The UAE doesn’t have an onshore MGA regime. MGA-type operations are conducted through two separate free-zone regulatory frameworks: the Dubai International Financial Centre (DIFC), regulated by the Dubai Financial Services Authority (DFSA), and the Abu Dhabi Global Market (ADGM), regulated by the Financial Services Regulatory Authority (FSRA).

Each regime is independent, with its own authorization requirements, regulatory standards and supervisory approach. DIFC and ADGM require an “Insurance Management” license, allow combined MGA/broking licenses, and provide no alternative license category for an entity to provide MGA services.

In the DIFC, entities must obtain DFSA authorization to conduct insurance intermediation activities, including delegated underwriting. In the ADGM, FSRA authorization is required. Both regimes have sophisticated application processes that involve detailed assessment of business plans, governance arrangements, financial resources and key personnel.

In the ADGM, the entire process from application submission to final approval typically takes around 4-6 months. In the DIFC, the process from application submission to final approval typically takes around 4-5 months.

There is no passporting framework between the DIFC, ADGM, and onshore UAE. Each jurisdiction is treated as a separate regulatory territory. Entities wishing to operate across multiple UAE jurisdictions must obtain separate authorizations. There is no equivalent of EEA passporting, and cross-border activity must comply with the requirements of each relevant jurisdiction.

Both free zones offer innovation-friendly frameworks. The DIFC operates an Innovation Testing Licence (ITL) that allows firms to test innovative financial services products in a controlled environment. The ADGM offers a fintech lab with similar objectives. Both frameworks provide reduced regulatory requirements during the testing phase and access to regulatory guidance and support.

Both the DFSA and FSRA conduct thorough fit and proper assessments of controllers, senior management and key personnel. Approval is required for changes in control or significant ownership. The assessments cover integrity, competence, financial soundness and governance capability.

Conduct of business rules apply in both the DIFC and ADGM, including requirements relating to product suitability, customer communication and fair treatment. While these frameworks are not identical to the EU’s IDD-based POG regime, they impose comparable obligations on intermediaries to ensure that products are appropriate for the customers they’re distributed to.

Both the DFSA and FSRA impose insurance money segregation requirements on intermediaries handling insurance funds. Premiums and other insurance monies must be held in designated trust or segregated accounts, separate from the firm’s own funds. Reporting and reconciliation obligations apply.

In the DIFC, the base capital requirement is USD30,000, calculated on an expenditure basis. In the ADGM, the base capital requirement is USD50,000, also on an expenditure basis. PII is required under both regimes. The specific capital calculation depends on the scope of authorized activities and the firm’s expenditure profile.

The existence of two separate free-zone regimes creates both opportunity and complexity. Each regime is sophisticated and well-regarded internationally, but entities must carefully consider which jurisdiction best suits their target market and operational model.

The absence of passporting between DIFC, ADGM and onshore UAE means that each jurisdiction must be treated as a distinct market. Both regimes offer attractive features for MGA operations, including English-language regulatory frameworks, common-law-based legal systems and access to regional insurance markets.