DFSA Category 4 License in DIFC: Activities, Capital and Fees

A DFSA Category 4 licence is the lightest prudential category for a financial services firm in the Dubai International Financial Centre (DIFC). It covers firms that advise and arrange but do not deal, lend or hold deposits. This page explains which services fall into Category 4 and what it costs in capital and fees, using the Dubai Financial Services Authority rulebook (PIB version 54, FER version 35, GEN version 72) and the DIFC Registrar’s table of fees (Rev. 16, 30 July 2026), read on 4 October 2026.

Which services are Category 4

Under PIB Rule 1.3.6, a firm is in Category 4 if its licence covers only one or more of these financial services and it does not meet the criteria of a higher category:

• Arranging deals in investments, and advising on financial products
• Arranging custody
• Insurance intermediation and insurance management
• Providing fund administration
• Providing trust services, where it is not acting as trustee of an express trust
• Providing money services, where it only provides money transmission
• Arranging credit and advising on credit
• Operating a crowdfunding platform
• Arranging or advising on money services

If the firm adds any other service, such as dealing as agent, managing assets or providing custody, it moves to a higher category with a higher capital requirement. A representative office is a separate regime, not a category.

Capital and insurance

The USD 30,000 base capital has applied since 1 January 2024; until then it was USD 10,000. Since 1 July 2025 operating an alternative trading system no longer sits in Category 4.

DFSA fees

• Several services: the application fee is the highest of the applicable fees, not the sum.
• Complex structure: a further 100% of the application fee if, for example, the group has several levels or members in two or more jurisdictions.
• Retail clients: an endorsement adds USD 20,000 to the application and USD 4,000 a year.
• First year: the annual fee equals the application fee, without the complex structure surcharge, pro rated by the whole months left in the year.
• Annual add-ons: USD 4,000 for each additional service on the licence, USD 1,000 for holding client assets, and an element based on expenditure.
• Late payment: USD 1,000 or 3% of the fee, whichever is greater, plus 1% a month.

DIFC fees on top

The firm is also a DIFC company. Under the Registrar’s table, a regulated non-retail private company pays USD 8,000 to register and USD 12,000 for its commercial licence, then USD 12,000 a year to renew and USD 300 for the yearly confirmation statement, plus AED 20 per transaction. A financial entity that processes personal data notifies the DIFC data protection commissioner for USD 1,250. On these published fees alone, a pure advisory firm pays USD 15,000 to the DFSA and USD 20,000 to DIFC before its licence, plus its pro rated first annual DFSA fee and its capital (our arithmetic).

People and office

• Required roles: a Senior Executive Officer, a Finance Officer, a Compliance Officer and a Money Laundering Reporting Officer.
• Residence: the SEO, Compliance Officer and MLRO must live in the UAE; the DFSA may waive this for the Compliance Officer and MLRO.
• Combining roles: the SEO cannot hold any of the other three roles and the Finance Officer cannot be Compliance Officer or MLRO, but one person can be both Compliance Officer and MLRO.
• Directors: all directors of a DIFC incorporated firm register with the DFSA as licensed directors.
• Office: the head office and registered office must be in DIFC, and the DFSA says it will not waive this.

How the application runs

The DFSA’s service page sets out five stages: an authorisation enquiry and meeting, an application through the DFSA ePortal, the DFSA’s evaluation, meeting the conditions in an in-principle letter, and final authorisation. For low-risk business models the regulatory business plan and the risk, AML and compliance policies can be self-certified. The DFSA gives no time; it says the time varies with the complexity of the application.

What is not published

• A processing time for a Category 4 licence.
• A minimum office size in DIFC.
• One total price; the cost is the sum of the separate DFSA and DIFC fees above.

For DIFC entity types and their fees outside financial services, see DIFC company setup; for holding structures, the DIFC Prescribed Company.