Banking·8 min·Aug 2025

CBUAE's Open Finance Framework obligations for licensed regulated entities.

The Open Finance Framework is the most consequential CBUAE regulation of the decade. Licensed banks and finance companies underestimate the operational uplift required at their peril.

RP
Rajas Pingle
Partner · RPLC UAE
§01

The Central Bank of the UAE's Open Finance Framework, published under Circular No. 9/2024, does not simply extend Open Banking to a broader set of financial products — it recalibrates the operating model for every licensed financial institution in the country.

§02

The framework establishes a tiered licensing regime: Licensed Financial Institutions ('LFIs') as data holders, Third Party Providers ('TPPs') as data users, and a category of Trust Framework Participants ('TFPs') that operate the shared infrastructure. LFIs' central obligation is to expose defined data sets — accounts, transactions, product features, and, in later phases, insurance and investment holdings — through standardised APIs.

§03

The operational uplift is significant. LFIs must implement API infrastructure to specified performance and availability standards (target 99.5% uptime, sub-500ms response for account information calls), implement strong customer authentication under the framework's defined SCA standards, and maintain a customer-facing consent dashboard.

§04

Governance is where most LFIs are behind. The framework requires a designated Open Finance Officer at senior management level, a documented consent lifecycle policy, and quarterly reporting on API performance, complaints, and consent revocations. These are not IT deliverables — they are compliance obligations.

§05

The commercial opportunity is real. LFIs are permitted to become TPPs themselves, competing for data-driven propositions across the wider market. The institutions treating the framework purely as a compliance cost are already ceding ground to those treating it as a distribution channel.

Next in insights

Federal Decree-Law No. 45 of 2021: A practitioner's field guide to consent and legitimate interests.