Guide
DFSA and FSRA licence categories compared
Updated
The category numbers look the same across the two zones. The activities inside them are not, and assuming otherwise is the most expensive mistake in this comparison.
How the categories are defined
The DFSA's definitions sit in PIB 1.3 of its rulebook and the FSRA's in PRU 1.3 of its own. Both work the same way: a firm is in a category if its licence or financial services permission authorises it to carry on one of the listed activities and it does not meet the criteria of a higher category. The order matters, so a firm doing several things lands in the heaviest category that applies.
| Category | DFSA, DIFC | FSRA, ADGM |
|---|---|---|
| 1 | Accepting deposits or managing an unrestricted PSIA | Accepting deposits or managing an unrestricted PSIA |
| 2 | Providing credit or dealing in investments as principal | Providing credit or dealing as principal, but not as matched principal |
| 3A | Dealing as agent, or operating an alternative trading system | Dealing as matched principal, or dealing as agent |
| 3B | Custody for a fund or of crypto assets, fund trustee, employee money purchase schemes | Custody for a public fund and related activities |
| 3C | Managing assets, managing a fund, custody other than for a fund, trust services, issuing stored value | Managing assets, managing a fund, custody other than for a public fund, trust services, money services, issuing a fiat-referenced token |
| 3D | A DFSA-only category | No equivalent |
| 4 | Arranging, advising, arranging custody, insurance intermediation, insurance management, fund administration, crowdfunding, money transmission | Arranging, advising, arranging custody, insurance intermediation, insurance management, fund administration, operating a multilateral or organised trading facility, private financing platforms |
| 5 | Islamic financial institution managing an unrestricted PSIA | Islamic financial institution managing an unrestricted PSIA |
Three differences that actually change the answer
- Matched principal dealing. The DFSA keeps it in Category 2 with a reduced US$500,000 floor. The FSRA moves it to Category 3A. Same business, different category, different rulebook chapter.
- Trading facilities. Operating a multilateral or organised trading facility is Category 4 for the FSRA. The DFSA puts operating an alternative trading system in Category 3A.
- Digital assets. The DFSA handles crypto custody in Category 3B. The FSRA handles issuing a fiat-referenced token in Category 3C with its own US$2 million floor.
Base capital is a floor, not the requirement
Both regimes require the firm to hold Common Equity Tier 1 capital of at least its base capital requirement at authorisation and at all times thereafter, and then require more where the firm's expenditure or risk profile demands it. The DFSA's expenditure based capital minimum and the FSRA's equivalent routinely produce a higher number than base capital for a real business with staff and premises.
Category definitions in both rulebooks are amended regularly. Read the current rule text at DFSA PIB 1.3 and FSRA PRU 1.3 rather than relying on a summary.