The Central Bank of the UAE Clearing the Noise Around Article 62

What Article 62 was meant to do

Article 62 does not introduce new categories of licensed financial activities. Instead, it addresses a practical reality of modern finance: regulated services are no longer delivered through a single model or infrastructure.

The article confirms that when a financial activity already listed under Article 61 — such as accepting deposits, providing payment services, issuing stored value, or offering lending — is conducted through any technological means, that activity remains subject to Central Bank supervision. The use of new tools, platforms, or architectures does not alter the regulatory nature of the activity itself.

Put simply, a payment service remains regulated whether it operates through a traditional banking system, a mobile application, or a blockchain-based platform. Article 62 was designed to close regulatory blind spots, not to widen the licensing net.

How Article 62 was misread

The confusion surrounding Article 62 did not stem from the law’s intent, but from how it was initially interpreted in public discourse. Early commentary tended to focus on the law’s expanded supervisory scope without clearly separating financial activity from technical enablement.

In a market already alert to developments around stablecoins, decentralized finance, and tokenized systems, that ambiguity proved costly. Many technology providers assumed that building software, operating infrastructure, or supporting licensed institutions could now trigger licensing requirements.

That assumption was wrong — and the Central Bank’s clarification now makes this explicit.

Article 62 and the line between finance and technology

The clarification draws a clear boundary. Article 62 does not regulate technology providers simply because their tools are used in financial services.

Companies that develop software, provide infrastructure, build protocols, or supply technical solutions do not fall within the licensing perimeter unless they themselves carry out, offer, issue, or professionally facilitate a regulated financial activity.

Crucially, the clarification also confirms that technology providers working exclusively with licensed financial institutions are not deemed to be offering or facilitating financial services by virtue of that relationship alone. Enabling a licensed entity does not, in itself, amount to regulated financial activity.

For builders, developers, and infrastructure providers, this distinction is fundamental. It confirms that innovation remains welcome in the UAE, provided financial services are delivered within a clear supervisory framework.

Why the UAE Central Bank stepped in

Rather than issuing a formal circular or reopening the legislative text, the Central Bank opted for a measured response. The clarification was published through its official FAQs on the Central Bank’s legislative portal.

While quieter in form, these FAQs are not informal commentary. They reflect the Central Bank’s authoritative interpretation of the law and carry legal and supervisory weight. In practice, they guide how Article 62 — and the wider Decree-Law — will be applied and enforced.

The choice of format signals regulatory maturity: addressing market feedback, restoring certainty, and doing so without creating further disruption.

Article 62, foreign stablecoins, and the registration deadline

The same set of FAQs also clarifies another issue that had quietly generated uncertainty: the treatment of foreign stablecoin issuers.

Earlier payment token regulations had contemplated a registration timeline for foreign issuers. When that initial period elapsed without enforcement action, speculation followed. The new clarification now places this issue squarely within the Decree-Law’s reconciliation framework.

Under Article (184), the law provides a one-year reconciliation period from its entry into force on 16 September 2025. This means that affected activities — including those involving foreign stablecoins — are expected to align with the Central Bank’s regulatory framework by 15 September 2026, unless the period is formally extended by the Central Bank’s Board of Directors.

Rather than resetting obligations or signaling abrupt enforcement, this approach formalizes an extended alignment window, reinforcing regulatory continuity while providing market participants with a clear and predictable deadline.

A broader lesson for the market

The episode surrounding Article 62 illustrates how quickly uncertainty can spread when legal provisions are read in isolation. In fast-evolving regulatory environments, early interpretations — particularly when detached from official guidance — can unintentionally amplify concern.

The Central Bank’s response reinforces a regulatory philosophy that has defined the UAE’s financial framework in recent years: protect financial stability without regulating innovation out of existence.

With the clarification now on record, Article 62 should be read for what it is — a technology-neutral safeguard against regulatory arbitrage, not a constraint on builders or infrastructure providers.

For the market, the takeaway is clear. Technology remains free to innovate in the UAE. Financial services remain regulated. And the line between the two, briefly blurred, is now firmly re-established.