Comparing UAE Fintech Documentation requirements: Mainland vs DIFC vs ADGM
Fintech Documentation Setup Requirements in the UAE: Mainland, DIFC, and ADGM Compared
Setting up a fintech business in the UAE requires navigating different documentation and regulatory frameworks depending on the jurisdiction—Mainland UAE (regulated by the Central Bank), the Dubai International Financial Centre (DIFC, regulated by the DFSA), or Abu Dhabi Global Market (ADGM, regulated by the FSRA).
Each jurisdiction has unique fintech documentation setup requirements, including incorporation documents, business plans, compliance policies, and financial disclosures.
This comparative table below outlines the specific regulatory expectations and document types required to establish a fintech entity across the UAE’s three major jurisdictions.
Whether you’re applying for a license, entering a regulatory sandbox, or preparing a business plan for a fintech approval, this guide will help streamline your preparation. (as of June 2025)
| Aspect / Type of Document | Mainland UAE (CBUAE) | DIFC (DFSA) | ADGM (FSRA) |
|---|---|---|---|
| Company Incorporation | Certificate of incorporation, MoA, DED trade license, possible sponsor agreement. | Incorporation application, MoA, commercial license, no sponsor needed. | Incorporation application, MoA, commercial license, no sponsor needed. |
| Business Plan | Detailed, with UAE market focus and 3-year financials for Category I (cross-border). | Fintech-focused, with 1–3 year projections for Category 3D/4. | Fintech-focused, with 1–3 year projections for Category 3C, regional emphasis. |
| Financial Documents | Proof of AED 1.5M–3M capital, audited source of funds, bank statements. | Proof of USD 140,000–200,000 capital, audited source of funds, financial model. | Proof of USD 250,000 capital, audited source of funds, financial model. |
| Compliance Policies | AML/CFT (Federal Law No. 20), UAE IA Standards, PCI DSS, sanctions screening. | AML/CFT (DFSA GEN 11), DIFC data protection, PCI DSS, sanctions screening. | AML/CFT (FSRA AML Rulebook), ADGM data protection, PCI DSS, sanctions screening. |
| Governance Documents | Detailed org structure, corporate governance policy, key personnel CVs. | Org chart, governance policy, MLRO and key personnel details. | Org chart, governance policy, MLRO and key personnel details. |
| Operational Documents | IT security, UAEFTS/SWIFT integration, disaster recovery, high-volume testing. | IT security, global payment integration, disaster recovery, data protection. | IT security, global payment integration, disaster recovery, data protection. |
| Shareholder/Director | Passports, CVs, due diligence, no-objection certificates. | Passports, CVs, due diligence on beneficial owners. | Passports, CVs, due diligence on beneficial owners. |
| Other Documents | CBUAE application, audited financials (if applicable), letter of intent. | DFSA FSP form, Innovation Testing License (optional), office lease. | FSRA FSP form, RegLab application (optional), office lease. |
| Volume | High, with extensive local compliance requirements. | Moderate, fintech-friendly and streamlined for foreign entities. | Moderate, similar to DIFC but with ADGM-specific frameworks. |
| Complexity | High, due to CBUAE scrutiny and UAE-specific systems. | Moderate, with international standards and innovation focus. | Moderate, with international standards and sandbox flexibility. |
| Cross-Border Focus | Emphasis on UAEFTS integration, sanctions, and foreign exchange compliance. | Emphasis on global payment networks, sanctions, and data protection. | Emphasis on global networks, sanctions, and regional connectivity. |
