Al Tamimi & Company, in collaboration with Axxion Claims Settlement Services, has outlined the operational implications of the UAE’s consolidated Central Bank framework for motor claims, ahead of the September 2026 deadline for the reconciliation period established under Federal Decree-Law No. 6 of 2025.
Federal Decree-Law No. 6 of 2025, which came into force in September 2025, brought banking, financial institutions and insurance business under a single supervisory framework. Article 184 grants all entities and individuals subject to the law one year to reconcile their positions with its provisions, with the Central Bank’s Board of Directors retaining discretion to extend that period.
While the legislative instruments are already well known across the market, Al Tamimi & Company and Axxion have focused on a narrower question: how these requirements apply in practice to the handling of individual claims, where compliance obligations arise in day-to-day operations, and what changes are required within claims processes rather than policy documentation.
“This framework follows the direction global insurance supervision has been moving for years and brings the UAE into line with the standards established by the International Association of Insurance Supervisors,” said Anand Singh, Legal Director and Head of Insurance, GCC, at Al Tamimi & Company. “The sanction ceilings ensure that the requirements are taken seriously, while the regulator’s focus remains on firms meeting them. Where businesses have undertaken gap analyses and remediation is under way, that progress carries significant weight, even where some gaps remain.”
The framework establishes governance obligations at board level under Article 130, brings insurance-related professions including third-party administrators and loss adjusters within the licensing perimeter under Article 61(1)(j), and applies <a href="https://jordangazette.com/gold-edges-higher-on-middle-east-tensions-u-s-economic-data-in-focus/”>data provision and disclosure obligations directly to those professions under Articles 90 and 91. Article 168 sets out twenty-one administrative sanctions, including fines of up to AED 1 billion for licensed financial institutions and AED 5 million for authorised individuals.
Three additional legislative and regulatory instruments intersect with the same claims process. Federal Decree-Law No. 25 of 2025, which introduced the new Civil Code and came into effect on 1 June 2026, restates the insurance contract provisions that have governed UAE claims handling since 1985, while strengthening statutory requirements relating to disclosure and indemnity. Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data grants claimants rights of access to personal data contained within claims files, including information underpinning claims decisions. In February 2026, the Central Bank also issued its Guidance Note on the Responsible Adoption of Artificial Intelligence and Machine Learning by Licensed Financial Institutions, introducing five key principles centered on transparency, explainability and effective human oversight.
“An insurer that places a function with a third party retains accountability for how that function performs,” said Singh. “Due diligence, service levels, data flows and audit trails remain matters for the insurer’s board. At the same time, the appointment of a loss adjuster licensed by the Central Bank sits outside the outsourcing provisions, while the engagement of an unlicensed third party falls within them. Understanding where those distinctions apply is essential.”
From an operational perspective, the framework requires claims records to be created and maintained in real time, ensuring that decisions, supporting evidence and timelines are documented as events occur. Beyond compliance, this discipline supports improved underwriting, fraud detection and stronger data quality across the market.
“The framework is understood at the level of principle, and the operational reach is where it gets interesting,” said Frederik Bisbjerg, Managing Director and Co-founder of Axxion. “This is not a policy exercise that ends with a board paper. It reaches the moment a handler decides an estimate is too high, the moment a rejection letter is drafted and the moment a file is closed. Those moments are where the framework will be tested, and they happen thousands of times a month across this market.”
“Four instruments converge on one process, and that is the part worth planning around,” added Bisbjerg. “A rejection has to connect to the peril that caused the loss, the file behind it has to be disclosable to the person it describes, and any automated step in the decision has to be explainable. Read separately, they look like four compliance projects. Operationally, they are one and approaching them as one is what makes the timeline manageable.”
