Three markets. One shift in regulatory thinking.
Three regulatory developments across the UAE, Nigeria and Kenya recently caught our attention. On the surface, they addressed different parts of the financial system. Dubai advanced its framework for virtual assets. Nigeria introduced a new model for coordinating oversight of the same market. Kenya tightened supervision of digital lenders. Viewed individually, each is an important regulatory development. Viewed together, they point to something much bigger. For decades, financial regulation largely followed the same sequence. Innovation emerged, markets developed, regulators assessed the risks, new rules were introduced and firms adapted. That approach worked when innovation evolved over years rather than months. Digital finance no longer moves at that pace. Products launch faster. Business models evolve continuously. Risks emerge in real time. Regulators are therefore changing more than their rulebooks. They are redesigning how they supervise markets, allocating responsibilities more clearly, improving coordination across agencies and strengthening oversight as markets mature. That is the thread connecting these three developments. Different markets. Different priorities. But each reflects the same reality: regulation is becoming a continuously evolving operating model rather than a static framework that changes only when legislation is updated. For firms operating across these markets, that shift matters. Regulatory strategy is becoming an ongoing capability rather than a milestone achieved when a licence is granted. UAE: jurisdiction is becoming as important as licensing Revolut’s recent in-principle approval from Dubai’s Virtual Assets Regulatory Authority (VARA) attracted considerable attention. Coming on top of the payment permissions it already holds from the Central Bank of the UAE, it marks another step towards building a broader digital financial ecosystem in the country. [1, 2] The approval itself is significant. What interested us more, however, was what it says about the direction of regulation in the UAE. Rather than creating a single framework for virtual assets, the UAE has deliberately developed a layered regulatory model where responsibility depends on both geography and activity. VARA regulates virtual assets within Dubai, excluding DIFC, under authority delegated at the federal level through Cabinet Resolution No. 112 of 2022. ADGM and DIFC continue to operate under separate regulatory regimes through the FSRA and DFSA respectively, while AED‑referenced payment tokens fall within the remit of the UAE Central Bank and investment‑type virtual assets remain subject to the federal capital markets regulator, alongside local supervision by VARA, DFSA and FSRA. For firms entering the UAE, the first question is no longer simply how to obtain a licence. It is understanding which regulator has jurisdiction over which activities, how those responsibilities interact and how they may change as a business expands across products, customers or jurisdictions. That distinction is becoming increasingly important. Capital, governance and risk management expectations have continued to evolve across VARA, the CMA, DFSA and FSRA during 2026. Firms operating across more than one framework should expect regulatory expectations to continue developing rather than assuming certainty begins once a licence has been granted. [4] The practical implication is straightforward. Licensing provides market access. Long-term success depends on understanding the regulatory architecture well enough to adapt as that architecture continues to evolve. The UAE’s approach also demonstrates a broader point. As digital finance becomes more sophisticated, regulators are recognising that effective supervision is no longer achieved through a single authority. It requires clearly defined responsibilities, coordination between regulators and the flexibility to respond as markets develop. The focus is shifting from simply regulating products to regulating increasingly complex financial ecosystems. Nigeria: coordination is becoming a regulatory capability Nigeria’s Presidential Executive Order on Virtual Assets Coordination is significant for reasons that extend well beyond digital assets. The Order establishes a Virtual Asset Council chaired by the Central Bank of Nigeria, with the Nigeria Revenue Service and the Securities and Exchange Commission as vice-chairs, alongside the Financial Intelligence Unit and the Office of the National Security Adviser. Rather than creating another regulator, it establishes a formal structure for coordination while leaving each authority’s statutory powers intact. [7, 9] That distinction matters. As digital asset markets have expanded, responsibility has increasingly been shared across central banks, securities regulators, tax authorities, financial intelligence units and law enforcement agencies. Without clear coordination, overlapping mandates can slow decision-making, create uncertainty for firms and weaken supervision. Nigeria’s approach acknowledges that challenge directly. The new Council is intended to remove much of that friction. The SEC continues to oversee securities-type virtual assets, while the Central Bank focuses on payments, settlement and custody. A 30-day timetable for a Harmonised Implementation Framework demonstrates the emphasis on operational coordination rather than simply announcing another policy initiative. [7, 9] This is happening alongside broader regulatory reforms. The SEC has strengthened capital requirements for digital asset firms, legislation continues to progress and more platforms are moving within the formal regulatory perimeter. [8] Taken together, these developments suggest Nigeria is entering a different phase of market development. The priority is no longer simply defining regulatory responsibilities. It is ensuring regulators can work together effectively as markets become larger, faster and more interconnected. For firms, this reduces more than regulatory uncertainty. Better coordination should also lead to more consistent supervision, clearer accountability and faster regulatory responses when markets evolve or risks emerge. The broader lesson extends beyond Nigeria. Financial innovation increasingly cuts across payments, capital markets, taxation, financial crime and consumer protection. Regulators organised around traditional institutional boundaries will inevitably face challenges keeping pace. Coordination is therefore becoming a regulatory capability in its own right rather than an administrative exercise. Kenya: supervision does not end with licensing Kenya illustrates a different stage in the evolution of digital finance regulation. The Central Bank of Kenya recently licensed a further 25 Digital Credit Providers, bringing the total number of licensed firms to 252. Within only a few years, digital lenders have moved from operating largely outside the regulatory perimeter to becoming one of the country’s most actively supervised financial sectors. [13] That is a considerable regulatory achievement. It also highlights an important reality. Licensing firms is only the beginning of effective supervision. The Competition Authority of Kenya’s latest