The Central Bank of the United Arab Emirates (CBUAE) has formally published Circular No. 1/2025, introducing the Representation Offices of Foreign Insurance Companies and Foreign Reinsurance Companies Regulation (“Rep Office Regulation”). Although originally dated 13 February 2025, the regulation took effect following its publication in the UAE Official Gazette on 14 October 2025.

This new framework provides a clear and structured regime for representative offices of foreign insurers and reinsurers operating in the UAE, defining their permissible scope of activity while maintaining strict prohibitions against commercial engagement.

Purpose and Scope

The Rep Office Regulation aligns with global best practices by allowing foreign insurers and reinsurers to establish a non-commercial presence in the UAE. These offices serve primarily as market intelligence and liaison points — facilitating research, business connections, and representation — rather than as vehicles for conducting regulated insurance activities.

This approach reinforces the UAE’s commitment to international regulatory standards while ensuring that market entry remains transparent, structured, and compliant with CBUAE oversight.

Prohibited Activities

To preserve the distinction between representative offices and licensed insurers or intermediaries, the regulation explicitly prohibits several activities. A representative office may not:

• Engage in or practice insurance business within the UAE.
• Assume, manage, or bear any insurance risk, or undertake underwriting.
• Sell insurance products, collect premiums, or offer insurance consultancy.
• Conduct the work of insurance-related professions, such as brokers, loss adjusters, or actuaries.
• Partner with or act as an agent for another representative office.
• Share or transmit confidential information obtained through its permitted activities to third parties, except as authorised under applicable laws.

The emphasis is clear: representative offices exist for representation, not revenue generation.

Licensing and Ongoing Obligations

The new regime introduces several key criteria for licensing:

• The applicant must demonstrate at least ten continuous years of business operation in its home jurisdiction.

• Licences are valid for one year and must be renewed annually.

• Licensed entities are required to maintain transparent governance, adhere to CBUAE reporting obligations, and ensure local operations remain within the permitted scope.

These measures are designed to ensure that only established, credible international insurers and reinsurers can secure a representative presence in the UAE.

Transition Period

Entities currently operating as representative offices under earlier frameworks are granted a six-month regularisation period ending 14 April 2026. By this date, they must either obtain a licence under the new regulation or cease operations. Failure to do so will be treated as a breach of the regulation, subject to CBUAE enforcement action.

Regulatory Implications

The Rep Office Regulation marks another step in the UAE’s broader financial services modernisation agenda. By distinguishing representational from commercial activities and formalising licensing standards, it reduces regulatory ambiguity and aligns UAE insurance oversight with global norms.

This move is also expected to enhance market confidence among foreign insurers considering strategic expansion, offering a structured pathway for early-stage market engagement before seeking full licensing.

How Can We Help?

The CBUAE’s new framework reflects the UAE’s continued drive to strengthen governance and oversight in its financial sector. Understanding these requirements, particularly the boundaries between representational and regulated activities, is critical for compliance and long-term planning.

Quwa Legal’s insurance and financial regulatory team can assist in reviewing your existing UAE operations, assessing eligibility under the new framework, and preparing the necessary documentation for compliance within the regularisation window.