The UAE central bank's AI guidance: in, on or out of the loop
Three levels of human oversight, a right to ask for human review, and an AI inventory for every bank. What the CBUAE guidance asks of lenders.
On 11 February 2026 the Central Bank of the UAE issued a Guidance Note on consumer protection and the responsible adoption of AI and machine learning by licensed financial institutions (CBUAE Rulebook). The principles are non-binding, but they set clear supervisory expectations.
Three levels of oversight
- Human in the loop: AI recommends; a person approves or rejects.
- Human on the loop: AI runs routine tasks; a person monitors and can step in.
- Human out of the loop: AI acts alone, but only for “low-risk, non-material processes with appropriate controls in place”.
What banks are expected to do
- Keep a documented AI governance framework, proportionate to their size.
- Keep an inventory of every AI model, including third-party models, with at least name, purpose and risk rating.
- Stress-test systems for bias, and stay accountable for outcomes even when AI is outsourced.
- Where feasible, use AI to spot potential fraud, money laundering and suspicious activity.
What customers get
According to Pinsent Masons, the guidance says customers can request human review, challenge AI-driven decisions, correct inaccurate data and use complaints channels, and that banks should consider opt-outs from AI-based decisions where appropriate (Pinsent Masons).
“The guidance note makes clear that the use of AI and ML in financial services is fundamentally a consumer protection and conduct risk issue.”Marie Chowdhry, Pinsent Masons
Context
The guidance arrived as generative AI use surged. A survey by the Dubai Financial Services Authority found generative AI use among financial firms in the DIFC rose 166% between 2024 and 2025, Pinsent Masons reported.
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