DFSA's January 2026 crypto rewrite gives firms the token gate and keeps payment-token issuance federal

The January 2026 DFSA package is already in force. It amended GEN, COB, CIR, FER, AMI, MKT and GLO, removed the recognised-token list for non-fiat Crypto Tokens, and shifted suitability to firms under GEN 3A.2.1 and 3A.2.1A.

The January 2026 DFSA package is already in force. It amended GEN, COB, CIR, FER, AMI, MKT and GLO, removed the recognised-token list for non-fiat Crypto Tokens, and shifted suitability to firms under GEN 3A.2.1 and 3A.2.1A.

Stablecoins were not pushed out of DIFC supervision. Fiat Crypto Tokens remain directly assessed by the DFSA under GEN 3A.2.1(2)(b) and the Policy Statement on Fiat Crypto Tokens, whose current annex lists EURC, USDC and RLUSD.

Custody did not become lighter. COB 15.4, COB 14.3, COB 6.13/App 6 and COB 15.7/15.8 still require segregation, key-security controls, client disclosures, quarterly incident reporting and annual independent technology audit. The sharper boundary is federal. The CBUAE Payment Token Services Regulation expressly licenses payment-token issuance, conversion, and custody/transfer across the UAE and for activity directed to UAE persons, including Financial Free Zone persons in the foreign-issuer registration limb.

DIFC no longer relies on a DFSA-maintained recognised-token list for non-fiat crypto tokens. Firms now assess suitability themselves, fiat stablecoins remain on a separate DFSA gate, and payment-token issuance, conversion and custody-transfer sit with CBUAE.