A New Sheriff in Town: How will CMA impact the EOSB saving schemes market?

The UAE capital markets woke up to a new reality on January 1, 2026. The Securities and Commodities Authority (SCA)—the regulator that approved the first wave of End-of-Service Benefit (EOSB) fund managers back in 2024 — has been replaced by the Capital Market Authority (CMA). For the emerging EOSB savings scheme market, this isn't just a name change. It's a signal that the game has fundamentally changed.

A More Modern, More Powerful and Stronger Financial Regulator

When pioneers like Daman Investments, Lunate, National Bonds and FAB received their EOSB Fund Manager approvals, they were operating under SCA's watch — a regulatory framework that, while functional and workable, had remained largely unchanged since 2000. Now, under Federal Decree-Laws (FDL) No. 32 and 33 of 2025, these fund managers find themselves supervised by an authority with significantly expanded powers, sharper teeth, and a clear mandate to position UAE capital markets on the global stage.

For End of Service gratuity saving schemes providers, this evolution carries profound implications. The CMA's statutory objectives explicitly include "protecting the interests of investors"—and in the EOSB context, those investors are all UAE employees entrusting their future financial security to approved fund managers, once the new schemes will have become compulsory.

For instance, The CMA can now designate certain licensed entities as "Systemically Important Licensed Persons." While regulations are still forthcoming, EOSB fund managers handling billions in worker savings could plausibly fall into this category, triggering requirements for recovery plans, enhanced capital buffers, and intensified supervisory scrutiny.

Next, let’s look at the “stick” of the new CMA. Under the old regime, regulatory fines maxed out at modest levels. Today, the CMA can impose administrative fines up to AED 200 million, with criminal penalties reaching AED 250 million and mandatory imprisonment for serious violations. For EOSB fund managers and other market participants (such as advisers), this underscores a clear message: Compliance isn't just a suggestion — it's now anchored in law, and ignoring said law carries serious consequences.

Cross-Border Clarity

Let’s look at another important aspect of FDL No32 and No33: Who is in scope of the new rules? The new framework explicitly regulates anyone "targeting clients within the UAE" even from outside its borders. This matters as all providers who were based outside the UAE but targeting UAE clients are now clearly within scope of CMA regulation.

And yes, this includes also providers in the DIFC and ADGM. It is our understanding that e.g. fund managers and EOSB saving providers fall under this definition too. This means, in case DIFC-based providers wish to offer their plans and funds in the Mainland, they will have to adhere to CMA rules and obtain the necessary approvals first. At present the nature of such licensing and approval processes is not spelled out, however, we at GratuityAdviser believe the direction of travel is clear: CMA rules supreme for all financial matters on the UAE mainland.

A related interesting question is whether the “voluntary unofficial” EOSB funding schemes are in scope of the new CMA as well. For instance, there are several such schemes, e.g. MEWSS (operating in the RAKEZ freezone), or Praxis’ solution in the ADGM. We don’t know the answer to this question yet, but we speculate that the RAK Freezone may have to follow UAE labour law, and become subject to Mainland EOSB rules, ie being supervised by CMA in this respect too. ADGM on the other hand is a different case, as this freezone (alongside with DIFC) operate on a different legal basis compared to all other Freezones. (At present this is just our educated guess - please watch out for further GratuityAdviser articles on this evolving topic!).

2026: A Transition Year

All entities subject to the new laws have until January 1, 2027 to regularize their status—a one-year transition window. During this period, we can expect the CMA to issue implementing regulations clarifying licensing requirements, prudential standards, and disclosure obligations that will impact EOSB fund managers, EOSB advisers, and other market participants.

Whilst we are awaiting these further details, we can already confidently conclude that the shift from SCA to CMA isn't just cosmetic. It's a recalibration of accountability and ambition for UAE capital markets. For the EOSB savings scheme market — still in its infancy — this means growing up fast under a regulator that plays by global rules. Firms – both fund managers, custodians, fund administrators as well as consultants and advisers – that embrace this new reality will define the next chapter of workplace savings in the UAE.