TRW & Co · Banking and finance
Financial Promotions Rules in the UAE, Including Finfluencers
Financial promotions UAE rules turn on who may send a message, to whom and from where. Onshore, the Capital Market Authority and Central Bank control marketing; the DIFC, ADGM and VARA run their own restrictions; and creators need an advertiser permit plus finfluencer registration when recommending financial products. This guide maps each regime and shows how to run a compliant campaign.
Key pointA creator can hold a valid UAE advertiser permit and still be unable to lawfully recommend a trading app: the media permit and the financial finfluencer registration are separate, and the brand is expected to check both.
At a glance
Five overlapping regimes
The CMA, Central Bank, DFSA, FSRA and VARA each police marketing within their own perimeter, and the National Media Authority licenses individuals who publish advertising content.
SCA became the CMA
Since 1 January 2026 the Capital Market Authority has replaced the SCA, and earlier SCA rules stay in force unless they conflict with the new laws.
Finfluencers must register
SCA Chairman Resolution No. 10 of 2025 requires individuals giving financial recommendations to the onshore public to register and to disclose conflicts and paid relationships.
Advertiser permit is separate
Individuals publishing promotional content need a National Media Authority advertiser permit; it is a media licence and does not authorise giving financial advice.
Free zone licence is local
A DFSA or FSRA authorisation covers marketing in that financial centre only; targeting onshore residents needs a separate onshore route or partner.
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The rules on financial promotions UAE firms and creators must follow come down to one question: who is allowed to send this message, to this audience, from this place? As of October 2026, the answer depends on the product and the location. The onshore Capital Market Authority, the Central Bank, the DFSA in the DIFC, the FSRA in ADGM and VARA in Dubai each police marketing within their own perimeter, and a separate media permit regime now covers paid content by individuals.
This guide explains what counts as a financial promotion, which regulator is engaged, how the finfluencer rules work for brands and creators, how to run a compliant campaign and the mistakes we see most often. It is written for marketing, compliance and legal teams at fund managers, brokers, banks, fintechs, crypto firms and the creators they work with.
The short answer: how financial promotions UAE rules work
There is no single UAE financial promotion code. Instead, five overlapping regimes apply depending on what is being marketed and where.
- Securities, funds and investment services onshore fall under the Capital Market Authority (CMA), which replaced the Securities and Commodities Authority (SCA) on 1 January 2026.
- Banking, credit, insurance and payment products onshore fall under the Central Bank of the UAE (CBUAE), whose 2025 law brings certain marketing of licensed activities inside its perimeter.
- Anything promoted in or from the DIFC or ADGM engages the DFSA or FSRA financial promotion restrictions.
- Virtual assets in or targeting the UAE from Dubai engage VARA's Marketing Regulations.
- Individuals who post promotional content need a National Media Authority advertiser permit and, if they give financial recommendations to the onshore public, registration as a finfluencer.
Most compliance failures happen at the overlaps: a free zone firm marketing to onshore residents, or a creator who holds a media permit but no financial registration.
What counts as a financial promotion
Each regime words the test differently, but the common idea behind financial promotions UAE law is simple. A communication is a promotion if it invites or induces someone to acquire a financial product or use a financial service. The format does not matter. A fund factsheet, a webinar, a podcast segment, a WhatsApp broadcast, a referral link and a short video comparing trading apps can all qualify.
Three features usually tip a message into promotion territory:
- A call to action. "Open an account", "join the waitlist", "use my code" or "DM me for the deck" all point the audience towards a transaction.
- A commercial link. Payment, free products, affiliate fees, equity or other benefits from the provider make neutrality hard to argue.
- A specific product or provider. Talking about inflation in general is commentary; recommending a named fund, token or broker is not.
Commentary, education and journalism
Genuine education and news reporting are treated differently from marketing in several regimes, but the exemptions are narrow. VARA, for example, recognises journalistic and educational content and private communications, yet "education" that ends with a sign-up link to a single exchange will rarely qualify. The safer working assumption is that anything paid for, or anything that steers people to a provider, is a promotion until analysed otherwise.
Who regulates financial promotions UAE-wide: the regulatory map
The first task in any campaign is to match the product and audience to the regulator. The table below is the starting map.
| What is marketed, and to whom | Regulator | Core legal basis | Usual route for a foreign or free zone firm |
|---|---|---|---|
| Securities, funds, portfolio management or advice to onshore investors | Capital Market Authority (CMA) | Federal Decree-Law No. 33 of 2025 on the Regulation of the Capital Market, plus SCA rules that remain in force | CMA-licensed local promoter or own licence; product registration where required |
| Deposits, loans, cards, insurance and payment services onshore | Central Bank of the UAE | Federal Decree-Law No. 6 of 2025 and CBUAE consumer protection rules | Partner with a CBUAE-licensed institution or obtain a licence |
| Any financial product promoted in or from the DIFC | DFSA | DIFC Regulatory Law and the DFSA Rulebook | DFSA-authorised firm, or a recognised exemption |
| Any financial product promoted in or from ADGM | FSRA | Financial Services and Markets Regulations and FSRA conduct rules | FSRA-authorised firm, or a recognised exemption |
| Virtual assets marketed in or targeting the UAE from Dubai (outside the DIFC) | VARA | Regulations on the Marketing of Virtual Assets and Related Activities | Marketing by, or approved by, a VARA-licensed provider |
| Promotional content posted by individuals | National Media Authority | Federal Decree-Law No. 55 of 2023 on media regulation | Creator holds an advertiser permit; brand verifies it |
Onshore: the Capital Market Authority
Federal Decree-Laws No. 32 and No. 33 of 2025 took effect on 1 January 2026, creating the Capital Market Authority as the SCA's successor and a new Capital Market Law. Earlier SCA decisions remain in force so far as they do not conflict with the new laws, until replaced. The law reaches persons who target UAE clients even from outside the country or from a financial free zone, which narrows the room for "offshore" campaigns.
Administrative fines can reach the greater of AED 200 million or ten times the illicit gain, so this is not a regime to test casually. Our securities regulation practice follows the CMA's implementing rules as they are issued.
Onshore: the Central Bank
The new Central Bank law, in force since 16 September 2025, lists certain promotion and marketing of licensed activities among the matters it regulates and confirms that a new technology or business model does not take an activity outside the perimeter. The CBUAE has also issued a telemarketing regulation in 2026 and applies consumer protection standards on fair, clear disclosure, including Arabic-language expectations for consumer products. For retail banking and insurance marketing, see our guide to consumer protection in banking and insurance.
The DIFC and ADGM
Both financial centres prohibit making a financial promotion in or from the centre unless the person is authorised by the local regulator or an exemption applies. Content rules follow a familiar common-law pattern: clear, fair and not misleading; risks as prominent as benefits; professional-only material labelled and kept away from retail clients. Authorisation in a centre covers that centre, not the onshore UAE. Our pages on DIFC financial regulation and ADGM financial regulation explain authorisation.
The finfluencer rules: what creators and brands must do
Social media is where most new enforcement attention on financial promotions UAE-wide now sits, and three separate rule sets can apply to the same post.
SCA finfluencer registration (now administered by the CMA)
SCA Chairman Resolution No. 10 of 2025, issued on 20 May 2025 and effective the next day, requires individuals who give financial recommendations to the public on the onshore UAE market to register with the regulator. It covers recommendations on financial products, virtual assets and regulated services, whether the issuer is local or foreign. Registrants must meet qualification or experience criteria, disclose conflicts, affiliations and paid relationships, separate fact from opinion, use current sourced data and carry appropriate risk warnings.
The resolution also reaches the other side of the deal. Issuers and licensed firms that use finfluencers are expected to confirm registration, review content before it goes out and keep records. Narrow carve-outs apply, for example to republishing information already approved by the regulator, to licensed firms acting within their permissions and to individuals operating from the financial free zones, but each should be read tightly. The regime continues under the CMA unless and until it is replaced.
The advertiser permit
Separately, federal media law requires individuals who publish advertising content in the UAE, paid or unpaid, to hold an advertiser permit from the National Media Authority. The registration deadline for existing creators was 31 January 2026. Visiting creators can obtain a temporary permit through a licensed agency. An advertiser permit is a media licence, not a financial one: a creator promoting a trading app may need both. Our page on media regulation covers the permit itself.
VARA's crypto marketing rules
VARA's Marketing Regulations took effect on 1 October 2024 and apply to marketing of virtual assets in or targeting the UAE, by licensed and unlicensed firms alike. Marketing must be carried out by, or approved by, a VARA-licensed provider; it must carry a prominent warning that virtual assets are volatile and can lose some or all of their value; and it must not describe investments as safe or guaranteed. Unsolicited airdrops and promotion of anonymity-enhanced tokens are prohibited. See our article on virtual asset marketing rules in Dubai and the VARA rulebooks.
A creator contract should list every authorisation the creator needs (advertiser permit, finfluencer registration where relevant) and every approval the brand needs (its own licence, VARA or regulator sign-off), and make pre-approval of each post a condition of payment. Screenshots and approval logs are what a regulator will ask for months later.
How to run a compliant campaign, step by step
Whether the product is a private credit fund or a payment card, the same disciplined sequence prevents most problems with financial promotions UAE regulators later question.
- Classify the product. Security, fund unit, deposit, credit, insurance, payment service or virtual asset. The classification fixes the regulator and often the licence you need.
- Define audience and geography. Retail or professional, onshore or free zone, existing clients or cold prospects. Record how you will geo-target and exclude audiences you cannot lawfully reach.
- Choose the legal route. Own licence, CMA local promoter, licensed bank or payment partner, DIFC or ADGM authorisation, VARA approval, or a documented exemption. Write the reasoning down in a short memo.
- Register or notify where required. Some foreign funds must be registered before onshore marketing; free zone funds may require notification to the DFSA or FSRA.
- Draft and approve content. Apply the relevant content rules, mandatory warnings, client-category labels and Arabic versions for consumers. A named approver signs off each item.
- Contract with intermediaries. Promoters, agencies and creators sign agreements with permit and registration warranties, approval rights, disclosure wording, takedown duties and audit access.
- Monitor, log and correct. Track complaints, creator posts and audience data. Withdraw or correct content quickly and keep evidence of what was published and when.
An illustrative scenario
Illustrative only; generic parties. A trading platform licensed in a financial free zone wants to grow among young professionals in Dubai. Its agency proposes ten creators, each posting a short video showing how they "made a return" using the app, with a referral code.
The analysis runs in layers. The platform's free zone licence covers marketing within that zone, not to onshore residents, so it needs an onshore route for the products concerned or must limit the campaign. Each creator needs an advertiser permit. Because the videos recommend a financial service to the onshore public, each creator is also likely to need finfluencer registration, and the platform must check it. If the app offers crypto, VARA's regime applies too, with its mandatory risk warning and its ban on implying guaranteed returns. Finally, "made a return" content invites a misleading-performance complaint under almost every regime.
The workable outcome is usually a narrower campaign: licensed onshore partner or route confirmed, fewer creators who hold the right permissions, scripted risk wording, no performance claims and a pre-approval workflow written into each contract.
Common mistakes with financial promotions UAE regulators see
Assuming a free zone licence covers onshore clients
A DFSA or FSRA authorisation is a licence for that centre. Marketing to someone living in Dubai Marina or a company licensed on the Abu Dhabi mainland is onshore activity, and the new Capital Market Law expressly reaches firms that target onshore clients from outside the country or from a financial free zone. Map the client base first, then plan the onshore route alongside the free zone one. The same works in reverse: an onshore broker cannot simply market into the DIFC or ADGM without considering their restrictions.
Treating reverse solicitation as a marketing channel
Reverse solicitation is a defence, not a strategy. It only helps where a client genuinely approached the firm first, unprompted by its marketing, and the firm can prove it. A pattern of "unsolicited" enquiries after a roadshow, dinner or creator campaign will be viewed sceptically, and commentators have noted uncertainty about how far the concept survives under the new Capital Market Law. Firms expecting regular UAE demand usually find a licensed local route cheaper over time than repeatedly defending exemptions.
Paying creators without checking permits and registration
Brands increasingly rely on creators for apps, cards and investment platforms. A creator without an advertiser permit exposes both sides to media-law penalties; a creator giving financial recommendations without registration exposes the brand, which is expected to verify status and review content. Build checks into onboarding, keep copies of permits and registration confirmations, and require the creator to notify you if either lapses during the campaign.
Running one global template in every market
Group marketing teams often push a single UK or EU-approved campaign to every region. UAE rules differ: different client categories, product registration, VARA's mandatory crypto warning, finfluencer registration and Arabic expectations for consumer material. A promotion compliant in London can still be unlawful in Dubai if no local route exists. Localise the legal analysis, not just the language.
Forgetting performance and risk balance
Across every regime, the content rules punish selective performance figures, missing risk warnings and claims that an investment is safe. Screenshots of gains, "passive income" language and countdown timers are common triggers. Present risks with the same prominence as benefits and keep the source data behind every number you publish.
Cross-border campaigns: UK, Singapore, India and the GCC
Many campaigns that raise financial promotions UAE questions originate abroad. A UK manager used to the FCA's financial promotion regime will recognise the DFSA and FSRA concepts, but must not assume that UK approval carries any weight onshore. Singapore and Indian platforms marketing to their diaspora in Dubai face the same issue: the UAE looks at where the audience is, not where the server sits.
Within the GCC, Saudi, Qatari and Bahraini regulators each run their own regimes, so a "GCC campaign" is really several campaigns. Geo-fencing, language choices and the platform's own advertising policies help, but they are evidence of intent rather than a legal exemption. For a view across all of this, start with our financial promotions practice page.
What to do next: a short checklist
Before the next campaign goes live, decision-makers should be able to answer yes to each of these questions about their financial promotions UAE exposure.
- Have we classified each product and identified every regulator whose perimeter it touches?
- Do we have a documented legal route for each audience, onshore and free zone?
- Are products registered or notified where the rules require it?
- Does every creator hold an advertiser permit, and finfluencer registration where relevant?
- Is there a named approver, a content log and a takedown process?
- Do our contracts with promoters, agencies and creators allocate these duties clearly?
Rules on financial promotions UAE regulators enforce are still settling as the CMA replaces SCA rules and the Central Bank implements its 2025 law. If you are planning a launch, a creator programme or a cross-border fund raise, contact TRW & Co to map the route before the first post goes out.
Frequently asked questions
01Do finfluencers in the UAE need a licence?
Often two. Anyone publishing promotional content in the UAE generally needs an advertiser permit from the National Media Authority. In addition, individuals who give financial recommendations to the onshore public on financial products, virtual assets or regulated services must register under SCA Chairman Resolution No. 10 of 2025, now administered by the Capital Market Authority. Registration requires qualification or experience, disclosure of conflicts and paid relationships, and balanced content. Narrow exemptions exist, for example for licensed firms acting within their permissions, so each creator's position should be checked rather than assumed.
02Can a DIFC or ADGM firm market to clients in Dubai or Abu Dhabi?
Not on the strength of its free zone authorisation alone. A DFSA or FSRA licence permits activity in or from that centre. Marketing to individuals or companies outside the centre is onshore activity, and the 2025 Capital Market Law reaches firms that target onshore clients from a financial free zone. Free zone firms usually need an onshore route, such as a CMA-licensed local promoter, a CBUAE-licensed partner or a fund passport where available, or must confine marketing to clients within the centre and keep evidence of that.
03Is reverse solicitation still allowed in the UAE?
Reverse solicitation, where a client approaches a foreign firm entirely on its own initiative, has long been relied on as a narrow defence. It is not a marketing method, and any pattern of enquiries following events or campaigns will be treated sceptically. Commentators have noted uncertainty about how the concept applies under the new Capital Market Law. Firms relying on it should keep the client's first written approach, avoid follow-up marketing of other products and consider a licensed local route if UAE demand is recurring.
04What warnings must crypto adverts in Dubai carry?
VARA's Marketing Regulations, in force since 1 October 2024, require marketing of virtual assets in or targeting the UAE to be clearly identifiable as promotional and to carry a prominent warning that virtual assets are volatile and may lose some or all of their value. Marketing must be fair, clear and not misleading, must not describe investments as safe or guaranteed, and must not urge immediate buying or selling. Unsolicited airdrops and promotion of anonymity-enhanced tokens are prohibited. The marketing must be done by, or approved by, a VARA-licensed provider.
05Does the brand share liability for a finfluencer's post?
It can. Under the SCA finfluencer resolution, issuers and licensed firms that engage creators are expected to confirm their registration, review content before publication and keep records. VARA's regime likewise requires crypto marketing to be done or approved by a licensed provider, and the media permit system extends to entities that commission promotional content. In practice the brand is the regulator's first port of call, so contracts should give it pre-approval, takedown and audit rights and require the creator to maintain all permits.
06Who regulates bank and credit card advertising in the UAE?
Onshore banking, credit, insurance and payment products are regulated by the Central Bank of the UAE. Its 2025 law brings certain marketing of licensed activities within its perimeter, and its consumer protection standards require clear, fair disclosure, key facts information and Arabic versions for consumer products. The Central Bank has also issued a telemarketing regulation in 2026. Unlicensed firms cannot market regulated banking products onshore and usually need a licensed bank or finance partner instead.
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, targeting of onshore clients and penalties
- Virtual Assets Regulatory Authority — Marketing Regulations and rulebooks for virtual assets
- ADGM Rules and Regulations — FSMR and FSRA conduct rules on financial promotions
- Dubai Financial Services Authority — DIFC financial promotion restriction and Rulebook
- CBUAE Rulebook — Consumer protection and marketing rules for licensed institutions
- National Media Authority — Advertiser permit for individuals publishing promotional content
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.
