DFSA’s Revised Client Assets Regime: What Firms Need to Know Before 2026
The Dubai Financial Services Authority (DFSA) has released a comprehensive FAQ to support authorised Firms in understanding and preparing for the revised Client Assets Regime, which will come into effect on 1 January 2026. These updates follow Consultation Paper 160 (CP160) and aim to enhance the safeguarding of client assets in or from the DIFC.
Who is Affected
The revised regime applies to Authorised Firms that:
- Provide custody
- Arrange custody
- Hold the Client Assets endorsement
This includes firms licensed for Managing Assets, particularly those under a Category 3C license, if they hold client money or investments or arrange for custody services.
What is Changing?
The revised regime strengthens protections for:
- Client Money
- Client Investments
- Client Crypto Tokens
Firms are now required to adhere to enhanced standards of segregation, written acknowledgments, reconciliation, client reporting, and crisis preparedness.
Key Areas Covered in the DFSA FAQ
- Amendments to the Client Assets Regime
- Controlling Client Assets
- Client Assets Auditor’s Reports
- Client Money Written Acknowledgement
- Client Assets Reconciliation
- Client Reporting
- TPA Suitability Assessment
- Client Disclosures
- Client Assets Crisis Preparedness Pack
- Investment Management of Funds
Why This Matters
These changes are part of the DFSA’s broader commitment to investor protection and market integrity. Authorised Firms must assess their current arrangements and update policies, controls, and documentation to comply with the new rules well before the implementation deadline.
How VelthRad Can Support
VelthRad Consultants offers regulatory guidance, policy framework design, and operational support to firms impacted by these changes. We help you assess your current state, identify compliance gaps, and prepare for the revised reporting and audit expectations under the 2026 regime.
This article summarizes the DFSA’s recently published FAQ on the Revised Client Assets Regime (effective 1 Jan 2026), following Consultation Paper 160.
Firms are encouraged to review the FAQ alongside the Rules and Feedback Statement, available on the DFSA’s website.
This blog is for informational purposes only and does not constitute legal or regulatory advice.
