Update to the DMCC Circular Dated 1 July 2025

Our recent bulletin addressed the issues raised by the DMCC’s Circular dated 1 July 2025 (the Circular) regarding those practising “insurance related activities” on the DMCC platform.

• In essence, the DMCC noted in the Circular that there was a “disconnect” between (a) the trade licences which it had issued to those practising “insurance related activities” on the DMCC platform and (b) the Central Bank of the UAE (CBUAE) which was required to authorise those entities’ activities. In essence, many of those having trade licences which stipulated insurance related activities had no authorisation from the CBUAE.
• The DMCC made clear that those entities had to:
  • apply for a No Objection Certificate (NOC) to the CBUAE within 30 days of the Circular (and prove that they had done so); and
  • ensure that they have a NOC in place before the end of 2025, or when their DMCC trade licence came up for renewal (whichever is earlier).

Current position

The CBUAE has made clear that (a) it will not grant NOC’s to regulate DMCC entities’ positions and (b) the entities will have to apply to the CBUAE for authorisation. The DMCC is now also dispensing this advice. It should be noted that this state of affairs is not limited to the DMCC – it is all freezones in the UAE which potentially have this issue, save for the DIFC and ADGM.

So, what are entities doing?

• Where entities have commercial interactions with onshore insureds or insurers or risks (in whatever capacity e.g. broker, agent, TPA etc) they will require a CBUAE licence.
• Where entities are providing reinsurance capacity, they can re-locate to the DIFC or ADGM. We are seeing those DMCC entities which are able to do so, apply to the DFSA for authorisation.
• Arguably, where the risks have no UAE “contacts” (e.g. the risk has no UAE connection and it’s not placed with UAE brokers, or with UAE insurers), the entities can continue their businesses, although they will have to get DMCC sign off (so as not to lose their trade licence) which might require some form of NOC from the CBUAE.

Whilst the situation remains quite fluid, the options available are becoming more defined. That said, we would strongly recommend you seek legal advice as to your options as some entities appear to be applying for certain authorisations/migrating to platforms which simply do not answer the fundamental problem.