Global Digital Finance (GDF) submitted a response to the Dubai Financial Services Authority’s (DFSA) Consultation Paper No. 170 on Operational Resilience. The response broadly supports the DFSA’s proposed framework and welcomes its proportionate and principles-based approach to operational resilience for Authorised Persons operating within the DIFC.
GDF supports the requirement for firms to identify critical business services, set impact tolerances, and embed operational resilience governance at board level in line with international standards. The submission also welcomes the flexibility provided around scenario testing, mapping of critical resources, and resilience planning.
From the perspective of digital asset firms, GDF encourages the DFSA to recognise the unique operational dependencies associated with blockchain infrastructure, smart contracts, custody arrangements, and shared technology providers. The response also recommends additional clarity regarding proportionality for smaller firms, recognition of group governance arrangements, and practical guidance on reassessment triggers and reporting expectations.
Overall, GDF supports the DFSA’s objective of strengthening operational resilience while maintaining a flexible, technology-neutral, and internationally aligned regulatory framework for the DIFC.
Submitted:
20/05/2026