UAE Cryptocurrency Custody Regulations

The UAE has established comprehensive custody requirements within its broader virtual asset regulatory framework, emphasizing enhanced governance, custody, and client asset protection standards, particularly through recent amendments effective January 2026.[3]

Regulatory Framework and Governing Bodies

The primary regulators overseeing custody requirements are:[2]

• Central Bank of the UAE (CBUAE): Governs federal monetary policy and virtual asset service providers (VASPs)
• Securities and Commodities Authority (SCA): Supervises VASPs' compliance outside free zones
• Dubai Financial Services Authority (DFSA): Regulates crypto activities within the Dubai International Financial Centre (DIFC)
• Virtual Assets Regulatory Authority (VARA): Manages virtual asset activities in Dubai

The foundational regulation is Cabinet Resolution No. 111 of 2022 Regulating Virtual Assets and the Related Service Providers, which grants the SCA broad supervisory powers over virtual asset service providers and requires strict anti-money laundering compliance and technical operational standards.[4]

Custody and Client Asset Protection Requirements

The DFSA Crypto Token Framework amendments, effective January 12, 2026, introduced strengthened custody and client asset protection requirements.[3] The DFSA's updated framework emphasizes:

• Enhanced custody requirements for regulated firms handling crypto tokens
• Client asset segregation and protection standards
• Strengthened governance and disclosure requirements for crypto-related activities within the DIFC[5]

Banks providing crypto custody services in the UAE, such as Zand Bank, are subject to rigorous regulatory frameworks that govern their custody operations.[6]

Specific Custody License and Qualified Custodian Requirements

The search results do not provide detailed specifications regarding:

• Explicit custodial license application requirements or procedures
• Specific definitions of "qualified custodian" status
• Mandatory cold storage percentages or technical specifications
• Insurance or bonding requirements for custodians
• Detailed client asset segregation methodologies

The DFSA and SCA regulations emphasize custody oversight but the available sources do not elaborate on these granular operational requirements.

Pending Legislation

Recent developments include Federal Decree-Law No. 6 of 2025, issued in September 2025, which consolidated federal-level oversight of crypto-based payment services and expanded the CBUAE's regulatory authority over cryptocurrency-related financial activities.[3] Additionally, Cabinet Resolution No. 83 of 2025 establishes fees for licensing and regulatory services provided to virtual asset service providers.[4]

For comprehensive custody compliance details and current regulatory documentation, you would need to consult directly with the DFSA, CBUAE, or VARA, as the publicly available search results focus on broad regulatory architecture rather than specific custodial operational requirements.