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GDF Response to the DFSA’s Consultation Paper 168 on Enhancements to the Regulation of Crypto Tokens

GDF convened its Policy & Regulatory Working Group to analyse the Dubai Financial Services Authority’s Consultation Paper 168. Overall, GDF is supportive of the DFSA’s commitment to strengthening its framework for Crypto Tokens, aligning with international regulatory standards, and supporting innovation while maintaining market integrity. We appreciate the DFSA’s pragmatic approach, drawing on supervisory experience, market feedback, and global regulatory developments since the initial framework introduced in 2022.

Our full response below provides detailed input to the questions set out in the CP. In doing so, we highlight areas where additional clarity, proportionality, or international consistency could further strengthen the proposed regime. The key areas of feedback of our response are:

  1. Support for the DFSA’s move to a platform-led suitability regime for Crypto Tokens, with recommendations to ensure operational feasibility and consistency across authorised firms.
  2. Endorsement of a risk-based framework for Fiat Crypto Tokens, accompanied by recommendations to streamline the pre-approval process, align with international benchmarks, and clarify supervisory coordination with the CBUAE for AED-backed stablecoins.
  3. Broad support for the DFSA’s approach to Recognised Jurisdictions, Collective Investment Funds, Conduct of Business requirements, and the removal of the application fee for Recognised Crypto Tokens.
  4. Agreement with the proposed reporting framework, with suggestions to harmonise reporting standards, consult on technical templates, and adopt a quarterly reporting frequency to maintain proportionality.
  5. Strong support for an orderly transitional period to ensure smooth implementation and market readiness.

Submitted 31/10/25

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