Fund management licensing in the UAE

Rules as at 3 November 2026. Each statement carries its label and the section it comes from. The rules engine works out which route applies to your business; Clara, Candovio's AI assistant, gathers the facts.

Which regulator applies, and when

• A manager in the DIFC. The DFSA licenses fund and asset managers as Category 3C. Rule DFSA PIB 3.6.2
• A manager in ADGM. The FSRA licenses them as Category 3C. Rule FSRA PRU 1.3.5, 3.3.2
• A manager onshore. The UAE Capital Market Authority (UAE CMA) licenses fund management and portfolio management as Second Category activities. Rule UAE CMA Financial Activities Rulebook Section 2 Annex 1
• A manager abroad, with a DIFC fund. A manager regulated in a Recognised Jurisdiction can manage a DIFC fund without a DFSA licence, on conditions. Rule DFSA CIR 6.1.2 to 6.1.5
• A manager abroad, with an ADGM fund. The same is possible for a closed-ended Qualified Investor Fund in ADGM. Rule FSRA FUNDS 7.1.1, 7.1.2
• Marketing across the UAE. A fund domiciled in the DIFC or ADGM can be promoted across the UAE under the Fund Passporting Rules agreed between the DFSA, the FSRA and the UAE CMA. Rule Fund Passporting Rules 2.1.2, 2.1.3, 6.3.2, 7.1.2 Promoting foreign fund units onshore needs a UAE CMA promotion licence and is limited to private offers to professional investors and counterparties. Rule UAE CMA Rulebook Section Three Ch 5 Art 6 First(3), Fourth(1), Fourth(8)

Licence categories and base capital

Key requirements

• Managing a fund other than a venture capital fund brings the DFSA's expenditure-based capital minimum into play, so the requirement can rise with the cost base. Rule DFSA PIB 3.7.1
• A manager abroad running a DIFC fund must be regulated in a Recognised Jurisdiction or one acceptable to the DFSA, submit to DIFC law and courts, and appoint a DFSA-licensed fund administrator or trustee before any units are offered. Rule DFSA CIR 6.1.2 to 6.1.5
• A manager abroad running an ADGM fund is limited to closed-ended Qualified Investor Funds and must appoint an FSRA-licensed fund administrator or trustee and an eligible custodian before management starts. Rule FSRA FUNDS 7.1.1, 7.1.2
• A licensed fund manager may delegate asset management to another firm only under a written delegation agreement and stays accountable for it. Rule DFSA CIR 8.12.2, 8.12.4; FSRA FUNDS 12.12.2, 12.12.5
• Before a DFSA firm offers units of a foreign fund, the fund must meet the Designated Foreign Fund criteria or the other foreign fund criteria, and retail offers are allowed only where the home regime allows them. Rule DFSA CIR 15.1.1A, 15.1.5, 15.1.6 In ADGM, retail offers of foreign fund units also need a current English prospectus with the FSRA warning. Rule FSRA FUNDS 10.1.1 to 10.1.3
• Fees: DFSA fund management applications cost USD 10,000 for public or credit funds, USD 5,000 for qualified investor funds and USD 2,000 for venture capital Rule DFSA FER 2.1.1, 3.2.1; the FSRA charges USD 10,000 Rule FSRA FEES 3.6, 3.10; the UAE CMA charges AED 5,000 to apply and AED 35,000 for a fund management licence. Rule UAE CMA service cards

Application stages

1. Assessment. The assessment gives a provisional result in about ten minutes, reviewed by a person before it is released to you, and Candovio confirms the route with you on a call.
2. Application pack. The AI assistant drafts the business plan, policies and forms; Candovio checks every line; you approve it.
3. Submission and questions. We file the application and answer the regulator's questions from the same record.
4. Decision and conditions. The regulator decides, usually first in principle with conditions, and the licence follows once the conditions are met.

The DFSA's 2016 target for a qualified investor fund manager was 28 to 42 calendar days to an in-principle decision, not since reaffirmed. Guidance DFSA authorisation outreach, 2016 The UAE CMA gives initial approval within 20 business days. Rule UAE CMA Financial Activities Rulebook Section 2 Ch 3 Art 1(3) The FSRA publishes no decision period. Guidance FSRA: Getting Started Guide We do not promise timelines.

Questions