In Brief:
- The convergence of finance and social media has given rise to a new category of actors within global investment landscapes: Finfluencers - a group that has discovered a receptive environment in the United Arab Emirates.
- The UAE Securities and Commodities Authority (SCA) has issued Resolution No. 10 of 2025, introducing a formal licensing regime for Finfluencers operating from the Mainland.
- DIFC and other financial free zone entities are not directly subject to the Resolution, but must still ensure compliance with overlapping DFSA financial promotion and conduct rules.
The convergence of finance and social media has given rise to a new category of actors within global investment landscapes: 'Finfluencers' – a group that has discovered a receptive environment in the United Arab Emirates (“UAE”). With a growing number of individuals offering bite-sized investment advice, portfolio picks and virtual asset recommendations to eager followers on public platforms, regulators have been quick to acknowledge the potential risks and benefits posed by this cohort.
On 20 May 2025, the UAE Securities and Commodities Authority (“SCA”) issued the Chairman Resolution No. 10 of 2025 (“Resolution”), introducing a regime regulating natural persons who provide financial recommendations via social media (“Finfluencers”), which took immediate effect the following day. While the law primarily applies to the UAE Mainland (“Mainland”), the implications for entities operating from or into the Dubai International Financial Centre (“DIFC”) and other financial free zones are also significant.
The scope of the Resolution is intentionally comprehensive, extending regulatory oversight to a broad spectrum of activity capable of influencing retail investor behaviour. In particular, it governs both outbound and inbound financial content disseminated from the Mainland, including the following:
- any natural person within the Mainland providing financial recommendations to the public, whether such recommendations relate to issuers or financial products located in the UAE or abroad;
- any natural person within the UAE providing recommendations on financial products, virtual assets, or any services regulated by SCA; and
- issuers and SCA-licensed entities that engage or contract with Finfluencers for promotional purposes.
However, the Resolution expressly excludes:
- financial recommendations that republish information already approved by the SCA or a licensed market;
- licensed financial consultancy firms and analysts acting within their authorised scope under the Financial Activities Rulebook; and
- individuals providing financial recommendations from within a UAE financial free zone (e.g. DIFC or Abu Dhabi Global Market).
These exclusions require narrow interpretation, as content generated outside the SCA’s direct jurisdiction may still reach and influence retail audiences within the Mainland.
Under the SCA framework, a Finfluencer is any natural person registered with the Authority to provide financial recommendations through a public medium. These may concern the purchase, sale, or retention of financial products, virtual assets, or services, whether in the UAE or abroad. The Resolution applies across a broad range of channels, including TikTok, Instagram, blogs, and in-person seminars.
While DIFC-based individuals fall outside the scope of the SCA’s Resolution, this does not mean the Dubai Financial Services Authority (“DFSA”) adopts a laissez-faire approach. The DFSA maintains a parallel regime within the DIFC, which captures financial promotions, investment advice, and marketing activity directed at DIFC clients. Any individual or firm offering such content must comply with the DFSA Rulebook, including the General Module, the Conduct of Business Module, and the Financial Promotions regime.
Where DIFC-regulated firms engage external content creators or key opinion leaders, these arrangements should be reviewed to ensure compliance with both DFSA and UAE federal standards.
Individuals operating from within the DIFC who issue financial promotions generally require DFSA authorisation unless a specific exemption applies. The DFSA defines financial promotion broadly, and unauthorised persons promoting financial products or services to DIFC-based audiences risk breaching regulations. DIFC firms (or individuals) promoting content to Mainland residents may trigger SCA compliance obligations.
For individuals operating from within the Mainland, a separate set of obligations apply under the Resolution. Although the SCA is waiving registration and renewal fees for the first three years, this incentive does not reduce the underlying compliance burden.
To operate lawfully under SCA jurisdiction, Finfluencers must:
- register with the SCA;
- meet minimum qualification thresholds, such as being a Certified Financial Analyst or having demonstrated experience and influence in financial commentary; and
- disclose professional experience, any conflict of interest, and affiliations with licensed entities.
The SCA is expected to monitor compliance through public content reviews, whistle-blower reports, and cooperation with platform providers. Where non-compliance is identified, enforcement measures may include administrative fines, deregistration, or referral to the relevant authorities.
The framework also imposes strict content and disclosure obligations. Finfluencers must clearly distinguish between fact and opinion, ensure that all data is current and properly sourced, and include appropriate disclaimers, such as noting that past performance is not indicative of future results. Any form of compensation or affiliation with issuers or licensed entities requires disclosure, including where a Finfluencer is paid to promote a virtual asset, republishes or modifies another party’s recommendation.
While the SCA Resolution expressly excludes financial free zones such as the DIFC and ADGM, the regulatory expectation remains clear: financial advice should only be provided by an individual or entity that is licensed and subject to regulatory supervision.
DIFC-licensed entities working with Finfluencers should assess whether the individual is making a financial promotion as defined under DFSA rules. In many cases, this could give rise to licensing, approval, or conduct obligations for both parties. Depending on the nature of the content, the DFSA’s Code of Market Conduct and Anti-Money Laundering Rulebook may also apply.
Although the SCA Resolution regulates individuals, financial services firms may be held responsible where they engage or promote Finfluencers who are not compliant. Accordingly, DIFC, ADGM or Mainland firms should:
- ensure the individual is duly registered (if SCA rules apply);
- review and approve all content before dissemination; and
- maintain internal records and disclosures.
These requirements reflect a unified regulatory approach that prioritises consumer protection and market integrity across both onshore and offshore environments.
The regulation of Finfluencers marks a pivotal shift in the UAE’s regulatory landscape and aligns the jurisdiction with other global regulatory leaders such as Australia, Hong Kong, and the United Kingdom. As other Gulf jurisdictions assess the intersection of digital influence and financial advice, the UAE’s framework is likely to serve as a regional benchmark for future regulation.
Through this Resolution, the SCA has introduced a meaningful barrier to entry for natural persons, reinforcing its commitment to retail investor protection through proactive oversight while acknowledging the persuasive role of digital voices in financial markets. By addressing both intentional and inadvertent non-compliance, the regime seeks to ensure market integrity while safeguarding retail investors in an evolving digital landscape.
Our lawyers at Hadef & Partners regularly advise on regulatory structuring, licensing, and compliance across the digital asset and financial services sectors. Whether navigating SCA registration for Finfluencers or advising on DFSA authorised promotions, our team brings a practical, solutions-oriented approach to managing risk and capturing opportunity. We act for financial institutions, digital creators, and virtual asset platforms across all stages of market entry and ongoing governance.
To discuss how Hadef & Partners can support your regulatory licensing or compliance strategy, please contact Bilal Snaineh, Partner, Corporate and M&A, at b.snaineh@hadefpartners.com.