The UAE continues to refine its regulatory and compliance framework to strengthen investor confidence, ensure international alignment, and enhance financial transparency. Consultation Paper No. 165 introduces significant changes in the appointment and responsibilities of Authorized Individuals (AIs), marking a crucial shift in how businesses and financial institutions operate.
At RegFinSolutions, we help clients navigate such regulatory updates, ensuring they remain fully compliant while staying ahead of industry transitions.
1. The Current Regime (Until 31 August 2025)
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Authorized Individuals (AIs) are appointed to perform controlled functions, such as compliance oversight, finance, operations, and risk management.
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The appointment process requires firms to seek approval from regulatory bodies, with emphasis on qualifications, relevant experience, and integrity.
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Responsibilities are function-specific, meaning each AI is directly accountable for their designated area (e.g., Compliance Officer, Finance Officer).
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Reporting lines are straightforward, with AIs reporting internally to senior management while maintaining accountability to regulators.
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Approval timelines and procedures, while effective, have been criticized for being lengthy and rigid, especially for firms scaling operations.
2. The New Regime (From 1 September 2025)
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Centralized Authorization – Instead of separate approvals for each function, firms will now appoint AIs under a consolidated framework, reducing duplication.
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Expanded Responsibilities – AIs will have broader accountability beyond their function, ensuring they contribute to overall governance, ethical culture, and regulatory alignment.
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Regulatory Oversight – Regulators will adopt a more flexible, risk-proportionate assessment, focusing on the nature, scale, and complexity of the firm’s activities.
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Enhanced Accountability – AIs will face greater personal accountability, with penalties for misconduct or negligence being more stringent.
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Efficiency in Appointments – Approval timelines will be shortened, and digitalized processes will reduce administrative burdens.
3. Key Comparison – Old vs. New
| Aspect | Until 31 August 2025 | From 1 September 2025 |
|---|---|---|
| Appointment Process | Function-specific approvals for each AI | Centralized approval under a unified framework |
| Responsibilities | Limited to designated functions | Expanded to governance, ethics, and firm-wide compliance |
| Regulatory Oversight | Function-focused review | Risk-based, holistic assessment |
| Accountability | Shared within management | Direct personal accountability with stricter penalties |
| Efficiency | Lengthy and rigid process | Streamlined, faster, and digitalized |
4. What This Means for UAE Businesses
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A need for robust internal governance frameworks.
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Appointing AIs who are not only technically qualified but also strategic leaders capable of overseeing broader responsibilities.
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Preparing for enhanced scrutiny from regulators, requiring proactive compliance monitoring.
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Leveraging the efficiency of the new system to accelerate business scaling without regulatory bottlenecks.
5. How RegFinSolutions Can Help
At RegFinSolutions, we specialize in:
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Regulatory advisory for smooth transitions into new compliance regimes.
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Accounting & Bookkeeping, ensuring transparent financial records.
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VAT & Corporate Tax Compliance, aligned with evolving UAE tax laws.
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IFRS Financial Reporting to maintain global standards.
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Regulatory Services UAE, including guidance on the new AI framework.
We ensure our clients remain compliant, focused, and ahead in an evolving regulatory landscape.
Final Thoughts
The transition under Consultation Paper No. 165 is more than just a regulatory update — it is a step toward stronger corporate governance and accountability in the UAE. Businesses that adapt early will not only remain compliant but also strengthen investor confidence and long-term growth prospects.
Stay Compliant. Stay Focused. Stay Ahead.
