Federal Decree-Law No. 6 of 2025 came into legal effect on 16 September 2025, replacing both the 2018 Central Bank Law and the 2023 Insurance Law in a single consolidated instrument. For training professionals at UAE financial institutions, the implications are immediate and material.

Board and Senior Management: New Fit and Proper Obligations

Article 104 grants the CBUAE explicit authority to issue governance and Fit and Proper rules for board members and senior management across all Licensed Financial Institutions. This is not a restating of existing practice. It is a new, consolidated mandate with enforcement weight. Any board member appointed or reappointed after September 2025 must satisfy the updated F&P framework. Institutions that have not built structured board-level governance development into their training calendars are now formally non-compliant.

AML/CFT Training: The Board Track Is Now Explicit

The CBUAE Best Practices document, which sits beneath the new Law, explicitly lists the Board of Directors as a distinct training audience with its own content requirements. This is not the same training as staff. Board members must understand their oversight accountability role in the AML/CFT framework, not the operational detection procedures. Institutions that have been sending board members to the same AML course as front-line staff are not meeting the regulatory expectation.

The September 2026 Compliance Window

All entities captured by the new Law have until 16 September 2026 to bring their operations into full compliance. For training, this means every annual training calendar for 2026 must be reviewed against the new consolidated framework. The three areas requiring the most material update are: governance and F&P development for boards, Open Finance/AlTareq compliance (Circular 3/2025), and the updated consumer protection provisions under Articles 148–152.

Mentyra's CBUAE Regulatory Framework program has been designed around Decree-Law No. 6/2025 from the ground up. Contact us to discuss how to map your institution's training obligations to the new requirements.

AlTareq is the CBUAE's branded Open Finance framework, introduced through Circular 3/2025. It establishes the technical and governance standards under which licensed financial institutions must share customer financial data with authorised third parties, via secure APIs and with explicit customer consent. The compliance deadline is September 2026. Nebras, the designated operator, is responsible for the technical infrastructure. The institutions are responsible for the compliance.

What Compliance Actually Requires

Meeting the AlTareq deadline is not a technology project alone. Staff across compliance, operations, IT, and product must understand: the consent management obligations under AlTareq (distinct from PDPL but related to it); API governance and third-party due diligence requirements; the data sharing standards and permissible use cases under the framework; CBUAE reporting obligations; and the liability framework when data is accessed or misused. Each of these requires training that does not currently exist anywhere in the UAE market in structured form.

Who Is Exposed

Any CBUAE-licensed bank, insurer, payment service provider, or finance company that processes customer financial data is within scope. This is not a niche regulation for fintechs. It captures mainstream retail banks and insurers with millions of UAE customers. The AED 60,000 penalty per institution for non-compliance is the floor, not the ceiling regulatory censure, licence conditions, and reputational damage are the more significant risks.

The Training Gap

At time of publication, no UAE training provider offers a structured AlTareq compliance program. Mentyra's Open Finance and AlTareq Compliance program is the first purpose-built offering in the market, developed in conjunction with professionals directly involved in the AlTareq framework design. It covers all five compliance dimensions above in a 2-day intensive, available for open enrolment and in-house delivery.

By June 2025, 2,159 Emiratis were employed across the UAE insurance sector, a 22.09% Emiratization rate in a sector with 9,773 total employees. The CBUAE's target for insurance is 50–60% by 2030, depending on company size. In banking, the Ithraa program achieved 95% of its 2023–2026 targets, placing 9,754 UAE nationals. These are meaningful numbers. But they mask the harder challenge ahead: senior leadership and board-level Emiratization.

The Leadership Gap Is Different

Hiring Emirati graduates into entry-level roles is a solved problem for most large UAE financial institutions. They have graduate programs, partnerships with UAE universities, and Nafis subsidy frameworks. The 30% CEO/GM mandate is a fundamentally different challenge. It requires Emirati professionals who are ready to operate at regulatory accountability level, who understand CBUAE Fit and Proper expectations, who can represent their institution in a supervisory inspection, and who can hold their own in a board risk committee discussion.

What Structured Preparation Looks Like

Mentyra's Financial Sector Leadership Program for Emirati Executives is built around this specific gap. The 3-day program covers: regulatory accountability and the CBUAE F&P framework as it applies to senior positions; strategic financial governance for UAE LFIs; stakeholder management with regulators, boards, and external parties; and practical preparation for the transition from operational role to board-facing leadership. It is co-branded with the Emirates Institute of Finance and ADGM Academy to ensure the pipeline has institutional credibility behind it.

The program is designed for Emirati professionals currently at VP or SVP level in UAE financial institutions, within 12–24 months of a critical role appointment. It is also suitable as a capstone for EIF ETHRAA program graduates entering their first senior role.

The CBUAE's Guidelines for Financial Institutions Adopting Enabling Technologies establish a clear principle: board members are responsible for the governance of AI systems their institution deploys. This is not a technology department matter. It is a board accountability matter. DFSA and FSRA have issued equivalent governance expectations for their regulated entities. In 2025, DIFC further raised the bar with amendments that make data protection a board-level governance risk with direct civil liability.

Six Questions Every Director Should Be Asking

Based on the CBUAE guidelines and international AI governance frameworks, directors at UAE financial institutions should be able to demonstrate they have asked management the following: What AI systems are currently deployed or under deployment, and what decisions do they make? What is the model risk management framework, and who owns it? How are algorithmic bias and explainability requirements being addressed? What is the data governance framework for AI training data? What are the escalation and human override procedures? And how is AI performance being monitored post-deployment?

The Problem with Generic AI Training

Most available AI governance training is either too technical (written for data scientists) or too generic (written for a broad corporate audience with no financial services specificity). Neither serves UAE LFI board members. What directors need is a concise, authoritative program that translates the CBUAE expectations into practical governance questions, accountability frameworks, and decision-making tools they can use at the next board meeting.

Mentyra's AI Governance for Financial Services Boards is a 1-day program designed precisely for this audience. It is the first program of its kind in the UAE financial sector. A half-day executive briefing version is also available for boards that need to move faster.

UAE insurers were required to adopt IFRS 17 for reporting periods beginning on or after 1 January 2023. By early 2025, all major insurers had completed their technical implementation, new actuarial systems, updated chart of accounts, revised close processes. The implementation project is largely over. The ongoing compliance challenge is just beginning.

The Contractual Service Margin Is Misunderstood

In our discussions with UAE insurance finance teams, the Contractual Service Margin remains the most frequently misunderstood element of IFRS 17. Specifically: how CSM is recognised in profit or loss over the coverage period, how changes in fulfilment cash flows adjust the CSM versus hitting profit or loss immediately, and how the CSM interacts with onerous contract assessments. These are not implementation questions. They are ongoing competency questions that require structured finance team training.

Measurement Model Selection Is Now a Live Decision

The choice between the General Measurement Model, the Premium Allocation Approach, and the Variable Fee Approach is not a one-time implementation decision. As new products are launched and existing portfolios evolve, finance and actuarial teams must be able to assess measurement model eligibility and implications in real time. This requires a level of IFRS 17 literacy across the finance function that goes well beyond what was delivered during implementation training in 2022–2023.

Mentyra's IFRS 17: Practical Implementation program is designed for post-implementation teams who need to build ongoing competency, not start from scratch. It runs as a 2–3 day intensive with UAE-specific case studies and is available for in-house delivery with your institution's own contract portfolio used as working material.

The UAE Sustainable Finance Working Group, co-chaired by the CBUAE and the Securities and Commodities Authority, published the UAE Sustainable Finance Framework in 2021. Since then, the regulatory architecture around ESG in UAE financial services has grown substantially and the Islamic finance dimension of that architecture has no direct international equivalent to draw from. UAE Islamic financial institutions are navigating a framework that is simultaneously Shariah-constrained, CBUAE-regulated, and internationally ESG-benchmarked.

Green Sukuk: Where Shariah Meets Climate

The UAE's Green Sukuk Guidelines, aligned to the Climate Bonds Initiative taxonomy, require that proceeds from green sukuk issuances are traceable to eligible green assets. For Islamic finance professionals, this creates a set of competency requirements that sit at the intersection of Shariah structuring, climate risk assessment, and disclosure standards. At present, there is no training anywhere in the region that addresses this intersection in a structured way.

Shariah-Compliant ESG Screening

Conventional ESG screening frameworks exclude activities on financial, social, or environmental grounds. Islamic finance has its own exclusion framework based on Shariah prohibitions. The intersection of these two systems and the governance required to manage them simultaneously is a practical challenge for Islamic banks, takaful operators, and Shariah-compliant asset managers. The AAOIFI Governance Standard No. 9 on ESG provides a foundation, but most institutions are well ahead of formal guidance and making decisions without structured frameworks.

Mentyra's Islamic ESG and Green Sukuk program is the first structured training in the UAE to address the practical intersection of Shariah governance and sustainability regulation. It runs as a 2-day program and is designed for Shariah supervisory board members, compliance officers at Islamic institutions, and investment professionals working with Shariah-compliant mandates.