DFSA authorisation
Writing a Regulatory Business Plan
In short
The Regulatory Business Plan is the document the DFSA reads first and returns to throughout. It has to describe what the firm does operationally, for whom, how money and instructions move, what can go wrong and what stops it. Strategy language fails. Operational specificity passes.
Describe the mechanics, not the ambition
The most common failing is a plan that reads like an investor deck. The DFSA does not need to be persuaded the market is attractive. It needs to know who signs the mandate, where the client's money sits, who can instruct a transaction, who checks it, what happens when the person who normally checks it is on leave, and how an error is detected.
A good test: could someone read the plan and draw an accurate flow diagram of a client's money and instructions from onboarding to settlement? If not, it needs more detail.
Be specific about clients
Client classification drives conduct obligations. Say whether clients will be Professional Clients or Retail Clients, how classification is assessed and recorded, and what happens when a client asks to be reclassified. Firms that say they will serve sophisticated investors without engaging the classification rules get a question about it every time.
Where the client base includes politically exposed persons, which in this region it often does, address it directly rather than leaving it to the AML policy.
Make the numbers agree with the narrative
The financial projections have to reconcile with the operating description. If the plan describes six staff and the model carries three salaries, that is a question. If the expenditure based capital calculation uses a cost base that differs from the projections, that is a bigger one.
Include a downside case. The DFSA will test whether the firm stays above its capital requirement if revenue underperforms, and a plan that only models success looks naive.
Questions
How long should a Regulatory Business Plan be?
There is no prescribed length. Most are between 40 and 80 pages including appendices. Length is not the measure. A shorter plan that answers the operational questions completely beats a long one that does not.
Can we reuse a business plan from another regulator?
As source material, yes. As a submission, no. The DFSA expects the plan mapped to its own Rulebook and its own definitions, and a recycled FCA or MAS pack is visible immediately.
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.