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The position
A UAE insurer is now governed by the same statute as a bank.
A UAE insurer is now governed by the same statute as a bank. Since 16 September 2025 the operative law is Federal Decree-Law No. 6 of 2025 on the Central Bank, the regulation of financial institutions and activities, and insurance business, which is in force and applies to the Central Bank, to financial institutions, and expressly to insurance business (Federal Decree-Law No. 6 of 2025, Article 2). Insurance is no longer set out in a standalone insurance statute. The definitions of an Insurance Company, a Reinsurance Company, an Insurance Broker, an Actuary, Technical Provisions and the Solvency Margin now sit in the Central Bank law’s own definitions article, and insurers are classed as Licensed Financial Institutions alongside banks (Article 1). One law now covers banks, insurers, payment providers and financial market infrastructures.
The move repealed what came before it. Federal Decree-Law No. 6 of 2025 repealed both the 2018 Central Bank law and the 2023 insurance law; the Central Bank’s own rulebook now marks the 2023 insurance law as repealed by the 2025 decree-law. The financial free zones are carved out: the decree-law does not apply within the Dubai International Financial Centre or the Abu Dhabi Global Market, or to institutions their authorities regulate (Article 2). And the large body of implementing decisions built up over the previous regimes does not fall away with the statutes; it continues in force until the Central Bank replaces it (Article 183), which makes the currency question a per-instrument check rather than a single answer.
So the position has three parts, each developed below: the current law is the consolidated 2025 decree-law; the free-zone insurers sit outside it under their own regulators; and the operational detail is a mix of surviving Insurance-Authority-era decisions and newer Central Bank instruments, whose status must be confirmed one instrument at a time.
The structural change is that insurance has been brought inside the Central Bank law rather than left in a sector-specific statute. The scope provision states it plainly: the decree-law applies to the Central Bank, to financial institutions, to insurance business, to financial activities, and to the persons subject to it (Article 2). The definitions article carries the whole insurance vocabulary, from the Insurance Policy and the Premium (called the Contribution in takaful) to the Solvency Margin and the Insurance-Related Professions (Article 1). And the umbrella term Licensed Financial Institutions is defined to mean banks, (re)insurance companies and other financial institutions licensed under the decree-law (Article 1), so an insurer is a licensed financial institution in the same sense a bank is.
The consequence is that the prudential, governance, enforcement and resolution machinery of the Central Bank law now reaches insurers by default, because they are within its defined perimeter, rather than through a separate insurance code. For an insurer, the practical reading is that the general provisions of this decree-law apply to it unless a provision is limited to banks or to a particular class, and the insurance-specific provisions sit as a section within the larger law rather than as a statute of their own. The takaful provisions examined in the companion articles, at Articles 104 and 105, are one such section within this consolidated law.
The current law is the third generation of UAE insurance statute, and the first to sit inside the Central Bank law. The 2025 decree-law repealed the 2018 Central Bank law and the 2023 insurance law; the repeal of the latter is confirmed on the Central Bank’s rulebook, which now displays the 2023 insurance law as repealed by Federal Decree-Law No. 6 of 2025, and the 2025 preamble lists the 2023 insurance law among the instruments it supersedes (Article 185 additionally repeals any provision in force that conflicts with the new law; the express-repeal wording is drawn here from practitioner summaries of Article 185 and flagged for primary confirmation).
The steps before that are set out here as context, on secondary sources. The 2023 insurance law had itself replaced the 2007 insurance law, and the 2023 law was occasioned by the transfer of insurance supervision to the Central Bank when the Insurance Authority was merged into it in 2020; these points are drawn from practitioner commentary rather than the primary instruments, and the exact 2020 decree that effected the merger is stated inconsistently across the sources seen and is not asserted here. What the primary instruments establish is the endpoint: insurance supervision now sits with the Central Bank, and the governing statute is the consolidated 2025 decree-law, not any of its predecessors.
The consolidated law stops at the edge of the financial free zones. It does not apply within the Dubai International Financial Centre or the Abu Dhabi Global Market, or to financial institutions regulated by those zones’ authorities (Article 2). A (re)insurer licensed in the DIFC is regulated by the Dubai Financial Services Authority, and one in the ADGM by the Financial Services Regulatory Authority, under those regimes’ own rulebooks, not under the Central Bank law. This article does not set out the free-zone insurance regimes; a comparison of the onshore Central Bank regime with the DFSA and FSRA frameworks requires those modules to be read, and they were not loaded for this article, so the comparison is reserved rather than made.
One qualification to the boundary is worth flagging, and it rests on secondary sources. Practitioner analysis of the 2025 law reads its prohibition on unlicensed financial activity, and on communications relating to such activity, as capable of reaching firms that target UAE customers from a free zone or from abroad, on the basis that the free zones remain subject to federal laws other than civil and commercial ones and that the Central Bank law prevails in the event of conflict. That reading turns on the interaction of the 2025 law with the financial-free-zones law and is drawn from commentary rather than a primary reading here; it is noted so the free-zone carve-out is not over-read as a complete exemption, and flagged for primary verification before reliance.
The reason the currency question has to be asked instrument by instrument is that the implementing detail survives the change of statute through a continuity provision, and it has done so more than once. Under the 2025 law, all regulations, decisions, standards, circulars and guidance issued under the repealed 2018 Central Bank law and the repealed 2023 insurance law remain in force until the Central Bank replaces them (Article 183). The 2023 insurance law had carried its own continuity provision preserving the decisions and circulars of the 2007 insurance law until superseded (that earlier provision is cited here from practitioner commentary and flagged accordingly). The effect is a chain: an Insurance-Authority decision made under the 2007 law could survive into the 2023 regime and then into the 2025 regime, still in force because no replacement has yet displaced it.
So the operative body of insurance regulation is a mixture, and the companion articles show both kinds. Some Insurance-Authority-era instruments have been replaced by Central-Bank-era ones: the 2010 takaful regulation was superseded by the 2022 Regulation Regarding Takaful Insurance, and the 2019 decision on the takaful Shariah controller was superseded by the 2023 takaful Shariah-governance standard. Others appear to survive as live legacy instruments, such as the 2014 financial regulations for takaful and the 2019 instructions for life and family takaful, whose status this series has flagged for primary confirmation. The rule that follows is the one the stack itself dictates: for any operational question, confirm on the rulebook whether the governing instrument is a current Central-Bank instrument or a surviving legacy one, and treat neither status as the default.
The law gives firms a year to align. All agencies and persons subject to the decree-law must reconcile their positions with its provisions within one year from its entry into force, which ran from 16 September 2025, and the Board of Directors may extend that period (Article 184). During the reconciliation window the preserved legacy instruments continue to apply, and firms are expected to bring their licensing, governance, prudential and conduct arrangements into line with the new law and the implementing instruments issued under it. For an insurer, the practical reading is that the general architecture is already in force, while the point at which any given legacy instrument is replaced by a Central-Bank-era one is the point at which that piece of the operational detail changes, and that timing is instrument-specific.
The migration of insurance supervision to the Central Bank is often stated as a single event, but for a firm reading the rulebook it is a live and uneven condition, and it produces a concrete discipline. Because the operational detail survives through the continuity chain, a legacy instrument can be current in force while citing a parent law that no longer exists: the 2022 takaful regulation and the 2023 takaful Shariah-governance standard, both in force, are drafted under the 2007 insurance law and the 2018 Central Bank law, both repealed. A reader who follows such an instrument’s internal cross-references to “the Law” can be led to a repealed statute while the instrument itself remains operative.
The rule, then, is not “use the current instrument and discard the legacy one,” because a legacy instrument may still be the current one for its subject. The rule is to confirm, for each instrument relied on, that it has not been replaced, and to read its cross-references to superseded parent laws as pointing to the consolidated 2025 law that now stands in their place. That is the field discipline this whole series applies, and the insurance stack is its clearest illustration: one consolidated statute on top, a chain of continuity beneath it, and a body of implementing detail that is being reissued piece by piece.
What is settled sits on the primary text. The governing statute is the consolidated 2025 decree-law, in force since 16 September 2025 (Articles 2 and, for entry into force, the instrument’s own commencement). Insurance is within its scope and its definitions, and insurers are Licensed Financial Institutions (Articles 1 and 2). The financial free zones are carved out (Article 2). The 2023 insurance law and the 2018 Central Bank law are repealed, the former confirmed as repealed on the Central Bank’s rulebook. And the implementing detail continues until replaced (Article 183), with a one-year reconciliation period from entry into force (Article 184).
What is open is the historical and peripheral detail, not the current position. The exact 2020 decree that merged the Insurance Authority into the Central Bank is unresolved on the sources seen. The repeal mechanics between the 2007 and 2023 insurance laws, and the precise wording of the 2025 law’s general repeal at Article 185, are held here on secondary sources pending confirmation against the primary text. And the onshore-versus-free-zone comparison is open pending the DFSA and FSRA modules. None of these unsettles the current governing position; each is flagged so it is not overstated.
What is moving is the implementing layer, instrument by instrument, as the Central Bank reissues Insurance-Authority-era decisions under the 2025 law. The single most useful thing to watch is the replacement of a legacy insurance or takaful instrument by a Central-Bank-era one, because that is the event that changes the operative detail for its subject and re-anchors the companion articles that rely on it. Until each such replacement issues, the surviving instrument governs, and the discipline is to confirm its status rather than assume it. This analysis rests on Federal Decree-Law No. 6 of 2025 as it stands on the Central Bank’s live rulebook and in force on the date of this article, and on the rulebook’s own record that the 2023 insurance law is repealed; the pre-2025 lineage and the free-zone interaction are flagged as secondary. Where the position turns on a specific implementing instrument, on the free-zone regimes, or on the merger decree, those instruments govern and are read in the pieces that follow.
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