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GDF Response to the UAE Securities and Commodities Authority’s draft regulations for Virtual Asset Activities

GDF convened its MEA Policy Working Group to analyse draft proposal from the UAE Securities and Commodities Authority’s (SCA’s) draft regulations for Virtual Asset Activities.  Overall, we are supportive of the aim of proposals, as well as the SCA’s broader aims to further develop the UAE’s regime for virtual assets.

Overall, our aim with this response is to support the SCA in developing future-proof and forward-looking regulation that supports the growth and responsible innovation of the UAE’s digital asset sector.

In collaboration with our members, GDF has aimed to provide feedback and suggested key thematic areas across all three modules set out by the SCA that would be beneficial for consideration as the SCA builds out these proposals. The key themes identified are:

1.⁠ ⁠Proportionality: Calibrate requirements (capital, roles, suitability, data retention) to risk, avoiding one-size-fits-all rules.

2.⁠ ⁠Clarity and Coordination: Ensure consistent definitions across Modules and identify potential overlaps with local regulatory regimes to avoid duplication.

3.⁠ ⁠Competitiveness: Align with global benchmarks (MiCAR, FCA, MAS, ADGM) to keep the UAE attractive for firms and investment.

4.⁠ ⁠Innovation: Use risk-based approaches to support new products (staking, NFTs, algorithmic tokens) while safeguarding integrity.

5.⁠ ⁠Operational Flexibility: Recognise global standards and tailor rules (outsourcing, custody, tech testing, disclosures) to practical business models.

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