The DFSA Recognised Jurisdictions List identifies foreign regulators whose standards match DIFC expectations. This allows DIFC firms to work with entities from these jurisdictions under simplified rules—especially when appointing external fund managers or setting up foreign-domiciled funds.

 

 

Understanding the DFSA Recognised Jurisdictions List

The Dubai Financial Services Authority (DFSA) maintains a Recognised Jurisdictions List, a formally curated list of foreign regulatory regimes that the DFSA considers equivalent, reliable, and suitably robust for specific cross-border financial activities. While the list may appear administrative at first glance, it plays a central role in how the DIFC interacts with global markets. Its relevance cuts across fund management, financial services, cross-border supervision, investor protection, and regulatory cooperation.

 

And so, it is important for firms operating in and from the DIFC, to understand the significance of this list, and its relevance to financial service activities regulated by the DFSA.

Regulatory Equivalence Framework

At its core, the Recognised Jurisdictions List is a regulatory equivalence framework. When a foreign jurisdiction appears on this list, the DFSA recognises that the regulatory standards governing financial services in that jurisdiction are broadly aligned with those of the DIFC. 

This recognition allows certain activities—such as establishing funds, appointing external managers, or marketing foreign funds—to be carried out under streamlined rules. It reduces duplicative regulatory checks and provides confidence that the foreign firm or fund operates under a supervisory environment comparable to that of the DFSA.

One of the most common uses of the list is in the establishment and management of funds within the DIFC. A foreign fund manager from a Recognised Jurisdiction can be appointed as an External Fund Manager of a DIFC-domiciled fund without setting up a physical presence in the Centre. Because the DFSA already recognises the strength of supervision in that jurisdiction, the manager avoids the heavier scrutiny applied to applicants from less regulated regions. 

The result is a faster onboarding process, reduced documentation requirements, and greater cross-border efficiency. For DIFC fund managers, the list also facilitates the establishment of “External Funds”—funds domiciled abroad but managed from the DIFC—where DFSA oversight can rely on regulatory cooperation with the foreign jurisdiction.

Role in Fund Marketing and Distribution

The Recognised Jurisdictions List also plays a crucial role in fund marketing and distribution. Under the DFSA’s Collective Investment Rules (CIR), marketing of a foreign fund in or from the DIFC is permitted only where specific criteria are met. One of the strongest and simplest routes is when the fund is domiciled in a Recognised Jurisdiction and qualifies as a “Designated Fund.” In such cases, the DFSA accepts that the fund is subject to regulatory requirements comparable to those applied to DIFC-domiciled funds, particularly in areas like disclosure, custody, valuation, investor protection, and governance. This recognition can significantly ease the process for financial institutions seeking to introduce international funds to UAE-based clients—especially Professional Clients.

Regulatory cooperation and supervision

The list also enables regulatory cooperation and supervision. Because Recognised Jurisdictions generally maintain high standards of enforcement, financial integrity, and investor protection, the DFSA can rely on information-sharing arrangements, mutual assistance protocols, and supervisory alignment with the foreign regulator. This reduces supervisory blind spots and strengthens confidence in cross-border activities. For example, when an External Fund Manager oversees a DIFC fund, both the DFSA and the home-state regulator are expected to maintain consistent oversight. This shared supervisory responsibility is far more efficient when the regulator is drawn from a jurisdiction on the Recognised List.

Counterparty assessments

Another area where the list becomes relevant is in assessing the suitability of counterparties and outsourcing arrangements. When a DIFC firm appoints a custodian, administrator, investment manager, trading venue, or other service provider abroad, DFSA rules generally require the foreign provider to be regulated in a jurisdiction with equivalent standards. Recognised Jurisdictions provide a straightforward benchmark for meeting this requirement. This clarity reduces legal uncertainty, ensures investor protections, and gives fund managers a safe framework for selecting international service providers.

For investors, the Recognised Jurisdictions List serves as an additional safeguard. Whether investing in a foreign fund, appointing an external manager, or receiving advisory services linked to offshore products, investors benefit from the fact that only firms regulated in reputable, well-supervised markets can operate within simplified DFSA channels. It strengthens trust, reduces risk, and aligns with global best practices in financial regulation.

Cross-border market access

Recognised Jurisdictions List promotes cross-border market access, supporting the DIFC’s positioning as a global financial hub. It encourages international firms to collaborate with DIFC-based managers, supports smoother capital flows, and enhances Dubai’s integration into global financial markets. For many global managers, the ability to enter the DIFC ecosystem without establishing a local presence—thanks to this recognition framework—reduces barriers and increases the Centre’s competitiveness.

The DFSA’s Recognised Jurisdictions List is a foundational regulatory tool that underpins much of the DIFC’s cross-border financial activity. It ensures that foreign participants meet the DFSA’s standards without unnecessary duplication, enhances investor protection, facilitates fund marketing and management, strengthens supervisory cooperation, and supports Dubai’s growing role as a global financial centre. For fund managers, banks, and financial institutions, understanding the implications of this list is not just useful—it is essential for operating efficiently and compliantly in one of the world’s most dynamic financial environments.

Here is the current list of recognised jurisdictions:

Australia

• Retail funds registered under the Managed Investment Scheme provisions of the Corporations Act 2001, with ASIC-approved constitutions.

Canada

• Mutual funds authorised under CSA National Instruments 81-101 and 81-102 by any Canadian provincial regulator.

European Union Member States

• UCITS-compliant funds authorised by any EU Member State regulator.
• AIFs managed by authorised AIFMs under AIFMD (Notice No. 5).

Guernsey

• Authorised schemes under the Collective Investment Schemes (Class A) Rules 2002 (as amended).

Hong Kong

• Unit trusts or mutual funds authorised under section 104 of the Securities and Futures Ordinance (SFO).

India

• Mutual funds constituted as unit trusts and registered with SEBI under the SEBI (Mutual Funds) Regulations 1996.

Isle of Man

• Authorised schemes under the Financial Supervision Act 1988 (as amended).

Jersey

• Recognised funds under the Collective Investment Funds (Recognised Funds) (Rules) (Jersey) Order 2003.
  
  

Singapore

• MAS-authorised Collective Investment Schemes under section 286 of the Securities and Futures Act.

South Africa

• Collective investment schemes registered under the Collective Investment Schemes Control Act (CISCA).

Switzerland

• Securities funds equivalent to UCITS under the Swiss Investment Fund Act, managed by a FINMA-licensed manager.

United Kingdom

 

United States of America

Malaysia

• Islamic funds approved by the Securities Commission Malaysia under section 212 of the Capital Markets and Services Act 2007.
• Islamic funds approved under section 32 of the Securities Commission Act 1993.

United Arab Emirates

Passported Funds for which: