finpeel Answers · UAE · updated 2026-08-14
Yes, if you provide regulated Open Finance Services onshore in the UAE. Under the current CBUAE Open Finance Regulation, an Open Finance Provider can seek authorisation for Data Sharing, Service Initiation, or both, depending on the service it provides.
The current instrument is the Open Finance Regulation issued in July 2025, which replaced the earlier Open Finance Regulation. It establishes the licensing and operating framework for regulated data-sharing and transaction-initiation services within the CBUAE Open Finance Framework.
The licensing question turns on what your company actually does. A business that itself provides regulated Data Sharing or Service Initiation services is different from a technology vendor that only supplies software to a licensed participant and does not provide the regulated service to users.
Open Finance can overlap with other CBUAE regimes. If the product also provides retail payment services, stores value or provides payment-token services, those activities need their own perimeter analysis rather than being assumed to be covered by the Open Finance authorisation.
Regulator: Central Bank of the UAE (CBUAE)
Primary sources: CBUAE — Open Finance Regulation (Circular No. 03/2025)
Directional — not legal advice. Verify with the regulator before committing.