Crypto Law Profile

SCA Decision No. 26/RM of 2023: Virtual Assets Platform Operators

UAE SCA resolution that set operating, listing, custody, transparency and trading-system duties for virtual asset platform operators. It was later abrogated by CMA Decision No. 04/RM/2026, according to Lexis Middle East.

United Arab Emirates Repealed Regulation May 15, 2023

At a glance

Status Abrogated in 2026 by CMA Decision No. 04/RM/2026, according to Lexis Middle East.
Issued Issued Apr. 14, 2023; official PDF says it took effect on publication.
Scope Applied to UAE virtual assets platform operators and their platform obligations.
Regulator Issued by SCA, now succeeded by the UAE Capital Market Authority.

Overview

Status as of June 12, 2026: SCA Decision No. 26/RM of 2023, formally titled the Chairman of the Authority’s Board of Directors’ Resolution No. (26/Chairman) of 2023 regarding the Regulation of Virtual Assets Platform Operator, was the UAE federal framework for virtual assets platform operators before the 2026 Capital Market Authority framework. The decision was issued on April 14, 2023 and took effect on publication in the Official Gazette. Lexis Middle East lists Official Gazette Issue No. 751 dated May 15, 2023 and reports that CMA Decision No. 04/RM/2026 abrogated the 2023 decision.

The decision should therefore be treated as a historical, repealed UAE virtual assets regulation rather than the current operating rulebook. Current users should review the successor CMA framework and any applicable Dubai VARA, ADGM FSRA, DIFC DFSA, Central Bank, or free-zone rules where relevant. This profile is a legal-reference summary and not legal advice.

What the 2023 SCA virtual assets platform operator decision covered

The 2023 decision applied to virtual assets platform operators in the State. It defined a virtual assets platform operator as the legal person licensed by the Securities and Commodities Authority to regulate virtual asset transactions through a virtual assets platform. A platform was framed as infrastructure for listing, trading, transferring ownership, clearing and settling virtual assets, and storing related information through distributed ledger technology or similar technology.

Article 3 created an important listing control: a virtual asset could not be traded in the UAE unless it was accepted on the official list of a licensed platform operator and registered with the Authority. Article 4 then required the operator to register each accepted virtual asset with the Authority before trading commenced and allowed the Authority to oversee platform and VASP membership fees.

Key provisions for virtual assets platform operators

  • Systems and operational resilience: operators had to maintain effective electronic systems, business-continuity and disaster-recovery arrangements, stress testing, IT controls, and risk-management processes.
  • Operational rules: operators had to set rules for membership, accepted assets, defaults, investor access, AML/CFT compliance, disciplinary procedures, dispute settlement, public availability, consultation, and filing with the Authority.
  • Transparency and records: operators had to provide information about risks, fees and costs; record activities, transactions and orders; keep transaction records for at least 10 years; protect data; and disclose required information to the Authority.
  • Client asset protection: operators had to segregate their own money and virtual assets from customers’ money and virtual assets, provide safe custody and transfer procedures, identify customers and beneficiaries, and reconcile accounts.
  • Trading controls: operators had to establish fair and orderly trading rules, pre- and post-trade information, suspension and cancellation mechanisms, short-selling and lending controls, error policies, clearing and settlement arrangements, and access controls.

Relationship to the wider UAE virtual assets framework

SCA Decision No. 26/RM of 2023 was issued under the wider framework created by Cabinet Resolution No. 111 of 2022, which regulated virtual assets and VASPs in the UAE, including free zones, while excluding financial free zones, certain digital securities and commodity contracts, and payment-purpose virtual assets within Central Bank competence. Cabinet Resolution No. 111 also identified SCA-licensed activities such as VA platform operation, VA exchange services, transfer services, brokerage, and custody.

Cabinet Resolution No. 99 of 2024 later added a table of violations and administrative penalties for breaches of Cabinet Resolution No. 111 and its implementing instruments, including specific references to VAPO obligations under SCA Decision No. 26/RM of 2023.

Status and successor framework

Federal Decree-Law No. 32 of 2025 replaced the Securities and Commodities Authority with the Capital Market Authority and provided that references to the SCA in legislation would be read as references to the CMA. It also continued Cabinet Resolution No. 111, Cabinet Resolution No. 112, and prior Authority resolutions to the extent not inconsistent with the new laws, until repealed, amended, or superseded.

Lexis Middle East reports that CMA Decision No. 04/RM/2026, issued on February 13, 2026, abrogated Securities and Commodities Authority Decision No. 26/RM/2023. For CryptoSlate’s profile taxonomy, this supports mapping the 2023 SCA VAPO decision to Repealed, with an editorial verification note that the abrogation should be checked against the official CMA text if available.

Key provisions

Official list and registration controls

Virtual assets could be traded only if accepted on a licensed platform operator’s official list and registered with the Authority.

Licensing May 15, 2023 Source

Operator licensing and tasks

A VAPO could operate the platform alone or also perform VASP activities, but had to meet the corresponding obligations.

Licensing May 15, 2023 Source

Operational resilience and risk systems

Required effective systems, business-continuity controls, stress testing, IT reviews and documented risk-management processes.

Cybersecurity May 15, 2023 Source

Operational rules and consultation

Required public rules for membership, accepted assets, defaults, investor access, AML/CFT, disputes and discipline.

Market rules May 15, 2023 Source

Transparency, records and fees

Required risk and fee information, transaction and order records, 10-year recordkeeping, data protection and regulatory disclosures.

Disclosure May 15, 2023 Source

Custody and segregation

Required segregation of operator and client assets, safe custody and transfer processes, beneficiary identification and account reconciliation.

Custody May 15, 2023 Source

Trading, clearing and settlement controls

Required fair trading rules, trade information, suspension and cancellation tools, error policies, and clearing and settlement arrangements.

Market structure May 15, 2023 Source

Timeline

  1. Cabinet Resolution No. 111 takes effect

    UAE federal VA/VASP framework came into force, establishing SCA licensing and oversight powers.

    In force Source
  2. SCA VAPO decision issued

    SCA Chairman issued Decision No. 26/RM/2023 on virtual assets platform operators.

    Enacted Source
  3. SCA VAPO decision published

    Official PDF says the decision took effect on publication; Lexis lists OG Issue 751 dated May 15, 2023.

    In force Source
  4. Cabinet penalties table active

    Cabinet Resolution No. 99/2024 added VA/VASP penalties, including VAPO obligation references.

    In force Source
  5. CMA successor laws enter force

    Federal Decree-Laws 32 and 33/2025 replaced SCA with CMA and continued prior rules unless superseded.

    In force Source
  6. CMA Decision No. 04/RM/2026 issued

    Lexis reports that CMA Decision No. 04/RM/2026 abrogated SCA Decision No. 26/RM/2023.

    Repealed Source

Who it affects

Actors

Capital Market Authority, Securities and Commodities Authority, UAE Cabinet

Asset classes

Virtual assets

Official sources

Editorial note

Status note: Lexis Middle East reports that CMA Decision No. 04/RM/2026 abrogated SCA Decision No. 26/RM/2023. Editors should verify against the official CMA text when available.