The Riffle
The Dubai Financial Services Authority (DFSA) has finalised targeted amendments to its credit rating agency and prudential reporting requirements following Consultation Paper No. 174. Its Feedback Statement, published on 5 October 2026, explains changes that consolidate regulatory reporting and introduce a more principles-based approach to assessing relationships that could affect rating independence.
For Authorised Firms, the update brings a redesigned Form B110 while retaining applicable capital requirements. For Credit Rating Agencies (CRAs), it refines conflict assessments, streamlines disclosures and clarifies advance notice guidance. The Crypto and Investment Token proposals consulted on under CP174 remain under consideration and are outside this adopted package.
Key highlights
Two implementation dates: Prudential reporting amendments apply from 2 October 2026. CRA amendments commence on 1 January 2027.
Reporting consolidation: Data previously reported in Forms B180 and B120 is captured in the redesigned Form B110. All Authorised Firms complete only the items applicable to them.
Capital requirements continue: The Expenditure Based Capital Minimum (EBCM) remains applicable, with its underlying reporting data captured through B110.
Principles-based conflict assessments: CRAs must assess whether a relationship may cause, or may reasonably be perceived as causing, a conflict of interest.
Streamlined disclosures: The specific requirement to identify whether methodology information is public or non-public is removed. The obligation to explain how a rating was determined remains.
Flexible advance notice: Guidance ordinarily calls for at least 12 hours’ notice before publication, with CRAs assessing whether a longer period is necessary.
Token proposals deferred: Crypto and Investment Token proposals will be considered further, with any next steps communicated separately.
What has changed, and what should firms do next?
Authorised Firms: review reporting mappings now
The redesigned B110 consolidates data previously reported through B180 and B120. It applies to all Authorised Firms, with each firm completing only the relevant data items. Updated guidance in the Prudential Returns module explains how to complete the reporting forms.
The removal of B180 does not remove the EBCM. Firms should review their reporting mappings, check applicable B110 fields and reconcile the data against internal records and capital calculations.
Credit Rating Agencies: document relationship assessments
The revised conflict framework moves beyond reliance on defined family categories. Relationships outside the “Close Relative” category can be relevant, while a relationship within that category does not automatically create a conflict.
CRAs must determine and document how relevant relationships are assessed and managed. Depending on the circumstances, mitigation may include escalation, disclosure or recusal. Existing organisational, systems and compliance requirements continue to support employee independence.
The DFSA also clarified that removing “currently” from the relevant provision does not extend it to former employment relationships.
Rating teams: review disclosures and notice procedures
Although the specific public/non-public information disclosure requirement is removed, CRAs must still provide enough information for users to understand how a rating was determined. An appropriate explanation remains necessary where reliance on material non-public information matters to that understanding.
Advance notice procedures should accommodate the circumstances of each rating. The guidance ordinarily calls for at least 12 hours, but that period may not be sufficient in every case. The underlying rule requires sufficient advance notice, to the extent practicable and appropriate, for the Rating Subject to identify factual errors.
CRAs should review these procedures ahead of 1 January 2027. Regulatory change teams should track the deferred token proposals separately from the adopted amendments.
These suggested implementation steps are practical considerations arising from the amendments, rather than additional requirements announced by the DFSA.
Conclusion
The amendments simplify reporting and remove certain prescriptive CRA disclosure requirements while maintaining expectations around capital, transparency and independence. Reporting changes are already effective; CRAs have until 1 January 2027 to implement their amended requirements.
The Riffle takeaway
Simpler reporting and greater judgment call for clear controls. Authorised Firms should check their B110 reporting now, while CRAs should prepare documented conflict assessments, meaningful rating disclosures and appropriate notice procedures for January. Keep the deferred token proposals on the watchlist.
