DSFA Amendments to Legislation: Regulation of Crypto Tokens under Consultation

DSFA Amendments to Legislation: Regulation of Crypto Tokens under Consultation Paper 168

On 15 December 2025, Dubai Financial Service Authority (DFSA) issued updated rules on the regulation of Crypto Token in Dubai International Financial Centre (DIFC). The rules were updated post the consultation period outlined in Consultation Paper No. 168 which enumerated the proposed legislative changes to these regulations.

Purpose of Issue

This Consultation Paper was issued to seek public comment from those providing and wishing to provide financial services related to Crypto Tokens, on prospective amendments to DFSA regulatory regime. The updated rules refine and strengthen the regime first introduced in 2022 and mark the next phase in the continued development of its digital assets' regulatory framework.

Summary of Changes made:

  • According to updated regime, firms providing financial services involving Crypto Tokens are directly responsible for undertaking the stipulated prior assessment of the Crypto token and determining that the particular token is suitable for the firm to be utilised for the authorised activities it engages in.

  • Therefore, the DFSA will no longer prescribe a list of Recognised Crypto Tokens.

  • This is accompanied by enhanced safeguards for investors and proportionate reporting requirements that reflect market developments.

  • For businesses operating or seeking to operate in the DIFC, this translates to a more transparent, predictable, and structured pathway for Crypto Token activities.

Shift in Suitability Criteria

'Recognised Crypto Tokens' originally depicted in the Initial List of Recognized Crypto Tokens established by the DFSA has been withdrawn, and are considered as 'Suitable Crypto Tokens,' in the new regulations. With introduction of term, “Suitable Crypto Token” DFSA has widened the scope of tokens which the firms could engage in.

Application Fee

Furthermore, since the application for a crypto token to be considered a recognised token is no longer part of the process, the application fee of $5000 is now void.

Holding or arranging custody with third party agents

Additionally, when assessing the suitability of a Third-Party Agent to hold Safe Custody Crypto Tokens, an Authorised Firm must have regard to the following matters:

  • Whether the Third-Party Agent is authorised and supervised by a Financial Services Regulator to provide custody of Crypto Tokens.

  • The Third-Party Agent's policies and procedures for the storage of Crypto Tokens, including the type of storage, safety of the keys and the measures put in place to protect the keys from hacking, theft or fraud.

  • The robustness of the Third-Party Agent's custodial technologies.

External Fund Managers & External Funds

The restriction preventing external fund managers from managing domestic funds that invest in crypto tokens has been lifted, further easing limitations on external funds' involvement in crypto token investments.

Implementation

The DFSA Board announced the Rulemaking Instrument to come into force on 12 January 2026.

On account of the above changes in the key DFSA rulebook (GEN), amendments have been made to other rulebooks to reflect these changes. For more information, please refer to the appendices listed in:

This blog is for informational purposes only and does not constitute legal or regulatory advice. The information provided has been compiled from publicly available sources, and while we have made every effort to ensure its accuracy and relevance at the time of publication, we do not guarantee its completeness or applicability to specific situations. Readers are encouraged to seek independent professional advice before making any decisions based on the content herein.

×