DFSA prudential category
DFSA Category 3B
Fund custodians and trustees
In short
Category 3B carries base capital of US$4,000,000 and an expenditure based capital minimum of 18 weeks of annual audited expenditure. A firm holds whichever is higher. Holding or controlling client assets on this scale attracts the higher base capital and stricter client asset rules.
- Base capital
- US$4,000,000
- Expenditure test
- 18 weeks
- Regulator
- Dubai Financial Services Authority
- Entity form
- Private Company limited by shares
Permitted activities
- Providing Custody for a Fund
- Acting as Trustee of a Fund
How the capital works in practice
Base capital of US$4,000,000 is the floor, not the target. The expenditure based capital minimum takes annual audited expenditure, deducts permitted exclusions, divides by 52 and multiplies by 18 weeks. Whichever number is higher is the requirement, and it has to be met continuously rather than at year end.
For a firm in this category with a meaningful cost base, the expenditure test frequently produces the larger figure. Model both across a three year plan including a downside case, because the DFSA will do exactly that during review and will ask what happens if revenue underperforms.
What the DFSA will want to see
A Regulatory Business Plan describing the operating model rather than the market opportunity. A compliance framework mapped to the applicable Rulebook modules. An AML policy addressing both the DFSA AML Module and the federal regime. And named individuals for the Senior Executive Officer, Compliance Officer, Money Laundering Reporting Officer and Finance Officer functions, all of whom the regulator approves personally.
Confirm before you budget
Capital requirements and fees are set by the DFSA and change. Figures here were reviewed in September 2026 and are a planning aid. Confirm the current position against the DFSA Rulebook before committing capital.Not sure which DIFC licence you need?
Answer eight questions and we will tell you the licence route, the likely cost and the realistic timeline. It takes about two minutes and there is no obligation.