Establishing a DFSA Category 3A and Category 4 Licence in Dubai in 2026
The Dubai Financial Services Authority (DFSA) is an autonomous regulatory body overseeing financial and certain ancillary services conducted in or from the Dubai International Financial Centre (DIFC). In addition to regulating financial and ancillary services, the DFSA also supervises and enforces applicable AML and CTF requirements within the DIFC.
In this article, the SALVUS Investment Firms Licensing team explores the requirements for obtaining a Category 3A or Category 4 licence under the DFSA framework, highlighting the current position under the DFSA Rulebook and the prudential reforms that took effect on 1 July 2025, with further amendments taking effect on 1 July 2026. We also outline our methodology in assisting you to secure the appropriate licence tailored to your business needs.
Additionally, our Licensing team sheds light on the DFSA’s vision and regulatory strategy, offering insights on becoming a licensed Investment Firm, Investment Fund, Money Services Firm, or other financial service providers.
This commentary aims to guide you through the process of establishing a DFSA Category 3A or Category 4 licence in Dubai in 2026, ensuring you are well-informed and prepared for the evolving regulatory landscape.
1. DFSA Category 3A license requirements and authorisation
2. DFSA Category 4 license requirements and authorisation
3. Comparison between Category 4A and Category 4 licenses
4. The DFSA’s vision and regulatory approach
5. Guidance from the DFSA on becoming a licensed entity
6. How can SALVUS assist you?
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1. The DFSA Category 3A license
The DFSA Category 3A licence permits investment firms to conduct the following financial service:
- Dealing in Investments as Agent
Firms wishing to conduct Financial Services in or from the DIFC must obtain DFSA authorisation, and where the business model involves specific permissions or endorsements, these must be reflected on the firm’s licence. To qualify, firms must be incorporated within the DIFC and may operate as subsidiaries of regulated entities from approved jurisdictions. With a Retail Clients licence endorsement from the DFSA, Category 3A licensed entities can onboard retail clients. Additionally, they can hold and/or control client funds or assets through a Client Assets licence endorsement issued by the DFSA.
The capital requirement framework for Category 3A firms has evolved under recent DFSA prudential reforms. As at the current Rulebook, the Base Capital Requirement for a Category 3A firm is US$200,000. Firms should also assess the wider prudential requirements applicable to their model under the PIB module, rather than relying solely on legacy fixed-capital summaries.
Current update: the DFSA’s proportionality reforms were finalised in 2025, with relevant rule changes coming into force on 1 July 2025 and 1 July 2026.
Based on our experience, the licensing process typically takes between 8 to 12 months to complete, depending on the complexity of the application and regulatory engagement.
2. The DFSA Category 4 license
The DFSA Category 4 licence allows firms to perform the following Category 4 services, where authorised:
- Arranging Deals in Investments, Advising on Financial Products, Arranging Custody, Operating an Alternative Trading System, Providing Fund Administration, Providing certain Trust Services, certain Money Services activities, Arranging Credit and Advising on Credit, Operating a Crowdfunding Platform, and Arranging or Advising on Money Services
- Alternative Trading Systems are currently expressly listed within Category 4 under the Rulebook
Depending on the scope of permission and the business model, firms may need specific endorsements on their licence. It should not be stated categorically that all Category 4 firms may never hold or control client assets; where a firm’s business model involves holding and/or controlling client assets, a Client Assets endorsement is required. This is expressly relevant in the DFSA framework for, among others, Operating a Crowdfunding Platform and certain Money Services activities.
Under the current Rulebook, the Base Capital Requirement is US$30,000 in ordinary cases, and US$140,000 where the firm is authorised to Operate a Crowdfunding Platform or Provide Money Transmission.
As with Category 3A, firms should assess the current prudential framework and the staged DFSA amendments already made for 2025 and 2026.
Based on our experience, the licensing process for a DFSA Category 4 licence can be completed within 4 to 6 months, assuming adequate preparation and regulatory readiness.
Our Licensing team is ready to support your firm in securing a DFSA Category 3A or Category 4 licence in 2026. Contact us at info@salvusfunds.com to discuss your licensing needs.
3. How the Category 3A and Category 4 licenses compare
Category 3A is principally linked to Dealing in Investments as Agent. Category 4 covers the specific services expressly listed in PIB 1.3.6, such as Arranging Deals in Investments, Advising on Financial Products, Arranging Custody, Operating an Alternative Trading System, Providing Fund Administration, Operating a Crowdfunding Platform, and certain money-services-related permissions.
The current Base Capital Requirement is US$200,000 for Category 3A. For Category 4, it is US$30,000 in ordinary cases, increasing to US$140,000 where the firm is authorised to Operate a Crowdfunding Platform or Provide Money Transmission.
Client-assets treatment should also be described more carefully: where a firm holds and/or controls client assets, the relevant Client Assets endorsement is required on the license.
4. The DFSA’s vision and regulatory approach
The DFSA’s vision remains: “To be an internationally respected regulator, leading the development of financial services through strong and fair regulation.” It also states that its regulatory approach is risk-based and aimed at avoiding unnecessary regulatory burden.
The current position should be described by reference to the DFSA’s published reforms: the prudential proportionality changes were finalised in 2025, with amendments taking effect on 1 July 2025 and 1 July 2026.
The DFSA remains committed to ensuring a high level of competence across all functions related to its administrative and consultative procedures, while maintaining strong credibility among market participants both regionally and globally.
5. Guidance from the DFSA on becoming a licensed entity
Preparing the necessary documentation and paperwork for submitting an application must be undertaken diligently. Whether you are a start-up investment firm or an established financial institution seeking to expand into the DIFC, it is crucial to prepare in advance.
Submitting the DFSA’s most up-to-date application forms helps avoid outdated requirements and unnecessary delays. Additionally, ensure the business activities to be provided are clearly defined, recognised by the DFSA, and aligned with the financial services specified on the proposed licence. The DFSA also states that firms seeking to conduct Financial Services in or from the DIFC must become authorised, and that firms wishing to change their licence scope or obtain endorsements should use the relevant application forms.
Firms should also consider developing a robust Regulatory Business Plan, establishing strong governance and compliance frameworks, appointing experienced senior management and control functions, and preparing for applicable regulatory and prudential reporting obligations.
6. How can SALVUS assist you?
Drawing on our extensive experience with DFSA Category 3A and Category 4 licence applications, we assist in:
- Assessing your business model to align with DFSA’s regulatory framework
- Preparing all necessary documentation, including financial projections, compliance manuals, and governance structures
- Liaising with the DFSA throughout the licensing process to ensure a smooth and efficient approval
- Providing ongoing compliance support post-licensing to maintain regulatory adherence
Our team works closely with clients to ensure a streamlined and successful licensing journey within the DIFC.
Our Licensing team is ready to support your firm in securing a DFSA Category 3A or Category 4 licence in 2026. Contact us at info@salvusfunds.com to discuss your licensing needs.
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The information provided in this article is for general information purposes only. You should always seek professional advice suitable to your needs.