UAE Insurance Licensing Rules Tighten for Brokers and Agents Outside DIFC and ADGM

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New licensing rules for UAE insurance agents and brokers operating outside DIFC and ADGM.

Federal Decree-Law No. 6 of 2025 consolidates UAE banking, fintech and insurance supervision under the Central Bank of the UAE (CBUAE), replacing the former Insurance Authority.
Insurance brokers, agents, consultants and other intermediaries are now classified as providers of Licensed Financial Activities, requiring formal CBUAE authorisation.
Non-financial free zones - including DMCC, JAFZA and RAKEZ - fall within CBUAE jurisdiction; only DIFC and ADGM retain independent regulatory regimes.
DMCC issued a circular on 1 July 2025 requiring all insurance-related entities in the free zone to obtain a CBUAE No Objection Certificate (NOC) by 31 December 2025.
The Insurance Brokers' Regulation 2024, effective from 15 February 2025, imposes stricter governance, capital adequacy, conduct and professional qualification requirements on licensed brokers.
Non-compliant firms face administrative fines of up to AED 1 billion, licence suspension and personal liability for senior individuals under the new law.

Federal Decree-Law No. 6 of 2025 Reshapes UAE Insurance Supervision

The enactment of Federal Decree-Law No. 6 of 2025 marks a pivotal shift in how the UAE regulates insurance distribution. The Central Bank of the UAE (CBUAE) now oversees all insurance-related activities across onshore UAE and non-financial free zones, having absorbed the former Insurance Authority as the primary supervisory body. This consolidation brings insurance brokers, agents and consultants firmly within the same regulatory perimeter as banks and payment service providers.

In parallel, the Insurance Brokers' Regulation 2024 - effective from 15 February 2025 - raises the bar for licensed intermediaries on governance, capital adequacy and professional standards. The Dubai Financial Services Authority (DFSA) in DIFC and the Financial Services Regulatory Authority (FSRA) in ADGM retain independent oversight within their own jurisdictions. However, all other UAE free zones - including the Dubai Multi Commodities Centre (DMCC) - now fall squarely within CBUAE's remit for insurance business and insurance-related services.

What the New Law Changes

Federal Decree-Law No. 6 of 2025 consolidates banking, fintech and insurance supervision into a single federal framework. It explicitly includes "insurance-related professions" - brokers, agents, surveyors, loss adjusters, actuaries and health insurance third-party administrators - within the definition of Licensed Financial Activities. This means these professionals are now treated as regulated financial services providers, not merely commercial intermediaries, according to analysis by Al Tamimi and Company.

The law applies across the UAE, including entities incorporated in non-financial free zones. DIFC and ADGM retain their existing carve-out, with insurers and intermediaries there continuing to operate under the DFSA and FSRA respectively. For all other entities, a CBUAE licence or formal authorisation is the baseline requirement for carrying on insurance business or insurance-related activities.

The Non-Financial Free Zone Question

A critical clarification in the 2025-26 reforms concerns free zones that are not designated financial centres. Non-financial free zones - including DMCC, Jebel Ali Free Zone (JAFZA), Sharjah Airport International Free Zone (SAIF Zone) and Ras Al Khaimah Economic Zone (RAKEZ) - fall within CBUAE jurisdiction for insurance activities. This is framed not as a new policy but as enforcement of a long-standing principle: federal financial regulation takes precedence over free-zone commercial licensing in regulated sectors.

Legal commentaries published in early 2026 note that many firms previously relied on non-financial free-zone trade licences alone to provide insurance consultancy, brokerage or claims services. According to analysis published by Gibson Dunn, this practice is now explicitly non-compliant. Entities that service onshore UAE clients from non-financial free zones must hold a CBUAE licence or obtain a formal No Objection Certificate (NOC) - a written confirmation from the regulator permitting the entity to carry on the relevant activities.

DMCC Sets the Compliance Benchmark

The most concrete regulatory signal came from DMCC, which issued a circular on 1 July 2025 requiring all DMCC-licensed insurance entities to obtain the necessary CBUAE approvals. The circular covers insurance consultancies, brokerage firms, reinsurance services and claims settlement providers. Entities were required to apply for the CBUAE NOC within 30 days of the circular and to provide proof of that application to DMCC within the same 30-day window.

The deadline to submit a copy of the issued NOC was 31 December 2025, or at the time of DMCC licence renewal, whichever came first. Failure to meet these deadlines may result in DMCC licence suspension or financial penalties from the Central Bank. Legal commentary from regional law firms, including Al Tamimi, suggests that similar requirements should be assumed to apply across JAFZA, SAIF Zone, RAKEZ and other non-financial free zones - even where no specific circular has yet been issued.

Stronger Standards for Licensed Brokers

The Insurance Brokers' Regulation 2024, issued by the CBUAE and effective from 15 February 2025, replaces the 2013 rules and substantially raises governance standards for licensed intermediaries. Key changes include stricter client-money segregation, enhanced disclosure obligations, remuneration transparency and mandatory professional qualifications for senior executives. These requirements are designed to raise technical competence and strengthen consumer protection throughout the insurance distribution chain.

According to HFW, CEOs and senior management at insurance companies and brokerages must hold recognised professional qualifications - such as the CII Advanced Diploma or ACII from the UK Chartered Insurance Institute - alongside a relevant bachelor's degree. Specified minimum experience thresholds and annual continuing professional development (CPD) obligations also apply. Practitioners describe these measures as part of a broader drive to professionalise the UAE insurance intermediary sector.

Penalties and Compliance Pathways

The New CBUAE Law significantly increases the ceiling for administrative fines - up to AED 1 billion in serious cases - and introduces minimum penalties for unlicensed financial activity. It also heightens personal liability for Authorised Individuals and criminalises certain forms of unauthorised financial business. Prior Central Bank enforcement actions, including licence revocations for regulatory breaches, are cited by practitioners as evidence that the regulator is prepared to act.

Advisory firms outline several options for affected entities. These include applying for CBUAE licensing or an NOC where the business involves onshore distribution or advice, and restructuring so that only unregulated support functions are performed from non-financial free zones. Firms can also partner with fully licensed onshore brokers to handle regulated activities. Re-domiciling to DIFC or ADGM remains a viable path for those focused on reinsurance broking or cross-border wholesale business. Law firms report active mandates for licence applications, compliance audits and re-domiciliation strategies as the insurance intermediary sector consolidates around the new regulatory baseline.