Publishing Verified Trader Performance — UAE Regulatory Overview

How NakedPnL is positioned across the UAE: DFSA in DIFC, FSRA in ADGM, SCA on the mainland, VARA for Dubai virtual assets, and federal data-protection law (PDPL).

NakedPnL operates a public registry of verified investment performance produced by individual traders who voluntarily connect read-only exchange API keys or sign on-chain wallet attestations. Daily NAV snapshots feed a time-weighted return (TWR) calculation; results are recorded in an append-only, SHA-256 chained ledger and Merkle-anchored to Bitcoin via OpenTimestamps so any third party can independently re-verify them.

This page describes how that activity is positioned across the UAE's overlapping regulatory regimes: the Dubai Financial Services Authority (DFSA) in the Dubai International Financial Centre (DIFC); the Financial Services Regulatory Authority (FSRA) in the Abu Dhabi Global Market (ADGM); the Securities and Commodities Authority (SCA) for mainland UAE; and the Virtual Assets Regulatory Authority (VARA) for the Emirate of Dubai (excluding the DIFC).

How NakedPnL is classified in the UAE

NakedPnL's activity is the production and distribution of factual performance data. The platform does not hold a licence from any of the four UAE regulators referenced above and does not appear on the corresponding public registers.

DIFC and the DFSA Rulebook

The DFSA regulates Financial Services in the Dubai International Financial Centre under the Regulatory Law 2004 (DIFC Law No. 1 of 2004) and the General Module (GEN) of the DFSA Rulebook. Financial Services include Advising on Financial Products, Arranging Deals in Investments, Dealing in Investments as Agent or Principal, Managing Assets, and Operating an Investment Crowdfunding Platform, among others.

The DFSA's perimeter analysis turns on whether the activity is conducted in or from the DIFC. NakedPnL does not undertake any of the listed Financial Services, does not operate from the DIFC, and does not target DIFC-resident professional clients. On those facts, the platform's analysis is that DFSA Financial Services authorisation is not required for its current activities.

ADGM and the FSRA Rulebook

The FSRA regulates Regulated Activities under the Financial Services and Markets Regulations 2015 (FSMR) of ADGM. Regulated Activities include Advising on Investments or Credit, Arranging Deals in Investments, Managing Assets, Providing Custody, and Operating a Multilateral Trading Facility, as well as the Virtual Asset framework introduced by the FSRA in 2018 and progressively expanded.

NakedPnL does not undertake any FSRA Regulated Activity, does not operate from ADGM, and does not provide any Virtual Asset service within the meaning of the FSRA's Guidance on Regulation of Virtual Asset Activities (initially published February 2018, periodically updated). The platform's analysis is that FSRA authorisation is not required.

SCA — UAE mainland

The Securities and Commodities Authority (SCA) regulates financial activities on the UAE mainland (i.e. outside the DIFC and ADGM) under Federal Decree-Law No. (4) of 2000 and subsequent decisions, including the SCA's Decision concerning the Regulation of Crypto-Assets and the consolidation of crypto-asset oversight following the 2022 Cabinet Decision creating VARA in Dubai. Activities requiring SCA licensing include providing securities consultation, brokerage in securities, and managing investment funds.

NakedPnL does not provide securities consultation in or from the UAE, does not act as a broker, and does not manage investment funds. The platform does not market its services to UAE mainland residents on a basis that would draw it within the SCA's licensing perimeter.

VARA — Virtual Assets in Dubai

The Virtual Assets Regulatory Authority (VARA) regulates Virtual Asset Activities in the Emirate of Dubai (excluding the DIFC) under Dubai Law No. 4 of 2022. The VARA Regulations and the seven Activity-specific Rulebooks (Advisory, Broker-Dealer, Custody, Exchange, Lending and Borrowing, Management and Investment, Virtual Asset Issuance) define the licensing perimeter.

NakedPnL does not provide Virtual Asset Advisory Services (which are defined to include personalised recommendations on virtual asset transactions), does not custody virtual assets, does not operate an exchange, and does not manage virtual asset portfolios on behalf of clients. The platform publishes factual performance data of consenting traders. On those facts, the platform's analysis is that VARA licensing is not required.

What NakedPnL does not do

• No copy trading. The platform cannot replicate a trader's positions into another user's account. Copy-trading services are typically Arranging Deals or Asset Management under the DFSA / FSRA rulebooks.
• No personalised recommendations or virtual-asset advisory services under the VARA Advisory Rulebook.
• No broker-affiliate links to UAE-licensed or unlicensed firms in exchange for fees.
• No investor-trader matching.
• No custody of assets — no Providing Custody under the DFSA / FSRA frameworks, no Custody Services under the VARA Custody Rulebook.
• No execution. The platform never sends orders to any venue.

These design choices are encoded as feature flags in the codebase and protected by a continuous-integration test that fails the build if any flag is changed.

What UAE users should know

Users in the UAE should treat the registry as factual performance data and nothing more. Past performance is not necessarily indicative of future performance — a phrase the DFSA, FSRA, SCA, and VARA each require licensed entities to display alongside past-performance information. NakedPnL applies an equivalent statement on every trader profile.

If a third party offers to manage your money based on a NakedPnL track record, check the public registers of the relevant UAE regulator to verify that the third party holds the appropriate licence (DFSA Public Register, FSRA Financial Services Permissions, SCA Licensed Activities, or VARA VASP register). NakedPnL does not vouch for any third-party manager.

Data protection: PDPL, DIFC DPL, and ADGM DPR

Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) is the UAE federal data-protection statute, with implementing regulations issued by the UAE Data Office. The DIFC Data Protection Law 2020 (DIFC Law No. 5 of 2020) applies to processing in the DIFC. The ADGM Data Protection Regulations 2021 apply to processing in ADGM. Each regime contains its own data-subject rights and lawful-bases framework.

Lawful bases used by the platform include performance of a contract for users with an account, legitimate-interests-style reasoning for minimal aggregated analytics, and explicit consent for the public listing of a trader's handle and TWR series. Data-subject rights — access, rectification, erasure, objection — are honoured through the privacy contact. Withdrawing public-listing consent removes the registry entry from public endpoints.

Tax considerations

The UAE introduced a federal Corporate Tax (Federal Decree-Law No. 47 of 2022) effective for financial years commencing on or after 1 June 2023, with a 9% rate on taxable income above AED 375,000 and a 0% rate below that threshold. Personal income from employment, personal investment, and real-estate income generally remains untaxed at the federal level. Specific facts may differ. The platform does not produce UAE tax statements; users are responsible for their own returns. A registered UAE tax adviser is the right resource for specific questions.

UAE disclaimer variant

The platform applies a UAE-specific disclaimer at the surface of the user interface. The disclaimer variant key is ae, configured in lib/jurisdictions.ts. The current additional notice text reads: NakedPnL is not regulated by the DFSA. The service is provided as an innovation-licensed publisher of verified data. The innovation-licensed phrasing is forward-looking framing reflecting the platform's interest in DFSA's Innovation Testing Licence (ITL) and FSRA's RegLab pathways; the platform does not currently hold an ITL, RegLab, or any other regulator-issued licence. This page is the more accurate statement of current status.

Frequently asked questions