Saudi Arabia Islamic finance governance

Shariah governance is additive to the SAMA or CMA legal route when a product or institution claims Shariah compliance.

Shariah governance map

SAMA's banking-side Shariah framework is live. CMA capital-market Shariah governance should be treated as draft or current authority dependent unless final instructions are verified.

Governance architecture

Banking-side rule: SAMA's Shariah Governance Framework for Local Banks Operating in Saudi Arabia is the live banking-side framework for banks conducting Shariah-compliant banking.
Capital-market status: CMA's draft Shariah-governance instructions should not be treated as a final public rulebook unless a final source is verified.
Product claim: A product marketed as Shariah-compliant needs documented Shariah basis, product-structure evidence, fee/reserve/asset review where relevant, and ongoing monitoring.
No substitution: Shariah governance does not replace SAMA payment licensing or CMA securities authorization.

When the Shariah layer applies

Scenario	Shariah governance	Consequence
Payment route through a conventional bank	No Shariah layer by default.	Use SAMA payment and banking controls unless Shariah compliance is claimed.
Route through a bank conducting Shariah-compliant banking	SAMA framework attaches.	Bank governance, committee, review, reporting, and disclosure controls.
Tokenized sukuk or Islamic note	CMA securities route plus Islamic-structure evidence.	Securities authorization and offer controls remain the legal base.
Product marketed as Shariah-compliant	Documented Shariah substantiation required.	Claims need governance records and ongoing monitoring.
CMI claiming Shariah compliance	CMA draft instructions are informative but current authority dependent.	Verify final status before treating as an enforceable rule.

Evidence and documentation requirements

For a bank route conducting Shariah-compliant banking, the evidence set should reflect the governance pillars in SAMA's framework: governance policy, committee structure, review, compliance function, audit interaction, reporting channels, corrective-action records, and disclosures.

For capital-markets products such as tokenized sukuk or Shariah-screened fund units, begin with the CMA legal-form route. Shariah review is additive to securities authorization, offer, custody, and market-infrastructure controls.

For products marketed as Shariah-compliant, retain the Shariah decision, product-structure paper, asset-eligibility analysis, fee-mechanics review, disclosure record, and monitoring evidence. Do not present a Shariah claim as a substitute for SAMA or CMA permission.