The Riffle
On 28 November 2025, the DFSA released an important communication outlining its supervisory agenda for 2026. With DIFC experiencing unprecedented growth across all financial sectors, Thematic Reviews are becoming one of the regulator’s most important tools for assessing risks, identifying weaknesses, and sharing good practices across the industry.
The DFSA has announced three major Thematic Reviews for 2026, focusing on Suitability, Fund Platforms, and Brokerage Oversight, each designed to examine governance, systems, controls, and operational practices at authorised firms. These reviews will include data analysis, surveys, information requests, and on-site visits.
Key Highlights
1. Suitability Review — Ensuring Appropriate Advice and Preventing Mis-Selling
The DFSA has positioned Suitability as a continuous priority, emphasising its importance in protecting clients and maintaining confidence in financial markets. Unsuitable advice can lead to significant client harm and reputational risks.
Stated Rationale
The DFSA explicitly notes that mis-selling and unsuitable advice can cause financial loss and undermine trust in the DIFC marketplace. The rapid evolution of financial products further increases the need for strong suitability frameworks.
Objectives
Assess the level of compliance across firms.
Identify sector-wide challenges and recurring weaknesses.
Key Areas of Assessment
Design of systems and controls
Whether the suitability framework is well constructed, logically structured, and aligned with DFSA rules.
Operation in practice
How effectively these systems are implemented day-to-day across advisory processes, documentation, and ongoing monitoring.
Supervisory Methodology
Analysis of existing regulatory data.
A targeted DFSA survey to relevant firms.
On-site inspections where necessary.
2. Fund Platform Review — Governance, Business Models, and High-Growth Risks
This review focuses on firms holding a Fund Platform Endorsement, reflecting the DFSA’s attention to innovation and rapid expansion within asset management ecosystems.
Stated Rationale
Fund platforms can vary widely in structure and strategy. Many operate with high-growth characteristics, making strong governance and risk management essential.
Objectives
Evaluate how firms have implemented and operationalized DFSA rules relating to fund platforms.
Assess whether systems and controls are adequate for the specific nature and scale of their business.
Key Areas of Assessment
Area | Focus |
|---|---|
Governance | Board and committee oversight, risk frameworks, quality of Management Information (MI). |
Business Models | Variations between platform models and associated commercial strategies. |
High-Growth Characteristics | Adequacy of financial resources, resilience of systems, staffing capacity, processes supporting expansion. |
Supervisory Methodology
Reliance on regulatory submissions such as the Periodic Fund Return.
Information requests and desk-based reviews.
On-site visits where required.
3. Brokerage Review — Oversight of the Trading Environment
Brokerage activity in the DIFC continues to expand, driven by new entrants and scaling firms. The DFSA’s 2026 focus is on controls that directly protect investors and preserve market integrity.
Stated Rationale
Effective oversight is “critically important” for orderly markets. Weaknesses in execution, monitoring, or governance can expose firms to regulatory risk.
Objectives
Conduct “deep-dive” engagement sessions across 2026.
Understand how firms maintain effective trading oversight frameworks.
Key Priority Areas of Assessment
Personal Account Dealing (COB 6.2)
Best Execution (COB 6.4)
Communication Channels & Record-Keeping (COB 6.7)
Explicit Exclusions
Market abuse controls and STOR reporting are not part of this review—but the DFSA strongly reiterates that market abuse prevention remains a key supervisory priority.
Supervisory Methodology
Review of existing DFSA data.
Focused survey to brokerage firms.
On-site visits where appropriate.
Conclusion & Next Steps
Following the completion of each thematic review, the DFSA will:
Publish Key Findings summarising observations and identifying areas for improvement.
Conduct Outreach Sessions to share examples of good practice with the wider industry.
Firms are encouraged to proactively assess their governance, systems, controls, and record-keeping in the three thematic areas ahead of DFSA engagement.
For queries or clarifications, firms should use the DFSA Supervised Firm Contact Form available on the DFSA ePortal.
Read the full briefing document presented by 10 Leaves here -
