Find a CMA Securities Regulation (formerly SCA) Lawyer

As of January 1, 2026, the UAE’s Securities and Commodities Authority was replaced by the Capital Market Authority, known as the CMA, established under Federal Decree-Law No. 32 of 2025, with Federal Decree-Law No. 33 of 2025 regulating capital market activity. The CMA is the SCA’s legal successor, and the change involved more than a new name.

The CMA then issued a new federal framework for virtual assets, announced on 13 April 2026, which expands the scope of regulated virtual asset activities from three to eight — replacing the previous onshore framework rather than renaming it.

For businesses that were already familiar with SCA rules, or are researching UAE securities regulation, understanding this transition and its practical implications is an important first step.

A lawyer with genuinely current knowledge of the CMA’s post-transition framework is essential given how recently, and substantially, this regulatory landscape has changed.

Launching an investment product, security token offering, or other CMA-regulated financial activity at the federal UAE level is a direct reason to need guidance on this framework.

Operating an existing business that may fall within the CMA’s expanded post-2026 scope, even if it didn’t clearly fall under the previous SCA framework, warrants a proactive compliance review.

Structuring a token or digital asset product with investment characteristics raises important classification questions relevant to CMA regulation specifically.

Businesses operating across multiple UAE regulatory frameworks, potentially involving both VARA and the CMA, benefit from guidance on how these frameworks interact for their specific activities.

Securities and investment token classification, determining whether a specific product or token falls within CMA-regulated categories.

CMA licensing applications, covering the process for businesses conducting CMA-regulated financial activities.

Capital markets compliance, addressing ongoing obligations for businesses operating within CMA’s regulatory scope.

Multi-regulator coordination, addressing situations where a business may need to navigate both CMA and VARA, or other UAE regulatory frameworks.

Transition guidance, helping existing businesses understand how the 2026 SCA-to-CMA transition affects their compliance position.

LEXNOVA is not a law firm and does not provide legal advice. Legal Connect exists to help you describe your CMA-related needs clearly, then explore potentially suitable legal professionals from our network.

We consider factors like your specific business activity, whether it involves securities, investment tokens, or another CMA-regulated category, and any overlap with other UAE regulatory frameworks.

Every potential match involves human review before an introduction is made, this area requires genuinely current regulatory knowledge given how recently the framework changed.

Once we identify potentially suitable professionals, we help facilitate an introduction, from there the lawyer can properly assess your specific business against the current CMA framework.

The CMA operates at the federal level, meaning its authority extends across the UAE, addressing securities and investment token regulation regardless of which emirate a business operates in.

VARA, by contrast, is specifically Dubai’s regulator for virtual asset activity within the emirate, excluding the DIFC, a genuinely distinct scope from the CMA’s federal securities focus.

For certain virtual asset businesses, particularly those involving investment-characteristic tokens, both CMA and VARA requirements may potentially be relevant, depending on the specific activity.

Understanding which regulator, or regulators, apply to your specific business is a foundational step that a lawyer with current knowledge of both frameworks can help clarify.

On 13 April 2026, the CMA announced its virtual assets framework: the Chairman of the Authority’s Board of Directors’ Resolution No. (4/R.M) of 2026 Concerning the Regulation of Virtual Assets Service Providers and the Alternative Trading System Operator. In the CMA’s own words, it expands the scope of regulated activities from three to eight, moving from a narrower set of regulated categories to a more comprehensive licensing structure.

The CMA names five core modules — General Requirements; Conduct of Business; Alternative Trading System; Anti-Money Laundering and Counter-Terrorist Financing; and Prudential Requirements — and eight regulated activities: Dealing in Virtual Assets as Principal, Dealing in Virtual Assets as Agent, Providing Custody, Arranging Custody, Arranging Investment Deals, Providing Investment Advice, Portfolio Management, and Operating a Multilateral Trading Facility.

According to the CMA, the Alternative Trading System module is not limited to trading facilities dedicated to virtual assets: it also extends to conventional multilateral trading facilities for securities and to facilities dedicated to tokenized securities. The framework is stated to be aligned with IOSCO and FATF standards and the principle of “same activity, same risk, same regulatory outcome.”

The resolution’s own commencement date, any repeal it effected, and any transitional treatment for firms licensed under the previous framework are not on the public record, so these are questions to put to a lawyer rather than assume.

While this framework replaced the previous onshore approach, it operates alongside the other UAE regimes rather than absorbing them: VARA for Dubai excluding the DIFC, the DFSA for the DIFC, and the FSRA for ADGM. The Central Bank’s separate track — including Article 62 of Federal Decree-Law No. 6 of 2025, which brings DeFi, dApps and protocols into its scope — is distinct from the CMA’s framework. Businesses need to understand how the CMA’s rules interact with each of these as relevant to their specific activities.

The expanded framework reflects the UAE’s broader effort to bring federal-level clarity and oversight to virtual asset activities that have investment or securities characteristics.

Given how recently this framework was introduced, businesses should seek guidance from lawyers with genuinely current, verified knowledge of the specific requirements now in place.

Determining whether a specific token or digital asset falls within CMA-regulated categories depends on its underlying structure, the rights it grants, and how it’s marketed and used.

This classification exercise is genuinely nuanced, a token with characteristics resembling a traditional security is treated differently than one functioning purely as a utility or payment token.

Getting this classification right from the outset affects which regulatory framework, if any, applies to your specific product, with meaningful compliance implications either way.

A lawyer with genuine experience in this area can help you assess your specific token’s classification and the resulting regulatory obligations.

The process typically begins with a careful assessment of your specific business activity or product against the CMA’s current regulated categories.

Where CMA authorization or licensing is required, this generally involves preparing documentation covering your business structure, governance, and compliance framework.

Given the framework’s recent expansion, the process may involve genuinely new considerations that a lawyer with current knowledge can help you navigate.

Throughout this process, understanding how CMA requirements interact with any other applicable UAE regulatory frameworks is an important, ongoing consideration.

Larger firms may bring more resources for complex, multi-regulator compliance situations involving significant institutional activity.

Independent lawyers with genuinely current CMA and broader UAE virtual asset regulatory knowledge can offer more direct, accessible guidance for many businesses.

Given how recently the CMA framework changed, prioritizing genuinely current, verified expertise matters more than firm size alone in this specific area.

This is a preference you can share through Legal Connect, and we’ll take it into account alongside the specific expertise your situation requires.

How current is their knowledge of the SCA-to-CMA transition and the CMA’s April 2026 virtual assets framework, given how recently and substantially this framework changed?

Can they clearly explain how CMA regulation interacts with VARA, DFSA, and FSRA for a business like yours?

What is their fee structure for assessing your specific compliance position or pursuing authorization?

These are reasonable questions any credible lawyer in this specialized area should answer clearly and confidently.

Fees vary considerably based on the complexity of your business activity and whether multiple regulatory frameworks are potentially relevant to your situation.

LEXNOVA does not set or control fees, this is communicated directly by each professional, and it’s reasonable to request a clear estimate before proceeding.

Given the genuinely novel nature of parts of the CMA’s expanded framework, an initial scoping conversation to understand your specific situation is often a worthwhile starting point.

A credible lawyer should be transparent about costs relative to the specific compliance work your business requires.

A lawyer who still refers only to "SCA" without acknowledging that the CMA replaced it in 2026 likely isn’t current on this rapidly evolved framework. Describing the change as a simple rename is a related warning sign: the CMA replaced the SCA, and its April 2026 virtual assets framework replaced the previous onshore regime.

Confusion between CMA and VARA’s distinct scopes is a meaningful red flag given how important this distinction is for accurate compliance guidance.

Overly confident classification of your token or product without genuine analysis of its specific structure and rights is worth questioning.

Trust your own judgment, given how recently this framework changed, it’s entirely reasonable to seek a lawyer who demonstrates genuinely current, verified knowledge rather than outdated assumptions.