UAE Open Finance is a regulated financial activity. It falls under Article 61 of Federal Decree-Law No. 6 of 2025, the UAE Central Bank Law. The Central Bank of the UAE (CBUAE) runs the framework through three parts: an API Hub, a Trust Framework and Common Infrastructural Services. These let banks, finance companies and licensed fintechs share financial data and start transactions, but only with a customer’s consent. Most businesses that provide Open Finance services need CBUAE approval before they can operate.
Key Facts
- Regulator: Central Bank of the UAE (CBUAE)
- Legal basis: Article 61, Federal Decree-Law No. 6 of 2025 (UAE Central Bank Law)
- Status: A Licensed Financial Activity, with phased and mandatory onboarding for in-scope licensees
- Core infrastructure: API Hub, Trust Framework, Common Infrastructural Services
- Scope: Cross-sector. It covers banking, payments, credit, investments, insurance, pensions and mortgages, not just bank accounts
- Consent requirement: Every data share or transaction needs the customer’s express consent, plus authentication and secure communication
- Licence needed: Yes, for most Open Finance Providers, unless they fall under a deemed-licensed category
What Is UAE Open Finance?
UAE Open Finance is the CBUAE’s regulated framework for financial data sharing and transaction initiation. It connects banks, licensed financial institutions and authorised Open Finance providers, and it always requires the customer’s consent.
Open banking models usually cover only bank accounts and payments. UAE Open Finance goes further. It is built for financial data across many sectors, including credit, investments, insurance, pensions and mortgages.
The infrastructure has three parts:
Trust Framework
Handles participant identification, digital certificates and secure connections.
API Hub
A standard, shared system for accessing and managing APIs.
Common Infrastructural Services
Shared technical services, such as secure communication and participant management.
Who Regulates Open Finance in the UAE?
The Central Bank of the UAE (CBUAE) regulates Open Finance. Article 61 of Federal Decree-Law No. 6 of 2025 names Open Finance services as a Licensed Financial Activity. This means providers usually need CBUAE approval to operate legally.
Is Open Finance a Licensed Activity in the UAE?
Yes. Article 61 of Federal Decree-Law No. 6 of 2025 lists Open Finance services as a Licensed Financial Activity. Businesses offering these services must get CBUAE authorisation, unless they qualify for a specific deemed-licensed category.
UAE Open Finance vs. Open Banking
| Open Banking | UAE Open Finance |
|---|---|
| Mainly about banking services | Covers many financial sectors |
| Mostly account and payment data | Broader data: credit, investment, insurance, pensions, mortgages |
| Often limited to data access | Covers data sharing and transaction initiation |
| Built around banking APIs | Built on the CBUAE API Hub and shared infrastructure |
| Bank-focused | Covers several types of CBUAE-regulated entities |
In short: open banking is one part of what UAE Open Finance covers.
What Data Does UAE Open Finance Cover?
| Data Category | What It Includes |
|---|---|
| Bank accounts | Account and transaction data |
| Payments | Payment-related data and services |
| Credit and loans | Credit facilities and related information |
| Investments and wealth | Investment product information |
| Insurance | Insurance product and policy data |
| Pensions and benefits | Relevant financial product data |
| Mortgages | Financing and property-related data |
Which categories are actually available depends on the products and services covered in each phase of the CBUAE’s rollout.
Who Has to Participate in UAE Open Finance?
Participation is mandatory for in-scope CBUAE licensees, and they are being onboarded in phases. This group can include banks, finance companies, payment service providers, stored value facility providers, exchange houses and insurance companies. There are four distinct roles in the ecosystem:
- Entities required to give Open Finance access (mandated data holders)
- Open Finance Providers who use the framework to build products
- Technology businesses that support regulated activities without directly providing them
- Customers who give consent for data sharing or transaction initiation
Do Open Finance Providers Need a CBUAE Licence?
Generally, yes. Businesses that provide Open Finance services need CBUAE authorisation, unless they fall under a deemed-licensed category. The exact requirement depends on the services offered: data sharing, transaction initiation, or both.
A licensing assessment typically looks at: Legal structure, regulatory scope, capital requirements, governance, fit-and-proper requirements, technology and operations, data security, how customer consent is handled, risk management and compliance systems.
What Does Article 62 Mean for Fintech Technology Providers?
Article 62 of Federal Decree-Law No. 6 of 2025 covers anyone who carries on, offers or facilitates a regulated financial activity, whether directly or through technology. This can include fintech platforms, APIs, protocols and infrastructure that support regulated payments, credit or investment services.
Not every technology company needs a CBUAE financial licence. What matters is whether the business facilitates or provides a regulated financial activity, not simply whether it touches financial data.
Does a Foreign Fintech Need a UAE Entity to Access Open Finance?
Generally, yes, if the activity counts as a regulated Open Finance service. A foreign fintech should not assume that an overseas licence gives it direct access to UAE Open Finance infrastructure. It needs to check CBUAE licensing requirements and choose a suitable legal structure, such as UAE mainland, DIFC, ADGM, or another jurisdiction, based on its business model and target customers.
Is UAE Open Finance Fully Live Yet?
Not everywhere. The framework is being rolled out through phased, mandatory onboarding of in-scope CBUAE licensees. Having the rules in place does not mean every institution or use case is connected yet. Fintechs should check the current onboarding status, API availability and licensing requirements directly with the CBUAE before setting a launch date.
What Should Fintech Founders Do Before Launching?
Businesses planning to offer Open Finance services in the UAE should take a structured approach.
Match the business model to a specific regulated activity
Determine whether the service is an Open Finance service, technology facilitation, or another CBUAE-regulated activity.
Identify the right regulator and licence category
Confirm whether the CBUAE is the relevant regulator and determine the applicable licence type.
Choose a legal structure
Select a structure such as mainland, DIFC or ADGM that supports the intended activity and target market.
Build compliance for both CBUAE Open Finance rules and UAE data protection rules
Ensure the business meets regulatory requirements for consent, data security and operational governance.
Confirm current CBUAE onboarding status and API availability
Check the latest CBUAE position before setting a launch date, as the framework is being rolled out in phases.
Glossary of Key Terms
- CBUAE: The Central Bank of the UAE, the regulator responsible for Open Finance.
- Open Finance Provider: A licensed business that uses the CBUAE framework to share financial data or start transactions on a customer’s behalf.
- API Hub: The CBUAE’s shared system for connecting to Open Finance APIs.
- Trust Framework: The identification and security layer that lets participants connect to each other safely.
- Deemed-licensed category: A specific exception under CBUAE rules where a business does not need a separate Open Finance licence.
Frequently Asked Questions
What is UAE Open Finance?
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Is Open Finance a licensed activity in the UAE?
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Do Open Finance providers need a CBUAE licence?
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Is UAE Open Finance the same as open banking?
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Does UAE Open Finance require customer consent?
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Can a foreign fintech access UAE Open Finance APIs directly?
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Does Article 62 apply to fintech technology companies?
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How can IncHub help fintech founders entering the UAE?
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Need Help Entering the UAE Open Finance Market?
If your business is exploring UAE Open Finance, IncHub can help you review your corporate structure and coordinate with specialist UAE regulatory counsel on CBUAE licensing.
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