CBUAE Resolution No. 16 of 2026 lets institutions licensed by the Central Bank — banks, finance companies, exchange houses and PSPs, but not insurers — undertake the virtual asset activities regulated by the Capital Market Authority under Resolution 04 of 2026. It punctures the perimeter between the two federal regulators, though the authorisation mechanics are not yet defined.
A short federal instrument can move the market more than a long one. CBUAE Resolution No. 16 of 2026 is such an instrument. In a few lines it lets prudentially-supervised, Central Bank-licensed institutions step into virtual asset activities that, until now, sat firmly with a different federal regulator. Before turning to what it does, one point of naming needs clearing up — because the update everyone is reading gets it right, and it matters.
First, the name: the SCA is now the CMA
Effective 1 January 2026, the Securities & Commodities Authority (SCA) was reconstituted as the Capital Market Authority (CMA) under Federal Law No. (32) of 2025. This is not a new regulator bolted alongside the SCA; it is the SCA's successor. So when you see "CMA" in the current virtual asset instruments, read it as the body that was the SCA — and read references to older SCA decisions as having been carried into, or replaced by, the CMA's framework.
The two instruments in play
Two 2026 resolutions do the work, one from each federal regulator, plus the underlying laws that frame them:
| Instrument | Author | What it does |
|---|---|---|
| Resolution No. 16 of 2026 | CBUAE | Permits CBUAE licensees to undertake the virtual asset activities regulated under CMA Resolution 04. Insurers excluded. |
| Resolution No. 04/Chairman of 2026 | CMA (ex-SCA) | The mainland VASP / Alternative Trading System framework. Replaced SCA Decision No. 26/R.M of 2023. |
| Federal Law No. (32) of 2025 | Federal | Reconstituted the SCA as the Capital Market Authority, effective 1 January 2026. |
| Decree-Law No. (6) of 2025 (Banking Law) | CBUAE | Frames the CBUAE's narrow virtual asset remit — essentially payment tokens / stablecoins. |
What Resolution 16 actually does
It punctures the regulatory perimeter between the two federal regulators. Until now, mainland virtual asset activity of the securities and exchange type sat with the SCA, now the CMA, while the CBUAE's virtual asset remit was narrow — essentially payment tokens and stablecoins under the Banking Law (Decree-Law No. 6 of 2025). A CBUAE-licensed bank, finance company, exchange house or PSP therefore had no clean route into CMA-regulated virtual asset activities such as custody, brokerage and dealing, or operating an Alternative Trading System (ATS).
Resolution 16 opens that route: CBUAE licensees may now undertake activities regulated under Resolution 04. One important exclusion — insurance companies are carved out, consistent with keeping insurers away from principal virtual asset and trading risk.
Why it matters
Strategically, this lets incumbent, prudentially-supervised institutions compete in a space that had been dominated by standalone VASPs and the free-zone regimes — VARA in Dubai, ADGM/FSRA and DIFC/DFSA. It signals that the federal onshore market is being opened to the balance sheets and distribution of licensed banks. For institutions with deposits, capital and existing customer relationships, that is a materially different competitive position from a standalone virtual asset business building distribution from scratch.
The load-bearing caveat: the mechanism is undefined
Here is the part that should govern any client advice today: the mechanism is not yet defined. Resolution 16 says CBUAE licensees may enter — it does not yet say how. Several questions are unresolved and material:
- Authorisation route. Does entry require a separate CMA authorisation layered on the CBUAE licence, or a coordinated or passported approval — and which regulator leads on supervision, capital, conduct and custody/segregation?
- Interaction with the CBUAE's own regime. How does this sit alongside the CBUAE's payment-token / stablecoin framework and the AML/CFT guidance issued in April 2026, which already lists VASPs among supervised entities?
- Governance and ring-fencing. What are the governance, ring-fencing and consolidated-supervision expectations where a deposit-taking bank runs an ATS or holds client virtual assets?
The practical takeaway
Treat Resolution 16 as an in-principle green light to scope virtual asset product lines — not yet an operable pathway. The application, capital and conduct mechanics await implementing rules or a joint CMA/CBUAE framework. The sensible posture now is to scope and design: identify which Resolution 04 activities fit your institution, map the likely capital, custody and conduct implications, and prepare governance and ring-fencing so you can move quickly once the mechanics land. Watch, in particular, for the CMA's implementing decision and any CBUAE circular.
How we help
Neo Legal advises banks, finance companies, exchange houses, PSPs and virtual asset businesses across the UAE's federal and free-zone regimes. We are already helping institutions scope Resolution 04 activity sets against Resolution 16, model the likely authorisation, capital and custody positions, and stand up the governance and ring-fencing that consolidated supervision will expect — so that a green light in principle becomes a workable plan the moment the implementing rules arrive.
This article is general information as at July 2026 and is not legal advice. The framework described is developing and its operating mechanics are not yet finalised; obtain advice for your institution's specific circumstances before acting.
