finpeel Answers · UAE · updated 2026-08-14
Yes, if your model falls within the CBUAE's regulated Short-Term Credit activity onshore in the UAE. The activity must be carried on through the permitted CBUAE framework — for example by an appropriately licensed Finance Company or through an agent arrangement with an eligible CBUAE-licensed Finance Company or Bank.
The CBUAE Finance Companies Regulation expressly brings Short-Term Credit, including relevant BNPL models, inside the regulatory perimeter. The correct structure therefore depends on who is legally extending the credit and whether the fintech is the regulated credit provider or is acting under an eligible agent arrangement.
The agent route is not a generic exemption from regulation. The current rules require the agent to partner with an eligible Finance Company or Bank, and the licensed institution's required CBUAE approvals or non-objections must be considered for the arrangement.
Product design also remains subject to applicable consumer-protection and conduct requirements. Before launch, map the legal creditor, customer contract, repayment structure and any fees or merchant-funded economics against the current Short-Term Credit rules.
Regulator: Central Bank of the UAE (CBUAE)
Primary sources: CBUAE — Finance Companies Regulation
Directional — not legal advice. Verify with the regulator before committing.
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