The United Arab Emirates has enacted sweeping legislation that designates cryptocurrency infrastructure, including Bitcoin wallets, as potentially criminal unless licensed by the Central Bank. This significant regulatory shift, effective from September 16, poses substantial implications for global technology providers involved in cryptocurrency access and services.
New Legislation Restructures Crypto Regulations
- The Federal Decree-Law No. 6 of 2025 took effect on September 16.
- Article 62 places APIs, explorers, and decentralized platforms under Central Bank control.
- Article 61 regulates all marketing, email, and online publications related to cryptocurrency services.
This new law supersedes the banking status established in 2018 and markedly broadens the definition of financial activity. Legal experts from Gibson Dunn have noted the law’s unusually extensive scope, warning of substantial risks for global tech providers.
The penalties for non-compliance can range from fines between 50,000 AED to 500,000,000 AED (up to 136 million USD) and even imprisonment. Importantly, the law applies not only to entities operating within the UAE but also to those with products accessible in the country.
Licensing Requirements for Wallets and APIs
The most critical aspect of the new law is found in Article 62, which grants the Central Bank authority over any technology that “engages, offers, issues, or facilitates” financial activities. This broad language encompasses self-custody wallets, API services, blockchain explorers, analytics platforms, and even decentralized protocols.
The regulatory framework fundamentally shifts how cryptocurrency infrastructure is governed in the UAE. Previously, licensing requirements focused primarily on traditional financial entities; however, the updated regulations now extend to software and data tools.
According to developer analysis, even publicly available tools such as CoinMarketCap and open-source Bitcoin wallets may now require a license to remain accessible within the UAE. For the first time, developers may face criminal penalties for offering unlicensed crypto tools, even if based abroad.
This jurisdictional extension indicates a new regulatory attitude that addresses access to cryptocurrencies as closely as their ownership or trading.
Regulation of Communications and Marketing
The crackdown extends beyond financial infrastructure. Article 61 of the same law defines marketing, promotion, or advertising of financial services as activities requiring a license. In practical terms, this means that merely hosting a website, publishing an article, or sharing a tweet about a cryptocurrency service without a license could be deemed a legal violation if that content reaches residents of the UAE.
This change dramatically expands the compliance footprint for businesses and developers. Gibson Dunn highlights that these provisions significantly broaden the scope of applicability, particularly for companies without a formal presence in the UAE. The law applies to communications coming from outside the country but accessible within.
Consequently, a regulatory landscape emerges where developers, content creators, and infrastructure providers must assess whether their platforms are indirectly accessible to UAE users. In many instances, preventing potential legal risks may necessitate disabling access or completely halting services.
Dubai’s Free Zones No Longer Shield Crypto Services
In recent years, the UAE has positioned itself as a hub for blockchain innovation, attracting global interest through favorable licensing frameworks established by bodies like the Dubai Virtual Asset Regulatory Authority (VARA) and the Abu Dhabi Global Market (ADGM). However, the new federal law nullifies these free zone arrangements, asserting Central Bank control on a national scale.
This federal law supersedes all rules introduced by UAE’s free zones, effectively dissolving the regulatory arbitrage that once drew companies to Dubai. The broader context reflects the country’s ongoing history of digital restrictions, such as the blockage of WhatsApp voice calls, emphasizing a consistent political approach toward centralized control over communications and digital tools.
While this may align the UAE more closely with international pressures from groups such as the Financial Action Task Force (FATF), it also places cryptocurrency service providers in a precarious position. In other countries under similar pressures, firms have withdrawn entirely to avoid legal risks.
Implementation Timeline and Anticipated Regulations
Entities have one year from September 16, 2025, to comply with the new regulations. This grace period may be extended at the Central Bank’s discretion. During this time, additional regulations are expected to clarify how these broad rules will be implemented in practice.
Despite this, the law’s scope is already raising concerns. The language surrounding facilitation and communication, combined with the severe penalties specified in Article 170, suggests that enterprises offering global crypto tools must now account for the risk of unintended exposure to UAE users. For software developers and platform operators, this marks a significant departure from the norms of decentralized access and open-source innovation.
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