; brands verify it |
Two points catch firms out. First, the regimes overlap: a fund manager in the DIFC targeting onshore Dubai investors must satisfy both the DFSA and the CMA. Second, the free zones do not act as a shield. The new onshore Capital Market Law expressly reaches activities conducted from outside the UAE or from the financial free zones where they target onshore clients.
Onshore rules: the Capital Market Authority
From 1 January 2026, Federal Decree-Law No. 32 of 2025 replaced the Securities and Commodities Authority with the Capital Market Authority, and Federal Decree-Law No. 33 of 2025 on the Regulation of the Capital Market became the core statute. Promotion, financial advisory, portfolio management and fund management are all listed regulated activities, and nobody may carry them on without a CMA licence or approval.
Existing SCA decisions remain in force so far as they do not conflict with the new laws, until the CMA replaces them. That means the SCA Rulebook of Financial Activities (Board Decision No. 13/R.M of 2021) and the 2023 foreign fund promotion rules still set the day-to-day detail. Licensed firms were given one year from 1 January 2026 to regularise their status, which the CMA may extend.
The local promoter model
A foreign issuer or fund manager cannot hold the onshore promotion licence itself. It works through a CMA-licensed local promoter, typically a UAE bank, broker or licensed financial consultant, and the product must usually be registered with the CMA before any marketing starts. For foreign funds, the 2023 reforms limited onshore promotion to private placement with professional and counterparty investors; retail investors are reached through onshore or free zone feeder structures instead.
Exemptions that matter in practice
Three exemptions do most of the work. Reverse solicitation applies where an onshore investor genuinely approaches the foreign firm first, and the firm can prove it with documents. Government entities and their wholly owned companies are carved out of registration and local promoter requirements. And funds passported from the DIFC or ADGM follow a separate registration route through their home regulator. Each exemption is narrow and evidence-driven; none of them permits a general campaign.
Penalties under the Capital Market Law are significantly higher than under the old regime. Administrative fines can reach AED 200 million or a multiple of the profit made, and the law contains criminal offences for serious breaches. Our securities regulation practice tracks the CMA's implementing resolutions as they are issued.
Financial promotions in the UAE's financial free zones
The DIFC and ADGM run common-law, UK-style regimes. In each, a person may not make a financial promotion in or from the zone unless it is authorised by the local regulator or falls within an exemption. The DFSA's restriction sits in the DIFC Regulatory Law and the General module of its Rulebook, alongside specific restrictions in the Markets Law and the Collective Investment Law. ADGM's equivalent sits in the Financial Services and Markets Regulations and the FSRA Conduct of Business rules.
In both centres the content rules follow a familiar pattern: promotions must be clear, fair and not misleading; risks must be as prominent as benefits; past performance must carry warnings; and promotions aimed only at Professional Clients must say so and must not be passed to retail clients. Representative offices can market only their group's products and only within tight limits.
Foreign funds marketed in or from the DIFC must go through a DFSA-licensed firm with the right permissions. The DFSA funds guidance explains the routes, including marketing to Professional Clients with a minimum subscription of US$50,000 where there is no public offer. Our pages on DIFC financial regulation and ADGM financial regulation cover authorisation in more depth.
An authorisation in the DIFC or ADGM permits marketing within that zone. It does not permit marketing to onshore Dubai or Abu Dhabi residents. If your target list includes clients outside the zone, plan the CMA or CBUAE route at the same time, not after the first complaint.
Finfluencers, social media and virtual assets
Social media has become the main battleground for financial promotions in the UAE, and three regulators now address it directly.
The finfluencer registration regime
In May 2025 the SCA issued Chairman Resolution No. 10 of 2025, which requires individuals who give financial recommendations on social media about financial products, virtual assets or regulated services to register with the regulator. Registrants must meet qualification or experience criteria, disclose conflicts and paid relationships, separate fact from opinion and carry risk warnings. Firms that engage them are expected to check registration and review content first. The regime continues under the CMA unless replaced.
The advertiser permit
Separately, federal media law requires individuals who create advertising content in the UAE to hold an advertiser permit, issued by the National Media Authority, which took over the functions of the UAE Media Council. The permit became mandatory from 1 February 2026. It does not authorise financial advice; a creator may need both a permit and a financial registration. See our media regulation page.
Virtual asset marketing in Dubai
VARA's Regulations on the Marketing of Virtual Assets and Related Activities took effect on 1 October 2024. Marketing in or targeting the UAE must be carried out by, or approved by, a VARA-licensed provider; prominent volatility and loss warnings are compulsory; privacy tokens may not be marketed; unsolicited airdrops are banned; and records must be kept for eight years. Influencers cannot rely on the journalist exemption. Our virtual assets practice covers the licensing side.
The question is never just whether the message is accurate. It is whether the person sending it was allowed to send it, to that audience, from that place.
How to launch a compliant campaign
Whether the product is a private credit fund or a buy-now-pay-later card, a disciplined sequence avoids most problems with financial promotions in the UAE.
- Classify the product. Decide whether it is a security, fund unit, deposit, credit, insurance, payment service or virtual asset. The classification fixes the regulator and often the licence.
- Define the audience and channel. Retail or professional, onshore or free zone, existing clients or cold prospects, and which media: email, events, social media, creators or paid search.
- Choose the route. Own licence, local promoter, passport, licensed partner, or a documented exemption such as reverse solicitation. Record the reasoning in a short memo.
- Register the product where required. Foreign funds onshore need CMA registration before promotion; free zone funds may need notification to the DFSA or FSRA.
- Draft and approve the content. Apply the relevant content rules, risk warnings, target-market statements and Arabic versions where consumers are involved. A named approver signs off.
- Contract with third parties. Promoters, agencies and creators sign agreements with compliance warranties, approval rights, takedown obligations and audit access.
- Monitor and keep records. Track responses, complaints, creator posts and geo-targeting. Keep records for the period the relevant rulebook requires.
Documents and evidence to assemble
Regulators judge financial promotions on paper. When a query arrives, firms that can produce a clean file usually resolve it quickly; those that cannot face a much longer conversation. The core file should contain:
- the regulatory analysis memo identifying product, audience, regulator and route;
- copies of licences, the local promoter agreement and CMA, DFSA or FSRA registrations or notifications;
- the approved version of each promotion, with date, approver and distribution list;
- client categorisation records showing that professional-only material reached professional investors;
- reverse solicitation evidence, such as the investor's first written request, where that exemption is relied on;
- creator and agency contracts, advertiser permit and finfluencer registration checks, and content review logs;
- complaint logs and records of any withdrawn or corrected promotions.
For banks and insurers, the CBUAE's consumer protection framework adds disclosure documents, key facts statements and Arabic-language requirements. Our consumer finance page explains those standards.
Common mistakes with financial promotions in the UAE
Treating reverse solicitation as a marketing strategy
Reverse solicitation is a defence, not a channel. It works only where the investor genuinely made the first approach, unprompted by the firm's marketing, and the firm can prove it. Regulators look sceptically at a pattern of "unsolicited" requests that follow a roadshow, a dinner or a social media campaign. A firm that relies on it should keep the investor's first written approach, avoid follow-up marketing of other products, and limit the conversation to what was asked. Where a manager expects repeated UAE interest, a local promoter or passport is almost always the safer and cheaper route over time.
Assuming a free zone licence covers onshore clients
A DFSA or FSRA authorisation is a strong credential, but it is a licence for that zone. Marketing to an individual living in Jumeirah or a company licensed on the Abu Dhabi mainland is onshore activity. The Capital Market Law now states expressly that it reaches activities from the free zones that target onshore clients. Free zone firms should map their client base, use passporting where available for funds, and appoint a local promoter or partner for anything else. The same applies in reverse: an onshore broker cannot market into the DIFC without considering DFSA rules.
Paying creators without checking their status
Brands increasingly use creators for trading apps, cards and investment platforms. Each creator may need an advertiser permit, and anyone giving financial recommendations may need finfluencer registration. Under the SCA resolution, firms that engage non-compliant finfluencers can share responsibility. Contracts should require proof of permits and registration, give the firm pre-approval of every post, require standard risk wording and disclosures of payment, and allow immediate takedown. Keep screenshots, because posts disappear and regulators ask for evidence long after the campaign ends.
Using one global template for every market
Group marketing teams often push a single campaign to every region. UAE rules differ in material ways from UK, EU and Singapore rules: different client categories, different exemptions, CMA product registration, VARA's mandatory crypto warnings and Arabic-language expectations for consumer products. A UK-compliant promotion may still be unlawful in Dubai if no local route exists. Build a UAE overlay into the approval workflow, with a local reviewer who checks the route as well as the wording.
Forgetting events, sponsorships and introductions
Conferences, sponsorship deals and introducer arrangements are common entry points to the UAE. A stand at a Dubai event or a sponsored dinner for prospective investors is marketing. Introducers who receive fees for referring clients may themselves be carrying on a regulated activity. VARA's rules specifically require event organisers to obtain undertakings from exhibitors. Review sponsorship agreements and introducer fees before the event, not after.
Cross-border marketing into and out of the UAE
Most financial promotions in the UAE have a foreign leg, and the counterpart rules matter as much as the local ones.
United Kingdom. UK managers are used to the FCA's financial promotion restriction and its exemptions. The DIFC and ADGM regimes will feel familiar, but onshore UAE rules do not follow the UK model, and UK exemptions such as those for high net worth individuals do not carry across.
Singapore and China. Singapore-licensed firms often serve Gulf clients from Singapore. The UAE perimeter still applies when they solicit UAE residents, and MAS will expect them to respect host-country rules. Chinese asset managers entering through the DIFC or ADGM should plan the onshore route early if Chinese-speaking onshore investors are the target.
India and Bangladesh. Many UAE residents are non-resident Indians and Bangladeshis, and home-country platforms target them heavily. Indian and Bangladeshi rules govern what the home firm may do; UAE rules govern whether it may solicit in the UAE. Remittance-linked investment products need particular care because they may cross the CMA and CBUAE perimeters.
Saudi Arabia and the GCC. UAE-based managers frequently market regionally. Saudi Arabia's Capital Market Authority has its own private placement rules, so a UAE campaign cannot simply be extended across the border. GCC fund passporting is under development but should not be assumed to be operational for any given product.
How TRW & Co helps with financial promotions
We advise issuers, fund managers, banks, fintechs and brands on financial promotions in the UAE, from the first perimeter question to campaign sign-off and regulator correspondence. Where representation before UAE onshore courts or the DIFC/ADGM Courts is required, we work alongside locally licensed advocates and registered practitioners.
Perimeter and route analysis
We classify the product and audience, identify every regulator in play and recommend the most efficient route: own licence, local promoter, passport or exemption. The result is a short memo your board and compliance team can rely on.
Fund marketing programmes
We structure UAE marketing for foreign and free zone funds, coordinate CMA registration through local promoters, and align DFSA or FSRA notifications. See our investment funds page.
Content review and approvals
We review decks, factsheets, web pages, app flows and social media scripts against the applicable rules and build a UAE overlay into your group approval workflow.
Creator and agency contracts
We draft creator, agency and sponsorship agreements with permit and registration checks, approval rights, mandatory wording, payment disclosure and takedown clauses.
Virtual asset marketing
We advise exchanges, token issuers and brokers on VARA, DFSA and FSRA marketing rules, including incentives, airdrops and event participation.
Regulator queries and investigations
When a regulator asks about a campaign, we help assemble the evidence, frame the response and agree remediation. Our regulatory investigations team handles escalated matters.
Checklist for decision-makers
- Have we classified the product and identified every UAE regulator whose perimeter it touches?
- Do we know whether each recipient is onshore or in a free zone, and retail or professional?
- Is there a documented route for each audience: licence, local promoter, passport or exemption?
- Are foreign funds registered with the CMA, or passported, before any onshore marketing starts?
- Does every promotion have a named approver, a dated final version and a distribution record?
- Do creators hold an advertiser permit and, where they give recommendations, finfluencer registration?
- Do crypto campaigns carry VARA's mandatory warnings and avoid prohibited incentives?
- Have we checked the CMA's latest implementing resolutions since the 1 January 2026 transition?
If any answer is uncertain, contact TRW & Co before the campaign goes live. You can also browse all our practice areas, including our work on market conduct.
Frequently asked questions
01Can a foreign fund manager send a pitch deck to UAE investors?
Only through a lawful route. Onshore, foreign funds are generally marketed by private placement to professional investors through a CMA-licensed local promoter after CMA registration. In the DIFC or ADGM, the marketing must be done by an authorised firm or under an exemption. A genuinely unsolicited request from an investor may be answered under the reverse solicitation exemption, but the manager should keep evidence of the first approach and avoid wider marketing. Sending decks to a purchased list of Dubai contacts without a route is a breach.
02Did the move from the SCA to the CMA change the promotion rules?
The legal foundation changed on 1 January 2026, when Federal Decree-Laws No. 32 and 33 of 2025 took effect. Promotion remains a licensed activity, the regulator gained stronger enforcement powers and the law now expressly reaches free zone and offshore firms targeting onshore clients. Existing SCA decisions, including the Rulebook of Financial Activities and the 2023 foreign fund rules, continue unless they conflict with the new laws or are replaced. Licensed firms have a transition period to regularise their status, so check for new CMA resolutions before each campaign.
03Do influencers need a licence to talk about investments in the UAE?
Often they need two things. Federal media law requires individuals creating advertising content to hold an advertiser permit, mandatory since 1 February 2026. Separately, SCA Resolution No. 10 of 2025 requires people giving financial recommendations on social media to register with the regulator, subject to exclusions such as licensed advisers acting within scope and individuals in the financial free zones. Crypto promotion in Dubai must also comply with VARA rules. Brands should check both statuses and contract for compliance.
04Is marketing to high net worth individuals exempt?
Not automatically. Onshore, foreign funds may be offered to professional investors, a category defined by the regulator with wealth, income and experience criteria, but the promotion must still go through a licensed promoter and a registered product. In the DIFC and ADGM, individuals can be classified as Professional Clients if they meet the rulebook tests and the firm documents the assessment. There is no general UK-style high net worth exemption that lets an unlicensed firm market freely.
05What happens if we breach the promotion rules?
Consequences depend on the regulator. The Capital Market Law allows administrative fines that can reach AED 200 million or a multiple of the profit made, licence suspension and, for serious cases, criminal referral. The DFSA and FSRA can impose fines, public censure and restrictions. VARA has a schedule of fines and can suspend marketing. Investors who suffer loss may also bring civil claims against the firm. Early remediation, a clean evidence file and candid engagement usually improve the outcome.
06Do bank and insurance advertisements follow the same rules?
No. Deposits, loans, cards, insurance and payment services are within the Central Bank of the UAE perimeter, not the CMA perimeter. The CBUAE consumer protection framework requires advertising to be clear, fair and not misleading, with prominent fees and key terms and Arabic versions for consumers. Only licensed institutions may offer these products. A foreign bank or fintech usually reaches onshore customers by partnering with a CBUAE-licensed institution, and joint campaigns should allocate approval responsibility clearly.
07Can a DIFC firm market to clients in mainland Dubai?
A DFSA-authorised firm may market within the DIFC under its permissions, but soliciting onshore residents is a separate question. For funds, the UAE passporting arrangements let qualifying DIFC and ADGM funds be registered for onshore promotion through the home regulator. For other products, the firm generally needs a CMA-licensed partner or its own onshore licence. Many DIFC firms run a two-track model: free zone clients served directly, onshore prospects routed through a licensed local promoter.
Sources and official materials
- Capital Market Authority — Onshore securities and funds regulator since 1 January 2026
- Federal Decree-Law No. 33 of 2025 on the Regulation of the Capital Market — Licensed activities including promotion; scope and penalties
- Federal Decree-Law No. 32 of 2025 on the Capital Market Authority — Establishes the CMA in place of the SCA
- DFSA: Collective Investment Funds — Marketing foreign and DIFC funds in or from the DIFC
- ADGM Rules and Regulations — FSMR and FSRA conduct rules on financial promotions
- Virtual Assets Regulatory Authority — Marketing Regulations for virtual assets in Dubai
- Central Bank of the UAE — Licensing and consumer protection for banking and insurance
General information only, current as at 27 October 2026. It is not legal advice and does not create a lawyer–client relationship. UAE law differs between the onshore jurisdiction, the DIFC, ADGM and the free zones, and changes frequently; check current official sources and take advice on the facts of your matter.
