The Central Bank of UAE (CBUAE) has issued Circular 1/2025 on the Representation Offices of Foreign Insurance Companies and Foreign Reinsurance Companies Regulation (Rep Office Regulation). The Rep Office Regulation is dated 13 February 2025, but Article 20 states that it will come into effect on the date of its publication in the Gazette, and this has now been published in the UAE gazette, on 14 October 2025.
The Rep Office Regulation is very similar to the draft regulations that was issued by the CBUAE, and helpfully lists down the activities that a representative office is allowed to engage in, and those it is prohibited from. Like most other jurisdictions, the key theme of the Rep Office is to act as a legal set up of a foreign insurer or reinsurer in UAE for the purpose of carrying out market study of UAE and other activities that it is allowed to, but to refrain from any commercial activity.
Prohibited Activities
Following are a list of activities the Rep Office is prohibited from carrying out under the Rep Office Regulations:
- practicing insurance business within UAE;
- assuming, managing or bearing any insurance risk or any form of insurance underwriting;
- performing or participating in any other insurance activities, such as selling insurance products, collecting premiums or providing insurance consultations;
- performing activities of any of the Insurance – Related Professionals;
- being a partner or an agent of any other Representation Office;
- sharing, exchanging, disclosing or transmitting confidential information which the Representation Office is authorized to access pursuant to applicable laws and regulations, to any third party.
What next
The Rep Office Regulation sets out the requirements that apply in relation to the licensing of the Rep Office, and has some specific criteria’s, such as, for instance, the applicant entity must have completed a period of no less than 10 continuous years of conducting business in the home territory. License will be issued for a term of 1 year and must be renewed yearly.
For all entities who are currently licensed as Rep Office of Insurance/Reinsurance companies in UAE, the Rep Office Regulations provides a regularization period of 6 months from publication, i.e. 14 April 2026, until which they should fix their legal position, i.e. either license under the Rep Office Regulation or cease business, failing which they would be considered to be in breach.
How can Al Tamimi help?
Their team is happy to assist should you require any support with understanding the requirements under the Rep Office Regulations and any assistance you need on the licensing of new Rep Office or the closure of existing Rep Offices.
Key Contacts
Anand Singh, Senior Counsel, a.singh@tamimi.com
Veena Iyer, Paralegal, Insurance & Transport, V.Shankar@tamimi.com