Overall, GDF welcomes the UAE’s commitment to implementing the OECD’s Crypto-Asset Reporting Framework (CARF) and supports its introduction as an information-reporting regime rather than a tax measure. The framework represents an important step toward enhancing transparency, interoperability, and regulatory credibility in digital finance. For the UAE, successful implementation will depend on ensuring proportionality, consistency across regulators and free zones, and a clear delineation of roles between the Ministry of Finance and other competent authorities.
Our below response focus on six key priorities:
1. Publish and maintain a definitive list of reportable jurisdictions to avoid a wider approach.
2. Provide clear regulatory mapping and worked examples across on-shore, regulated, and non-regulated free zones.
3. Release full technical specifications and a sandbox well ahead of first reporting.
4. Clarify CARF/CRS 2.0 alignment, including nil-return mechanics and crypto-derivative treatment.
5. Issue practical due-diligence guidance, including simplified self-certifications and proportionate data requirements.
6. Adopt a phased “soft-landing” approach with proportionate, transparent enforcement.
Submitted 11/07/25