Starting September 13, 2026, new small and medium business protection rules are in effect in the UAE, the SME Customer Protection Regulation (Circular C 2/2026), approved by the Central Bank of the UAE (CBUAE).
The new regulation establishes additional requirements for banks and financial companies regarding the servicing of SME clients. Among other things, it defines the rules for opening bank accounts, application review timelines, document requirements, and the procedure for handling complaints.
For companies planning to open a corporate account in the UAE, the most practical change is the introduction of a specific timeframe for opening an account under certain conditions.
What has changed in opening an account in the UAE?
Under the new regulation, a financial institution must have procedures in place to ensure that a bank account is opened within 3 business days if:
the applicant's profile is assessed as low risk for money laundering and terrorist financing;
the bank is satisfied with the standard Customer Due Diligence (CDD) document package;
the client has provided all documents and information required to open the account.
The three business days are counted from the day the request is submitted and all necessary documents and information are provided.
Important: 3 business days does not mean that every company in the UAE will receive a corporate account within three days.
The regulation explicitly provides that the obligation to meet the three-day timeframe does not apply if the financial institution is acting in accordance with UAE Financial Crime Compliance requirements. The reason for applying such an exception must be properly documented and reported to the financial institution's management.
That's why KYC, AML, sanctions screening, and risk assessment remain an important part of opening a corporate account in the UAE.
Who is considered an SME under CBUAE rules?
For the purposes of C 2/2026, an SME is a micro, small, or medium-sized enterprise in the UAE that meets established criteria for number of employees and annual revenue.
The criteria differ depending on the sector of activity: trade, manufacturing, or services. They are defined in Article 1 of the new regulation with reference to Cabinet Resolution No. 22 of 2016.
Category | Trade | Manufacturing | Services |
|---|---|---|---|
Micro | ≤5 employees or ≤ AED 3 million | ≤9 or ≤ AED 3 million | ≤5 or ≤ AED 2 million |
Small | 6-50 or ≤ AED 50 million | 10-100 or ≤ AED 50 million | 6-50 or ≤ AED 20 million |
Medium | 51-200 or ≤ AED 250 million | 101-250 or ≤ AED 250 million | 51-200 or ≤ AED 200 million |
The criteria are given in accordance with the definition of SME in C 2/2026. To determine a specific business category, the criteria established by UAE legislation must be taken into account.
What documents can a bank require?
The new rules require that a financial institution have clear, transparent, and consistent requirements for the minimum document package needed to open an account and for further due diligence.
That said, the specific document package depends on the bank and the company's profile.
In practice, opening a corporate account in the UAE may require documents and information regarding:
company registration and structure;
directors and ultimate beneficial owners;
the nature and geography of business activity;
sources of funds;
expected turnover;
counterparties;
contracts and invoices;
the business model and future transactions.
For international business, it's important that these documents don't contradict each other and together form a clear picture of the company's activity.
What happens if the bank doesn't manage to open the account in time?
The regulation provides a separate procedure for situations where an application has already been accepted, but there are reasonable circumstances requiring additional time.
In such a case, the financial institution must explain the reason for the delay to the client and document it.
For a client with low AML/TF risk, in certain cases an account may be opened with temporary restrictions on transactions. Such a delay must not exceed 2 weeks.
This is an important clarification: opening an account and being able to carry out all transactions through it are not always the same thing.
CBUAE separately notes that opening a bank account does not mean automatic authorization to carry out any transactions until the necessary checks are completed, including Financial Crime Compliance and sanctions screening.
Can a bank refuse to open a corporate account?
The new regulation does not abolish banks' risk-based approach.
A financial institution continues to assess a client in accordance with anti-money laundering and counter-terrorist financing requirements.
Therefore, having a complete document package doesn't automatically mean a positive decision.
The following can be of particular significance to a bank:
company activity → ownership structure → geography of operations → counterparties → source of funds → expected transactions → overall risk profile.
That's why preparing to open a corporate account in the UAE involves not only gathering registration documents, but also preparing a clear justification of the business model.
New timelines for handling SME complaints
C 2/2026 also establishes specific requirements for how financial institutions handle complaints from SME clients.
A bank or financial company must:
confirm receipt of a complaint in writing within 2 business days;
provide the client with a unique reference number;
provide a final written response within 30 business days;
state the detailed reasons for the decision in the response.
At the same time, the reason for refusal may not be disclosed if disclosure is related to Financial Crime Compliance requirements or prohibited by law. The regulation also provides for information about the possibility of further recourse to an external financial complaints resolution mechanism, in particular the Ombudsman Unit (Sanadak).
What does this mean for foreign business?
For companies with foreign owners, the new rules don't eliminate standard banking checks.
If a company plans to open a bank account in the UAE, it's important to prepare in advance:
corporate documents;
information about UBOs and directors;
a description of business activity;
confirmation of source of funds;
contracts with counterparties;
information about expected turnover and transactions;
documents confirming the reality of the business.
The more clearly a bank can assess a company's activity and future operations, the easier it is to pass the KYC procedure within the bank's established requirements.
What has actually changed since September 13, 2026?
The new SME Customer Protection Regulation C 2/2026 does not introduce a rule that "any business will get an account in 3 days."
Its practical significance is different: for qualifying SME clients, more specific rules have been established regarding account opening timelines, documentation requirements, communication with the financial institution, and complaint handling.
For companies planning to open a corporate account in the UAE, this means that preparing a complete and logical KYC package is becoming even more important.
Opening a corporate account in the UAE with Maira Consult
Maira Consult supports the opening of corporate accounts in the UAE and helps prepare a company for bank KYC.
We analyze the company's profile, ownership structure, and activity, help put together the document package, and support communication with the financial institution.
The decision on opening an account and the final assessment of the client always remain with the bank, in accordance with its internal procedures and compliance requirements.
