Central Bank of the UAE (CBUAE)
Do I need a licence to offer Buy Now Pay Later (BNPL) in the UAE?
Content reviewed 2026-09-12 · How we check sources
Short answer
Yes, if the model involves regulated Short-Term Credit onshore in the UAE. The CBUAE framework includes licensed Finance Companies, Restricted Licence Finance Companies and permitted agent arrangements with eligible licensed Finance Companies or Banks; the applicable route depends on who legally provides the credit.
What this means
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.
Official sources
CBUAE — Finance Companies Regulation ↗Ask with your entity, activity and regulator.
Regulatory research, not legal advice. This answer has the scope and review date shown above; your institution decides applicability.