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Prudential categories

The eight DFSA categories and what each one costs to hold

In short

Your category follows from the activities you intend to carry on. It sets base capital, the expenditure based capital minimum, reporting frequency and supervisory intensity. Most new DIFC entrants land in Category 3C at US$500,000 base capital, or Category 4 at US$10,000.

Category 1

Banks and deposit-taking institutions

US$10,000,000

Permitted activities

  • Accepting Deposits
  • Providing Credit from own balance sheet

The heaviest prudential category. Firms face full capital adequacy, liquidity and large exposure requirements, and the authorisation process is correspondingly long.

Expenditure test: 13 weeksDetail →

Category 2

Proprietary trading firms and principal dealers

US$2,000,000

Permitted activities

  • Dealing in Investments as Principal
  • Providing Credit where not Category 1

Applies where the firm puts its own balance sheet at risk in market transactions. Market risk and credit risk capital requirements apply on top of base capital.

Expenditure test: 13 weeksDetail →

Category 3A

Brokers and execution-only intermediaries

US$500,000

Permitted activities

  • Dealing in Investments as Matched Principal
  • Dealing in Investments as Agent

The firm transacts for clients without taking principal risk on its own account beyond matched positions.

Expenditure test: 18 weeksDetail →

Category 3B

Fund custodians and trustees

US$4,000,000

Permitted activities

  • Providing Custody for a Fund
  • Acting as Trustee of a Fund

Holding or controlling client assets on this scale attracts the higher base capital and stricter client asset rules.

Expenditure test: 18 weeksDetail →

Category 3C

Asset managers, fund managers and discretionary portfolio managers

US$500,000

Permitted activities

  • Managing Assets
  • Managing a Collective Investment Fund
  • Providing Custody other than for a Fund
  • Managing a Profit Sharing Investment Account on an unrestricted basis

The most common category for new DIFC entrants in asset and wealth management. The expenditure based requirement usually exceeds base capital once the cost base is real.

Expenditure test: 18 weeks, or 6 weeks where no client assets are heldDetail →

Category 3D

Payment service providers and money transfer businesses

US$200,000

Permitted activities

  • Providing Money Services
  • Operating a Crowdfunding Platform

Payment and money services carry heavy AML expectations relative to their capital requirement, and safeguarding rules apply to client funds.

Expenditure test: 18 weeksDetail →

Category 4

Corporate finance advisers, insurance brokers and arrangers

US$10,000

Permitted activities

  • Advising on Financial Products
  • Arranging Deals in Investments
  • Insurance Intermediation
  • Insurance Management
  • Operating an Alternative Trading System
  • Providing Fund Administration
  • Acting as Trustee of a Fund where not Category 3B

The lightest category. The firm neither holds client assets nor deals as principal, so the expenditure based requirement is what usually sets the capital number.

Expenditure test: 6 weeksDetail →

Category 5

Islamic financial institutions operating the entire business in accordance with Shari'a

US$10,000,000

Permitted activities

  • Islamic Financial Institution managing a Profit Sharing Investment Account on an unrestricted basis

Requires a Shari'a Supervisory Board, a Shari'a compliance function and systems that evidence compliance throughout the business.

Expenditure test: 13 weeksDetail →

Base capital is only half the answer

Every Authorised Firm also holds an expenditure based capital minimum, calculated as a number of weeks of annual audited expenditure. For most firms with a real cost base that figure exceeds base capital. Model both across three years and hold the higher number with headroom. See DFSA capital requirements.

Not sure which category applies?

It follows from the activities, and the activities are defined in the DFSA General Module rather than in commercial language. We map it before anything is drafted.