DFSA Rulebook Amendments of October 2026: What Changed and Who It Affects

On 1 October 2026 the DFSA published a Notice of Amendments to Legislation recording four rule-making instruments. One changed the prudential reporting matrix the next day. The other three, covering conduct of business, the Islamic Finance Rules and the Glossary, start on 1 January 2027.

We have read the four appendices with their markup, where underlining shows new text and strike-through shows deletions. The notice warns that the final rules may differ from Consultation Papers 172 and 174, so earlier commentary on those papers needs checking against the appendices.

The four instruments and their dates

The PIB change came out of CP 174 on miscellaneous changes, released on 9 July 2026. The Islamic finance and Takaful changes come from CP 172, launched on 5 May 2026. Consolidated modules sit in the DFSA Rulebook once each change commences.

PIB: the reporting matrix, already in force

Appendix 1 amends Table 1 in PIB A2.4, the Authorised Firm Reporting Matrix, which lists the prudential forms each Authorised Firm category files.

Form B110 is renamed from Capital Ratios to Capital Resources and Capital Requirements, and it now applies to all categories rather than only Categories 1, 2, 3A and 5. Form B120 Capital Resources is deleted, which suggests the two have been folded together. Category 3A is removed from B130D Settlement Risk and B140H Credit Valuation Adjustment, which now cover Categories 1, 2 and 5. Form B180 Expenditure Based Capital Minimum is deleted from the matrix. Two forms are added: B290 Non-Bank Liquidity Requirements, quarterly and annually, for Categories 3A, 3B, 3C, 3D and 4; and B400 Safeguarded Assets, quarterly and annually, for all categories and, unusually, for Branches as well as Domestic Firms.

For a Category 3C fund manager, then, the practical effect is a different set of returns: B110 now, B290 instead of B180, and B400. The appendix changes no capital figure, and we would not read the deletion of the B180 row as removing the expenditure based capital minimum itself. If that matters to you, ask the DFSA.

Islamic endorsement: when a firm is holding itself out

This is the change most likely to catch firms that do not think of themselves as Islamic businesses. Article 9 of the Law Regulating Islamic Financial Business 2004 bars an Authorised Person from holding itself out as conducting Islamic Financial Business unless its Licence carries an endorsement, either as an Islamic Financial Institution or for an Islamic Window. From 1 January 2027, new IFR Rule 1.1.1(2) spells out when that holding out happens. It covers a firm that presents the whole or part of its operations as conducted in accordance with Shari'a, one that provides a Financial Service on a product it holds out as Islamic or Shari'a compliant, and a Fund Manager that manages a Fund it holds out that way.

The new guidance is practical. Describing services as "Shari'a compliant, Islamic or halal" in marketing counts, as does giving opinions on whether a product complies. Distributing a product that someone else markets as Islamic does not, unless the firm produced or approved that material, and nor does listing an instrument by its market name, such as sukuk. The DFSA will look at substance over form.

Chapters 3 and 4 of IFR (general obligations, accounting and audit) are re-pointed to an Authorised Person that is an Islamic Financial Institution or operates an Islamic Window, and Rule 3.3.1(1) on Shari'a systems and controls now says Authorised Person rather than Authorised Firm, so it reaches Authorised Market Institutions too.

The test we would apply: read your website, pitch books and fund documents as the DFSA would. If any of them call a product or service Islamic, and the Licence has no endorsement, that needs resolving before January, either by changing the wording or by applying under Article 11 of the 2004 Law. Our guide to Shari'a-compliant wealth structures in DIFC and ADGM covers the structuring side.

Takaful disclosure moves to COB

The Takaful disclosure duty currently sits in IFR chapter 8, which applies to firms carrying on Takaful as Islamic business. Instrument 445 deletes IFR Rules 8.1.1 and 8.2.1, and Instrument 444 reinstates the same four disclosure items as COB Rule 7.7.4. Any Insurer or Insurance Intermediary proposing Takaful to a Retail Client must explain the nature of the contracts between the Takaful fund and the operator, how any fees or profit shares paid to the operator are calculated, how surpluses are shared, and when additional contributions may be required. New IFR guidance confirms this applies whether or not the firm holds itself out as conducting Islamic Financial Business. A conventional broker that places Takaful for retail clients is therefore in scope.

The Glossary instrument adds a definition of Takaful: a Contract of Insurance under which the parties agree to support one another jointly for specified losses from a fund to which all commit to donate, drawn up to allow the parties to comply with Shari'a.

Credit Rating Agencies

Appendix 2 also revises COB chapter 8. The employee conflict test in Rule 8.6.3(2) now catches a relationship with any individual employed by the Rating Subject or its Related Party, fee arrangement disclosure under Rule 8.8.2 moves to the annual report, and Rule 8.8.3 on structured finance information is deleted. The 12 hours' notice guidance now adds an expectation that the agency consider whether more time is needed.

Who is not affected

A non-regulated DIFC company, a Prescribed Company or a DIFC foundation is not an Authorised Person. It files no prudential returns and needs no Islamic endorsement, so these instruments do not apply to it directly. Prescribed Companies have their own change to plan for, set out in our note on the Prescribed Company corporate service provider deadline.

Groups are different. Where a holding structure sits above a DFSA-authorised fund manager or insurance intermediary, the group board should know the regulated entity has dealt with these changes. If that group also operates in ADGM, remember that DFSA authorisation does not carry across to ADGM, so the FSRA position needs its own review. For fund groups, our pieces on the 2026 DIFC fund regulations and setting up a fund management company in the DIFC give the background.

What we would do before 1 January 2027

1. Ask the finance team to map the firm's category against the revised matrix, and to confirm with the DFSA which reporting period the new forms, including B290 and B400, first apply to.
2. Have the compliance officer read Appendices 2 and 3 with the markup and note which rules apply to the firm.
3. Review marketing, websites and offering documents for words such as Islamic, halal or Shari'a compliant, and compare the result with the endorsement on the Licence.
4. If the firm sells Takaful to retail clients, update the disclosure documents to the four COB 7.7.4 items.
5. Report the review to the board and minute it, then add 1 January 2027 to the group calendar alongside the items in our Q4 2026 compliance calendar.

How Atlas helps

We are a DFSA-registered corporate service provider, not an authorised firm, so we do not advise on the Rulebook or prepare prudential returns. Where we are useful is the corporate housekeeping around a regulated entity: keeping registers and constitutional documents current, drafting resolutions, and running board meetings and minutes through our company secretarial and governance service. For fund structures we support the holding entities and SPVs through our fund and SPV support. If your compliance review needs to be recorded properly at board level, we can help with that part.

This article is general information and does not constitute legal, tax or regulatory advice. It summarises a DFSA notice and its appendices, and the Rulebook text governs. Confirm the position for your firm with its compliance officer or a qualified regulatory adviser before acting.