Dubai Financial Services Authority issues FAQ to guide firms on revised Client Assets regime ahead of 1 January 2026 start

The Dubai Financial Services Authority (DFSA) has published a Frequently Asked Questions document to help Authorised Firms and Registered Auditors prepare for the revised Client Assets regime taking effect on 1 January 2026. The changes apply to Authorised Firms that provide custody, arrange custody and or hold the Client Assets endorsement, and are positioned as strengthening protections for Client Money, Client Investments and Client Crypto Tokens in or from the Dubai International Financial Centre. The FAQ consolidates issues raised through industry engagement and sets out how the revised rules apply, transitional arrangements and supervisory expectations, alongside the revised rules and the Feedback Statement to Consultation Paper 160. It highlights key updates including clarification of requirements for firms that control but do not hold Client Assets, confirmation that Investments and Crypto Tokens that constitute Fund Property fall outside the Client Assets regime, and a new requirement for certain custody or holding firms to maintain a Client Asset Crisis Preparedness Pack that must be kept up to date and updated within five business days after a change makes it inaccurate. Until 1 January 2026, firms should continue complying with the existing rules and submitting the current auditor reports where applicable. Firms and auditors are encouraged to run gap analyses and implementation plans to be ready by the effective date, and the DFSA intends to host outreach sessions and update the FAQ periodically.