CBUAE, DFSA, or FSRA: Which Regulates Insurance Where You Are?

The Insurance Authority (IA) — established under Federal Law No. 6 of 2007 — no longer exists as an institution. It was dissolved and its functions folded into the Central Bank of the UAE (CBUAE) through two 2020 instruments: Decretal Federal Law No. 24 of 2020 and Decretal Federal Law No. 25 of 2020, the second of which amended the then-Central Bank law to bring insurance regulation inside it. The CBUAE confirmed the transfer was complete in its own announcement of 27 January 2021, describing itself as assuming “the regulatory, supervisory, licensing and enforcement functions of the insurance sector.”

This does not mean every old Insurance Authority rule vanished. The CBUAE’s own transfer announcement states that existing Insurance Authority regulations continue to apply to licensed institutions and activities until the CBUAE replaces them — which is why older instruments, such as an Insurance Authority Board of Directors’ decision on motor claims discussed later in this guide, are still cited as live law today. The institution is gone; most of its rules are still in force under the Central Bank’s authority.

• Central Bank of the UAE ↗

The substantive insurance-activities law currently in force is Federal Decree-Law No. 48 of 2023 Regulating Insurance Activities, issued 2 October 2023 and effective 30 November 2023. It names the CBUAE as supervisor — the Governor implements the law and the CBUAE’s Board of Directors sets regulatory policy — and it repeals Federal Law No. 6 of 2007, the original 2007 statute the old Insurance Authority once administered.

Sitting alongside it is Federal Decree-Law No. 6 of 2025, the newly consolidated Central Bank law, issued 8 September 2025 and effective 16 September 2025. It confirms the CBUAE’s supervisory authority over insurers, reinsurers, takaful operators, and insurance-related professions, and requires branches of foreign insurers to provide the CBUAE with an unconditional, irrevocable bank guarantee. Between the two, this is the current federal framework — not Federal Law No. 6 of 2007, and not anything issued in the Insurance Authority’s name.

• uaelegislation.gov.ae ↗

Outside the two financial free zones, insurance business is regulated federally by the CBUAE — this covers Dubai mainland, Abu Dhabi mainland, and the great majority of the UAE’s other free zones, which operate under federal law rather than their own separate regimes.

The DIFC and ADGM are different in kind, not just in rulebook. Each runs a full separate financial-services regulatory system, with its own regulator, its own licensing categories, and, in places, its own court system. An insurer, broker, or policy connected to the DIFC sits under the Dubai Financial Services Authority (DFSA); one connected to ADGM sits under the Financial Services Regulatory Authority (FSRA). Confusing “based in Dubai” with “regulated by the CBUAE,” or “based in Abu Dhabi” with the same, is a common and consequential mistake once the DIFC or ADGM is involved.

Under Federal Decree-Law No. 48 of 2023, Article 26 requires an insurer to pay the compensation set out in the policy “as soon as the insured incident occurs or the insured risk materialises” — a general obligation, not a fixed numeric deadline. Article 5 separately gives the CBUAE’s Board power to impose compulsory insurance on specific risks by regulation, which is the enabling power behind compulsory motor insurance discussed below.

Where a dispute over an insurance claim can’t be resolved directly, mainland UAE runs its own dispute-committee structure, described in detail later in this guide: decisions up to AED 50,000 are treated as final, and decisions above that can be appealed to the Court of Appeal within 30 days of the decision. The exact article number behind that threshold was not independently confirmed in the research behind this guide, but the figures themselves are corroborated across more than one independent legal-commentary source.

• Central Bank of the UAE Rulebook ↗

Insurance business connected to the DIFC sits entirely outside the CBUAE’s regulatory perimeter. It is regulated by the Dubai Financial Services Authority (DFSA), the DIFC’s own independent financial regulator, which licenses insurers, reinsurers, and takaful operators for “Effecting and Carrying Out Contracts of Insurance,” brokers for “Insurance Intermediation,” and agents and coverholders for “Insurance Management.” The DFSA also regulates managing general agents, coverholders, third-party administrators, insurance managers, and representative offices — a genuinely broader intermediary perimeter than a narrower assumption that free-zone regulators only cover brokers.

Two points of real distinction are worth knowing. The DFSA describes itself as “not a products regulator” — insurers within their licensed classes don’t need product-level approval, provided they run appropriate systems and controls, which is a lighter-touch approach than product-by-product sign-off. And the Lloyd’s of London entity situated in the DIFC is not itself regulated by the DFSA as such; individual managing agents and coverholders operating on the Lloyd’s platform are separately DFSA-authorised.

• DFSA ↗

ADGM runs its own separate regime again. The Financial Services Regulatory Authority (FSRA) regulates insurance business in ADGM under the Financial Services and Markets Regulations 2015 (FSMR), applying what it describes as a risk-based approach, and is a member of the International Association of Insurance Supervisors. Its Insurance Business Supplement sets out four licensed insurance-business activities: Effecting Contracts of Insurance (underwriting), Carrying Out Contracts of Insurance (administration), Insurance Intermediation (brokering and distribution), and Insurance Management.

ADGM’s clearest point of differentiation is captive insurance. The FSRA’s Insurance Business Supplement sets out a dedicated “Class of Captive Cell” framework across four classes, and notes that an applicant planning to write captive insurance business should contact the FSRA in advance to discuss additional requirements. Nothing equivalent to this specialisation appears in the mainland CBUAE regime or, on the evidence available, in the DIFC’s DFSA regime — it is a genuine niche ADGM has built for itself.

• ADGM ↗

Vehicle registration on the mainland requires insurance as a matter of law, not just convention. Federal Decree-Law No. 14 of 2024 on Traffic Regulation, Article 19(1), states that in order to licence or renew the licence of a vehicle, it must be insured by a licensed UAE insurer. The law repeals the older 1995 Traffic Law and came into force 180 days after publication — approximately early 2025, though the exact in-force date was not independently confirmed for this guide.

The mechanics of a motor third-party-liability claim are still governed by Insurance Authority Board of Directors’ Decision No. 25 of 2016 — a continuity-clause survivor, still live in the CBUAE Rulebook. It sets the single most concrete numeric deadline found anywhere in UAE insurance regulation: the insurer must flag any missing claim documents within three days, and once the claim file is complete, must fairly settle it within fifteen days; for a total loss specifically, compensation is due within fifteen days, with a specific compensation remedy if the insurer overruns that without justification. This deadline applies to motor third-party-liability claims specifically — it is not a general rule for insurance claims of every kind, whatever secondary commentary sometimes implies.

• uaelegislation.gov.ae ↗

There is no single federal “UAE mandatory health insurance law.” Dubai runs its own regime under Law No. 11 of 2013, regulated by the Dubai Health Authority, which requires employers to enrol employees and sponsors to enrol dependants not otherwise covered, backed by penalties from AED 500 up to an AED 500,000 cap for repeat violations. Abu Dhabi runs a separate regime under Law No. 23 of 2005, enforced by the Department of Health, requiring non-nationals holding Abu Dhabi work or residence visas — and certain visitor categories — to be insured, with UAE nationals covered separately through the government-funded Thiqa programme administered by Daman.

The other five emirates — Sharjah, Ajman, Fujairah, Ras Al Khaimah, and Umm Al Quwain — sit under a newer federal “Basic Health Insurance Scheme,” effective 1 January 2025 per MOHRE’s own guidance, applying to private-sector employers and employers of domestic workers as a precondition for issuing or renewing residency permits. Dubai and Abu Dhabi are explicitly outside this federal scheme; they keep their own, older, emirate-level laws. Anyone assuming one national rule covers all seven emirates is working from an outdated or oversimplified picture.

• Dubai Legislation (DHA) ↗
• MOHRE ↗

For mainland (and, on the evidence gathered, federally regulated) insurance, the first step is always a formal complaint to the insurer itself — every escalation route below requires this to have happened first, with the insurer given time to respond. From there, the relevant body is Sanadak, the Central Bank’s Ombudsman Unit, which describes itself as the first financial Ombudsman Unit in the MENA region. It is free to use, open to natural persons, sole proprietors, and SMEs (not, on this evidence, large corporates), and covers health, car, property, general, marine, and life and investment insurance complaints, provided the same issue isn’t already in court or already decided.

Sanadak’s own published process runs roughly as follows: acknowledgment of a complaint within three business days, up to ten business days to respond to any request for more information, a substantive institutional response window referenced elsewhere as 30 complete business days, a written decision once review is complete, and a 30-business-day window to appeal that decision. Insurance-specific complaints are handled through the Insurance Dispute Resolution Committee, which Sanadak’s own site describes as sitting within Sanadak and acting as the first instance for complaints about insurance companies. Decisions up to AED 50,000 are final; above that, they can be appealed to the Court of Appeal within 30 days.

• Sanadak ↗

Two genuine gaps came up while researching Sanadak’s process, and it would be misleading to paper over either. First, the waiting period before you can escalate an unresolved insurer complaint to Sanadak is stated differently in two places that both look authoritative: Sanadak’s own site (across three separate pages) says 15 calendar days; the UAE’s official government services portal, u.ae, says 30 calendar days. These can’t both be precisely right, and this guide isn’t going to pick one — check the current figure directly on sanadak.gov.ae before relying on it.

Second, some legal commentary describes the Insurance Dispute Resolution Committee as an appeal stage that sits above Sanadak, rather than as Sanadak’s own first-instance insurance arm, and cites a specific 2024 instrument for that structure. That instrument was not independently located or confirmed on a primary government source for this guide, so this guide is not going to assert a single confident sequence for how the two bodies relate. What is confirmed is that both a Sanadak process and an Insurance Dispute Resolution Committee exist and that insurance complaints move through them — the precise order is worth confirming directly with Sanadak or a lawyer for a live complaint.

Sanadak is the Central Bank’s mechanism, and it is not confirmed, on the research behind this guide, whether DIFC or ADGM policyholders can use it at all, or are confined to their own free-zone regulator and court routes instead. This guide is not going to guess. Financial free zones are commonly carved out of federal financial-services regimes elsewhere in UAE law, which makes “DIFC and ADGM run their own separate complaint routes” a reasonable working assumption — but it is an inference, not a confirmed fact, and it wasn’t independently checked against a DFSA or FSRA source stating it directly.

The safer approach for a DIFC or ADGM policyholder is to check directly with the DFSA or FSRA (or the DIFC Courts or ADGM Courts, if it has reached that stage) rather than assuming the mainland Sanadak process applies. Similarly, no ADGM-specific claims-handling timeframe or ombudsman-equivalent body was found for this guide — if one exists, it wasn’t located in the sources used here.

That the “Insurance Authority” still regulates UAE insurance — it doesn’t; it was dissolved and folded into the Central Bank in 2020–2021, and the current framework runs under Federal Decree-Law No. 48 of 2023 and Federal Decree-Law No. 6 of 2025.

That UAE law fixes a general deadline for any insurer to pay or reject any claim — it doesn’t; Article 26 of Federal Decree-Law No. 48 of 2023 only requires payment “as soon as” the incident occurs, with no fixed number of days named. The one place a hard number genuinely exists is motor third-party-liability claims specifically, not insurance claims generally.

That there’s one UAE mandatory health insurance law — there isn’t; it’s three separate regimes, one each for Dubai, Abu Dhabi, and the other five emirates, on different legal bases with different effective dates.

That arbitration is a standard or default step in a UAE insurance dispute — it isn’t; it only applies where the specific policy itself contains an arbitration clause. The route that actually exists by default is insurer complaint, then Sanadak, then, for insurance, the Insurance Dispute Resolution Committee, then the Court of Appeal for claims above AED 50,000.

LEXNOVA is a lawyer-matching service — it is not a law firm and does not give legal advice or interpret a specific policy or claim. What it does is help you describe your situation clearly enough — which regulator likely governs your insurer or policy, and what the dispute or question actually is — that you can be matched with lawyers whose practice fits the regime involved, whether that’s mainland CBUAE-regulated insurance, DIFC/DFSA, or ADGM/FSRA. Every match is reviewed by a person, and the working relationship, once formed, is directly between you and the lawyer you choose.