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Research  ·  Financial services

The customer asks why. Can you answer?

What we are watching in this sector, and the research that touches it. This is the research view; the services view is on the industry page.

SECTOR VIEWUPDATED 26 AUGUST 2026RESEARCH ONLY
What we are watching

Three questions we put to every estate in this sector.

01

Explaining one decision, months later

Whether a specific adverse decision can be explained to a specific customer, months later.

02

An inventory that answers two control sets

Whether the AI inventory was built to answer a cybersecurity control set as well as an AI framework.

03

Tested on your population, or someone else’s

Whether the model was tested on your own population or on somebody else’s benchmark.

Obligations in force

What is already due, and what is coming.

Every obligation below is dated, named and externally imposed. Read them against what your organisation could evidence this week rather than against what it intends to build.

IN FORCECBUAE

Fraud-liability transfer for entities retaining OTP-based authentication (since July 2025)

Migration off OTP; 24/7/365 fraud monitoring with device, location and behaviour analysis.

UAE
27 NOV 2025UAE Cyber Security Council

National Encryption Policy approved

Formally approved post-quantum transition plans; automated cryptographic inventory; crypto-agility.

UAE
DURING 2026UAE

Mandatory submission of PQC migration plans

A migration plan resting on an inventory you can defend.

UAE
1 JAN 2026DIFC Commissioner of Data Protection

Regulation 10 in full enforcement

Documented pre-processing risk assessments, transparency notices, human-oversight design, and either certification or a named Autonomous Systems Officer.

UAE
11 FEB 2026CBUAE

Guidance Note on Consumer Protection and Responsible AI Adoption

Board and senior-management accountability for every AI system deployed; human oversight of high-impact decisions.

UAE
SEP 2025UAE Central Bank

Decree-Law No. 6 (2025) extends oversight to fintech and crypto firms

Statutory fraud-prevention capability, prompt breach reporting; criminal liability attaches to management negligence.

UAE
JUL 2025DIFC

Data Protection Amendment No. 1

Private right of action including for distress; processors carry direct liability.

UAE
FROM 2026KSA — NCA

NCNICC-1:2025 brings private-sector entities into mandatory scope

Governance, audit, third-party and cloud-provider controls.

KSA
2024KSA — SAMA

Cyber Security Framework and e-KYC framework

Biometric identity proofing for licensed digital banks and payment service providers.

KSA
2027SWIFT

SwiftNet 8.0 expected to be PQC-enabled

Participant migration inside a 15-month window.

ALL MARKETS
2028CBUAE

PQC readiness expectation for banks

Migration executed on critical systems.

UAE

Reproduced from the Orvix Financial services industry page. Last reviewed 26 August 2026.

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