The Central Bank of the UAE (CBUAE) issued its Guidance Note on the Consumer Protection and Responsible Adoption and Use of Artificial Intelligence and Machine Learning by Licensed Financial Institutions.
Although described as “non-binding”, the Guidance clearly signals that AI governance has entered the supervisory perimeter for UAE financial institutions.
Although described as “non-binding”, the Guidance clearly signals that AI governance has entered the supervisory perimeter for UAE financial institutions.
CBUAE’s message is clear:
Artificial Intelligence must be deployed responsibly, transparently, and fairly, with meaningful human oversight, particularly where it impacts consumers.
For Boards and senior management, the challenge is no longer whether AI should be governed, but whether governance is sufficiently mature to withstand supervisory scrutiny.
Who It Applies To
The Guidance applies to all Licensed Financial Institutions (LFIs) regulated by CBUAE, including:
Banks
Finance companies
Insurance providers
Payment service providers
Any regulated entity deploying AI or machine learning
It extends to any AI or ML system that influences customer outcomes, including:
Credit scoring and loan approvals
Insurance underwriting and claims decisions
Fraud detection and transaction monitoring
Customer onboarding and account opening
Product targeting and marketing
Chatbots and automated customer interaction
Complaint handling and service decisions
If AI affects access to financial services or materially influences a consumer decision, the Guidance applies whether AI is developed internally or provided by a third party.
What Are the Expectations?
CBUAE expects institutions to:
Establish Board-level oversight and an AI governance framework
Maintain an inventory of all AI systems and classify them by risk
Provide transparency and explainability for AI-driven decisions
Allow customers to seek human review of high-impact decisions
Test AI models regularly for bias and unfair outcomes
Retain the ability to suspend or override AI systems
Conduct due diligence and ongoing monitoring of third-party AI providers
Continuously monitor AI for performance, bias, and consumer impact
In particular, AI used for “high-impact decisions” such as loan approvals or insurance claims will face heightened scrutiny.
How MAST Consulting Can Help
MAST Consulting helps UAE financial institutions build regulator-ready AI governance aligned with CBUAE expectations.
We support clients with:
We support clients with:
AI strategy design
AI governance frameworks
AI model inventory and risk classification
Bias and fairness testing
Human oversight and override protocols
Third-party AI due diligence
Board reporting and regulatory gap assessments
By strengthening AI governance today, institutions can reduce regulatory risk, build customer trust, and enable safe, scalable AI adoption.
