Question 1

Who regulates insurance in the UAE?

Accepted Answer

Three regulators with distinct perimeters. (1) Central Bank of the UAE (CBUAE) — under Federal Decree-Law 48 of 2023 (the new Insurance Law replacing FL 6/2007), CBUAE assumed the role formerly held by the standalone Insurance Authority (since 2020 reform). CBUAE licenses mainland UAE insurers, reinsurers, takaful operators, brokers, agents and surveyors. (2) DIFC Financial Services Authority (DFSA) — licenses insurance intermediaries, captive insurers and reinsurance carriers operating within DIFC. (3) ADGM Financial Services Regulatory Authority (FSRA) — licenses ADGM-located insurance entities. Mandatory motor and health insurance regimes operate under separate authority (RTA/Dubai Health Authority etc.) but reinsurance flows through CBUAE-licensed entities.

Question 2

What does the new Insurance Law (FDL 48/2023) change?

Accepted Answer

Federal Decree-Law 48 of 2023 modernised the UAE insurance regime, with key changes including: (i) consolidation of regulator under CBUAE (completing the 2020 reform); (ii) updated capital adequacy framework aligned to international solvency standards (RBC); (iii) clearer mandatory cession requirements for reinsurance; (iv) bancassurance regulation; (v) digital and embedded insurance frameworks; (vi) takaful-specific provisions strengthening Sharia governance; (vii) consumer protection provisions including unfair-terms test and cooling-off rights; (viii) stricter licensing and ongoing-fitness criteria for senior insurance personnel; (ix) enhanced enforcement and AML/CFT integration. Implementing regulations and Cabinet Decisions continue to roll out.

Question 3

What is takaful and how is it different?

Accepted Answer

Takaful is the Sharia-compliant alternative to conventional insurance — based on mutual contribution (tabarru'), risk sharing rather than transfer, and Sharia-compliant underlying investments. UAE structure: takaful operator manages a separate Participants' Fund (the risk pool funded by contributions) and a Shareholders' Fund (the operator's capital and management fees), under the wakala or hybrid wakala-mudaraba model. CBUAE licenses takaful operators separately from conventional insurers. Sharia Supervisory Board approval is required for all products. Re-takaful is the equivalent reinsurance market. Major UAE takaful operators include Salama, ADNIC's takaful arm, Watania, Methaq. Cross-border placement requires careful Sharia and regulatory analysis.

Question 4

How are insurance disputes resolved?

Accepted Answer

Multiple dispute paths depending on policy and dispute type. (i) IDC (Insurance Disputes Settlement & Reconciliation Committee) — federal-level body for fast-track consumer insurance disputes (motor, health) up to specified thresholds; binding decisions subject to court appeal. (ii) Onshore courts (CFI / Appeal / Cassation) — typical forum for commercial insurance disputes including marine, fire, D&O, professional indemnity, business interruption. (iii) DIFC and ADGM Courts — for DIFC/ADGM-domiciled insureds and policies with appropriate jurisdiction clauses; English-law principles apply. (iv) Arbitration — many large commercial policies have DIAC, LCIA or LMAA arbitration clauses; particularly common in marine and energy insurance. We act for insureds, insurers and reinsurers across all four paths.

Question 5

What about D&O insurance — what should the policy cover?

Accepted Answer

D&O cover for UAE-listed and unlisted companies should include: (i) Side A (direct cover for individuals where company cannot indemnify); (ii) Side B (company reimbursement for indemnification of individuals); (iii) Side C (entity cover for securities claims, where applicable); (iv) regulatory investigation cover (for SCA, CBUAE, FSRA, DFSA inquiries) — increasingly important; (v) cross-border defence cost cover where individuals face parallel non-UAE proceedings; (vi) outside director cover for board roles in subsidiaries; (vii) bookrunner / IPO cover for capital-markets work. Common gaps: aggregate-limit erosion under defence costs, sub-limited regulatory investigation coverage, broad ML/sanctions exclusions. We routinely review D&O placements pre-binder and on claim notification.

Question 6

What about cyber insurance?

Accepted Answer

UAE cyber-insurance market has grown rapidly post-2022 with the rise in ransomware and the introduction of PDPL (FDL 45/2021). Coverage typically includes: first-party (incident response costs, forensic, notification, business interruption, cyber-extortion); third-party (regulatory fines where insurable, defence costs, defence of regulatory action); and add-ons (PR, credit monitoring, hardware replacement). Critical coverage points: ransomware payment coverage (some policies now exclude or sub-limit ransomware), state-actor exclusions (post-Ukraine war, cyber-war exclusions are widespread), aggregation rules across multiple insureds in a single attack, scope of business interruption (often narrow versus expectations). UAE-licensed insurers issue most cover but London-market and international reinsurance is the underlying market.

UAE Insurance & Reinsurance — CBUAE, DIFC, ADGM and the takaful framework.

What we do for insurers, brokers, insureds and claimants.

Regulatory & licensing

Underwriting & product

Claims & disputes

M&A & transactional

Frequently asked questions

Insurance matter — claim, dispute, or licensing?