New CBUAE SME Customer Protection Rules: What Changes for UAE Businesses from 13 September 2026

---

Effective date and transition

New regulation: SME Customer Protection Regulation (C 2/2026) Effective date: 13 September 2026 Applies to: CBUAE-licensed banks and finance companies in their dealings with SME customers, including relevant Islamic-finance activities

Transition note: The existing SME Market Conduct Regulation (C 1/2021) remains in force until 13 September 2026, when it is replaced by C 2/2026. Until that date, the current framework continues to apply. From 13 September 2026, C 2/2026 governs the covered conduct.

Primary source: CBUAE Rulebook — Small to Medium Sized Enterprises (SME) - Customer Protection Regulation

---

Confirmed regulatory requirements

The following requirements are drawn from the CBUAE Rulebook. They are stated here for awareness and preparation; they are not CFUAE interpretation.

| Area | What the regulation requires | |------|------------------------------| | Disclosure and transparency | Banks and finance companies must provide clear, timely, and material information to SME customers before and during the provision of financial products or services. | | Key Facts Statements | The institution must provide a Key Facts Statement before the product/service is provided, and the customer must acknowledge receipt before contracting. | | Pricing and fee transparency | Charges, fees, pricing bases, and changes must be clearly disclosed and explained. Changes to terms or fees require at least 60 calendar days' written notice before taking effect. | | Responsible financing | Financial Institutions must not provide Credit beyond amounts the Customer is capable of servicing, based on the Financial Institution's assessment of the Customer's ability to meet Credit obligations. | | Application and rejection handling | Where a facility is rejected, the institution must disclose the reason in writing, except where the reason relates to financial crime or disclosure is otherwise legally prohibited. | | Complaints and redress | Financial Institutions must provide complaint handling and redress pathways under governed procedures. After the institution's process completes, the final written response must inform the Customer of the process for escalation to an available external financial complaints-resolution function, including Sanadak, if the Complaint is not resolved to the Customer's satisfaction. | | Financial-difficulty support | Institutions must proactively assist when payment irregularities appear, maintain support mechanisms including restructuring, product modification, or adjusted payment plans, and provide impartial credit counselling. | | Customer-data protection | Financial Institutions must protect Customer Data and ensure confidentiality, collect only the minimum Customer Data/information needed for licensed activities, and comply with applicable laws/regulations. |

These requirements apply to CBUAE-licensed banks and finance companies. Islamic-finance activities within the defined scope are also covered.

---

Borrower good practice: what to request and document

The following steps help SME owners and finance managers work within the regulatory framework and maintain their own records. These are good-practice actions; they do not create additional legal rights beyond the regulation.

Before signing or renewing a facility

• Request and retain the Key Facts Statement provided.
• Confirm all fees, rates, and charges in writing, including conditions for variation.
• Verify whether Islamic-finance conditions apply and how they are disclosed.
• Compare the disclosed terms against your cash-flow and sensitivity assumptions before signing.

During the lending relationship

• Retain written notices of changes to terms and conditions, including Fees, and clarify their contractual/financial implications with the institution where needed.
• Document verbal representations in follow-up email.
• Keep a dated file for each facility including applications, approvals, amendments, and correspondence.

If an application is rejected

• Request a documented outcome.
• Retain the written reason provided by the Financial Institution, subject to the Financial Crime / legal-prohibition exceptions in Article 3.12.

If cash flow deteriorates

• Engage the lender early.
• Ask about hardship or restructuring pathways.
• Keep records of all communications.

Complaints and redress

• Use the lender's formal complaints process before considering external escalation.
• Keep copies of all correspondence.

---

CFUAE interpretation

The regulation creates a regulated baseline that SMEs can reference when comparing providers or escalating issues.

A practical governance discipline for CFOs and owners is maintaining complete financing records. Maintain:

• Signed disclosure documents and fee schedules
• Pricing/fee change notices
• Loan application submissions and lender correspondence
• Covenant-compliance evidence and cash-flow forecasts provided to lenders
• Collections, hardship, or restructuring communications

Good documentation supports internal governance and, if needed, external dispute resolution.

---

Sources & references

CFUAE uses primary regulatory sources and translates them into practical guidance. This article is educational and is not legal advice.

• CBUAE Rulebook: Small to Medium Sized Enterprises (SME) - Customer Protection Regulation (C 2/2026) — rulebook.centralbank.ae.
• CBUAE SME Market Conduct Regulation (C 1/2021) for the current framework in force until 13 September 2026.
• CFUAE SME finance guidance for contextual operating interpretation only.

The aim is to help SME owners and finance managers understand the regulatory environment, maintain clear financing records, and engage with regulated institutions from an informed position.