AI Governance Sprint — CBUAE Fast-Track
Two CBUAE pressures land 16 September 2026 — be audit-trail-ready for both.
What this is
A 4–6 week urgency-priced governance sprint for CBUAE-licensed financial institutions and DIFC/DMCC firms exposed to the 16 September 2026 convergence — the Federal Decree-Law 6/2025 regularization deadline (Art. 184, max administrative penalty AED 1B for unlicensed/breaching activity) and the now-active CBUAE Guidance Note on Consumer Protection & Responsible Adoption of AI/ML (supervisory expectation, formally non-binding).
Why now
Two CBUAE pressures converge on 16 September 2026: the hard licensing-regularization deadline (Federal Decree-Law 6/2025, Art. 184; AED-1B max administrative penalty for unlicensed/breaching activity — not an AI-specific fine, but a real ceiling) and the active CBUAE Guidance Note on AI/ML in consumer protection (non-binding but supervisory). After October 2026 the urgency wedge expires and the sprint converts to the standard DIFC Reg 10 program.
Engagement tiers
Three productized scopes. Pick the one closest to your reality — we'll right-size on the fit call if needed.
AED 90K
4 weeks
Single-line-of-business scope, baseline policy stack, deadline-ready board memo.
AED 120K
5 weeks
Multi-line scope, full evidence pack, customer-facing override flows.
AED 150K
6 weeks
Group scope, AED-1B exposure memo, board readout, regulator engagement support.
50% on signature / 50% on signoff. All AED prices exclusive of 5% VAT.
Outcomes
- Combined readiness pack for the two CBUAE pressures
- Model inventory + tier classification for consumer-protection scope
- Audit-trail + explainability evidence for AI/ML decisioning
- Policy stack aligned to CBUAE Feb-2026 Guidance
- Pre-October 2026 board memo and remediation backlog
What's included
- Federal Decree-Law 6/2025 (Art. 184) exposure baseline
- CBUAE AI/ML Guidance Note obligation mapping (consumer fairness, transparency, redress, accountability)
- Model inventory + decisioning audit-trail
- Customer-facing AI: disclosure, complaints, override flows
- Pre-deadline mock review
Who this is for
CBUAE-licensed banks, insurers, payment institutions, exchange houses
DIFC/DMCC entities with consumer-facing AI/ML in financial services
Heads of Compliance / Risk / Data preparing for the 16 Sept 2026 window
How we work
- 01 · Week 1
Exposure baseline. Federal Decree-Law 6/2025 + CBUAE Guidance obligation mapping.
- 02 · Weeks 2–3
Model inventory + decisioning audit-trail. Customer-facing AI review.
- 03 · Weeks 4–5
Policy stack, override flows, evidence pack, mock review.
- 04 · Week 6
Board memo + handover. (Enterprise tier only.)
FAQ
Is there a 1-billion-dirham AI fine?▾
No. AED 1B is the maximum administrative penalty ceiling for unlicensed or breaching financial activity under Federal Decree-Law 6/2025 — it is not an AI-specific fine. The CBUAE AI/ML Guidance Note is a supervisory expectation, not law. We sell the convergence, not a fictional fine.
What happens after October 2026?▾
This urgency-priced sprint sunsets. The DIFC Reg 10 program remains available for ongoing governance work.
Is the CBUAE Guidance Note enforceable?▾
It is formally non-binding — but it is the regulator's stated expectation. In a supervisory review, divergence from the Note will be challenged.
Related programs
DIFC Reg 10 Sprint
DIFC Regulation 10 readiness for fund admins, family offices, and DIFC entities.
From AED 60K–150K
AuditAudit & Roadmap
Outsourced Private-Sector Chief AI Officer (paid entry).
From AED 25K–45K
OperateOps Retainer
Monitoring, tuning, drift checks, new workflows, governance updates — monthly KPI cadence.
From AED 12K–30K / month
Book a fit call
30 minutes, WhatsApp or Calendly. We'll tell you straight if this is the right next step — and if not, what is.