Federal Decree-Law No. (6) of 2025 regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business contains one of the most important perimeter provisions now sitting in UAE financial services law.
For banks, fintechs, payment businesses, tokenised product builders, wallet providers, embedded finance players and Web3 infrastructure providers, the real question is not whether the law mentions technology. It plainly does. The more important question is where the line now sits between a pure technology provider and a business that is, in substance, facilitating a regulated financial activity.
That line matters. A great many modern business models are built on the idea that the operator is not itself the bank, the payment provider, the lender or the issuer of value, but instead provides the software, user interface, API layer, protocol, infrastructure or orchestration stack through which the service is delivered. Article 62 is aimed directly at
