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PhD researchers Hassan Amine El Sayed and Fatimah Diouani outlined key differences between European Union and Gulf Cooperation Council approaches to crypto regulation in an article titled Crypto-assets through the lens of EU and GCC regulations that Gulf Today published on July 13, 2026. The researchers noted that the EU introduced the Markets in Crypto-Assets regulation in 2023 to cover assets not already governed by legislation such as MiFID II. GCC-based crypto-asset service providers seeking to offer services to the EU public or gain trading admission must obtain authorisation and meet MiCA standards, the article stated.
According to the Gulf Today article, MiCA imposes obligations on crypto-asset service providers that include safekeeping of client assets and funds, complaints-handling mechanisms, conflict-of-interest procedures, prudential requirements and governance arrangements. Providers must also satisfy rules on client due diligence, transparency and prevention of market abuse depending on the services offered. A Sumsub analysis indicated that full MiCA enforcement across the EU takes effect after the July 1, 2026, transitional deadline, requiring unauthorised providers to cease regulated activities.
El Sayed and Diouani reported that GCC states have adopted differing regulatory models despite sharing goals of investor protection and market integrity with the EU framework. The United Arab Emirates regulates crypto-assets at both federal and free-zone levels through Cabinet Decision No 111 of 2022 on virtual assets and service providers, Dubai Law No 4 of 2022 that established the Virtual Assets Regulatory Authority, and oversight by the Abu Dhabi Global Market and Dubai International Financial Centre authorities. Bahrain introduced a dedicated Crypto-Asset Module setting licensing and anti-money laundering requirements, the researchers wrote.
Saudi Arabia lacks a comprehensive crypto-trading framework while Qatar allows certain digital asset activities inside the Qatar Financial Centre but bars traditional cryptocurrencies such as Bitcoin, according to the Gulf Today article. Kuwait prohibits crypto-related activities outright and Oman is developing a licensing-focused regime centred on investor safeguards. An IMARC Group assessment placed the GCC cryptocurrency market at USD 869 million in 2025 and projected growth to USD 3,547.5 million by 2034 at a compound annual growth rate of 16.92 percent.
Sumsub data published in 2025 showed that 27.67 percent of the UAE population owns virtual assets, the highest per-capita adoption rate globally, with more than 15 million crypto-app installations recorded in the country during 2024 alone. The Virtual Assets Regulatory Authority increased its roster of licensed firms from 14 to 36 over a recent one-year period and issued enforcement notices against 36 unlicensed entities between August 2024 and August 2025, according to VARA records. Fortune Business Insights separately estimated the global cryptocurrency market size at USD 8.47 billion for 2026.
The researchers highlighted that MiCA provides for penalties reaching €5 million for individuals and €15 million for companies, in addition to administrative measures such as temporary bans or authorisation suspensions. Gulf Today reported that crypto-asset service providers in the GCC must ensure multi-jurisdictional compliance when targeting EU markets. ESMA documentation confirms that the regulation supports market integrity, financial stability and improved consumer information on crypto-asset risks.
El Sayed and Diouani concluded that both the EU and GCC continue to promote innovation through regulation while stressing that companies operating across jurisdictions require thorough understanding of applicable rules. The article noted that evolving frameworks in both regions could support expanded cross-border activity if greater alignment emerges over time.
