DIFC Law No. 1 of 2025

The Riffle

The Dubai International Financial Centre (DIFC) has introduced DIFC Law No. 1 of 2025, amending several key legislations to strengthen its legal and regulatory framework. Enacted on 8 July 2025 and effective from 15 July 2025, the amendments cover the Data Protection Law 2020, Law of Security 2024, Insolvency Law 2019, and Employment Law 2019.

1. Data Protection Law – Stronger Rights, Clearer Rules

• Broader Scope: Now applies to all processing “in the DIFC” by controllers/processors, regardless of incorporation, if part of stable arrangements.

• Stricter Data Sharing Rules: Controllers/processors must verify the validity and proportionality of public authority requests, assess data subject risks, and obtain assurances before disclosure.

• Enhanced Commissioner Powers: Can initiate claims on behalf of data subjects and set up advisory committees.

• Private Right of Action: Data subjects can directly claim damages for breaches, including distress.

• Revised Fines: Certain penalties reduced (e.g., data sharing breaches lowered from $50,000 to $10,000).

2.  Law of Security – Modernised for Digital Assets

• Expanded Definitions: “Financial Collateral” now includes FCR Receivables; new “Collateral Taker” term replaces “Secured Creditor” in relevant contexts.

• Control & Priority Rules: Priority generally favours security rights effective by control over those by registration.

• Streamlined Enforcement: Collateral can be enforced without court approval, prior notice, or auction requirements, even during insolvency.

• Digital Asset Clarity: Default governing law for digital asset security rights set to England & Wales, unless DIFC specifies otherwise.

3. Insolvency Law – Minor Alignment

• Terminology Update: “Movable Asset” replaced with “asset” in the definition of security rights, broadening applicability.

4. Employment Law – Fairer Benefits for Nationals

• Top-Up Contributions: UAE and GCC nationals must receive pension and gratuity top-ups to match core benefits, if GPSSA contributions fall short, with a minimum threshold of AED 1,000 per month.

Impact:

These amendments reinforce DIFC’s position as a globally aligned financial hub. Data privacy protections are stronger, financial collateral rules are modernised for the digital era, and employee benefits for nationals are more equitable.

Read the briefing document by 10 Leaves here -