By 2026, many regulated firms in the UAE will find themselves navigating two regulatory realities at the same time. On one side sit expanding global cyber and operational resilience regimes, such as EU NIS2 and DORA. On the other sit increasingly assertive local enforcement expectations from UAE regulators, including the DFSA, FSRA and federal authorities.
The challenge is not choosing between them. It is managing where they collide.
Global rules are raising the floor, not replacing local oversight
International frameworks such as NIS2 and DORA introduce prescriptive requirements around incident reporting timelines, third-party oversight, resilience testing and senior accountability. For firms with European parents, clients or operations, these obligations apply regardless of where systems are hosted.
However, UAE regulators do not defer to global rules. DFSA and FSRA expect firms to meet local supervisory standards in full, even where global policies already exist. In practice, this means global frameworks raise expectations, but local enforcement defines acceptability.
Firms relying solely on group-level policies often discover gaps during audits, particularly where regional operating models, outsourcing arrangements or data flows differ from European assumptions.
Where collisions typically occur
Several pressure points appear repeatedly.
Incident reporting is one. Global rules impose strict timelines and detailed disclosure requirements. UAE regulators focus on clarity, accuracy and governance of escalation. Firms struggle when reporting lines are unclear or when regional teams lack authority to act quickly.
Outsourcing and third-party risk is another. Global frameworks demand strong oversight, but UAE regulators often expect more granular evidence of local control, especially where service providers operate outside the region.
Operational resilience creates further tension. Global programmes may define impact tolerances at group level. Local regulators expect these tolerances to reflect the realities of UAE operations, clients and market dependencies.
Enforcement is becoming more practical
One notable shift in the UAE is the move from principle-based discussion to evidence-led enforcement. Regulators increasingly test whether firms can demonstrate alignment between policy, practice and decision-making.
This places pressure on organisations to:
- translate global requirements into local operating procedures,
- clarify accountability between group and regional management,
- and ensure local teams can evidence compliance without relying on head office interpretation.
What firms should focus on in 2026
Success in this environment depends less on adopting new frameworks and more on integration.
Firms should be able to explain how global cyber and resilience obligations are reflected in local governance, how incidents are managed in practice, and who holds decision-making authority in the UAE.
Regulators are not opposed to global consistency. They expect it to work locally.
In 2026, the firms that perform best are those that treat global rules as a baseline and UAE enforcement as the decisive test.
