UAE CMA Category 5 License — Marketing & Financial Promotions Authorization (2026)

What is the UAE CMA Category 5 License?

The UAE CMA Category 5 license authorizes firms to conduct marketing, promotion, financial consultation, and client introduction activities related to financial services and products in the UAE. It allows the licensed entity to refer UAE-based clients to a foreign regulated broker or investment firm without directly executing trades, managing portfolios, or providing formal investment advice.

Note: No leverage restrictions apply — since the licensed entity itself does not execute orders, leverage rules applicable to trading firms are not relevant at the Category 5 level.

For a detailed breakdown of which investor categories you can legally market to under Category 5 — including the specific AED asset thresholds for professional investors — see our guide: Who Can You Legally Market To Under UAE Category 5? →

Who Needs a CMA Category 5 License?

The Category 5 license is specifically designed for international financial services firms seeking a regulated UAE presence without the cost and complexity of a full Category 1 brokerage or Category 4 asset management authorization.

• •Offshore forex and CFD brokers holding foreign licenses (AFSL, CySEC CIF, Mauritius Investment Dealer, Seychelles Securities Dealer, FSCA, FCA) who want a regulated UAE entity to market their services locally
• •International asset managers and fund promoters seeking to reach HNWI and institutional clients in the UAE
• •FinTech companies providing financial product comparison, referral, or lead-generation services
• •Financial consulting firms offering introductory and arrangement services

2026 SCA to CMA Regulatory Transition

Effective 1 January 2026, the UAE enacted Federal Decree-Laws No. 32 and No. 33 of 2025, replacing the SCA with the Capital Market Authority (CMA) as the federal capital markets regulator. The CMA is the legal successor to the SCA and inherits all its rights, contracts, and obligations.

1. 1
   Replaced the SCA with the CMA as the federal capital markets regulator with expanded jurisdiction covering cross-border activities impacting UAE markets
2. 2
   Expanded regulatory scope — the CMA's authority now extends to activities conducted abroad by UAE entities or nationals
3. 3
   Introduced stronger enforcement powers — higher maximum penalties, broader sanctions, and a new recovery and resolution regime
4. 4
   Preserved existing licenses — existing SCA Category 5 licenses carry forward; firms have until 1 January 2027 to regularize under the new framework

For new applicants, the process is now directed to the CMA. The SCA Rulebook (Board of Directors' Decision No. 13/R.M of 2021) continues to apply as the operational framework during the transition. Zitadelle AG monitors all CMA implementing regulations as they are issued and advises clients on compliance in real time.

Key Requirements for CMA Category 5 Authorization

Capital Requirements

Local Company Incorporation

A UAE mainland company is required. Importantly, incorporation can occur concurrently with the licensing process — you do not need to wait for a company to be fully set up before initiating your CMA application. Zitadelle AG manages both processes simultaneously to minimize overall timeline.

Governance and Staffing

UBO Fit and Proper Requirements

• Clean criminal record certificate from home country
• Credit report from a recognised credit agency with no negative entries
• Clean public record — adverse media or past regulatory sanctions can materially jeopardize approval

Application Timeline

The biggest single variable affecting timeline is whether your key staff are already CMA-qualified. Zitadelle AG streamlines the process by coordinating document preparation, staff sourcing, business plan drafting, and regulatory submissions in parallel.

The M&A Route — Acquiring an Existing Category 5 Entity

For firms that need UAE market access faster than the ~6–12 month new application timeline allows, acquiring an existing CMA Category 5-licensed entity is a viable alternative.

Trade-offs

A pre-approved acquisition reduces time-to-market significantly — the licensed entity is already operational, with an established SEO, Compliance Officer, and Promotions Manager in place.

However, acquisition requires detailed legal and operational due diligence: reviewing the target's compliance history, any prior CMA correspondence or sanctions, the quality of existing staff (whether they remain post-acquisition), and the condition of the company's banking relationships.

A new application provides full structural control — you design the governance, choose your own key personnel, and build the compliance framework from scratch — at the cost of a longer timeline.

Zitadelle AG lists available CMA Category 5-licensed entities on Financial License Market and manages the complete acquisition process — due diligence, CMA change-of-control notification, and transition planning for key staff retention or replacement.

Browse licensed entities for sale →|M&A Advisory Services →

CMA Category 5 vs DFSA (DIFC) — Which UAE Structure Is Right?

The UAE has multiple distinct regulatory perimeters that are frequently confused by first-time applicants. CMA Category 5 governs UAE mainland marketing and introduction activity. The Dubai Financial Services Authority (DFSA) is a separate, independent regulator for the Dubai International Financial Centre (DIFC) — a financial free zone operating under its own English common law framework.

Which to choose: CMA Category 5 is correct for firms whose primary goal is reaching UAE mainland retail and professional clients with marketing and introduction activity — the most common use case for offshore brokers. DFSA (DIFC) Category 4 is correct for firms prioritizing institutional credibility, English common law certainty, and professional-client-only fund distribution from a globally recognized financial free zone.

Some groups hold both — a CMA Category 5 entity for mainland marketing reach and a DFSA Category 4 entity for DIFC-based institutional distribution.

DFSA Category 4 License (DIFC) →|UAE CFD & FX Licensing Comparison →

Why the UAE CMA Category 5 License in 2026?

How Zitadelle AG Supports Your Application

Zitadelle AG is a specialist regulatory consultancy offering end-to-end advisory and execution support for firms seeking CMA Category 5 authorization in the UAE.

• Regulatory feasibility assessment — we evaluate your firm's structure, UBO profile, and existing licenses to advise on the optimal approach before you commit resources
• Corporate structuring and UAE company incorporation — handled in parallel with licensing to reduce overall timeline
• Key staff sourcing and onboarding — access to our network of pre-vetted, CMA-exam-eligible professionals via HRFinEase
• Business plan and internal policy drafting — tailored to CMA expectations and examination standards
• Full application management — end-to-end coordination of submissions, CMA correspondence, and feedback
• Post-licensing compliance support — ongoing assistance with CMA reporting, annual renewals, and regulatory updates
• CMA transition advisory — for existing SCA Category 5 licensees navigating the 2026 regulatory overhaul
• Simultaneous multi-jurisdiction licensing — for firms seeking UAE authorization alongside other licenses (CySEC, AFSL, Mauritius, Seychelles)

UAE DMCC Company Formation →|Dubai VARA License →