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.
Question 1
What will the business actually do?
Pick the closest description. If several apply, pick the one that would need the heaviest permission.
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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 one of the listed activities and it does not meet a higher category's criteria. 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 Common Equity Tier 1 capital of at least the base capital requirement, at authorisation and at all times after. They require more where expenditure or risk demands it. For a real business with staff and premises, the DFSA's expenditure based capital minimum and the FSRA's equivalent routinely exceed base capital.
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.