QFMA Introduces International Licensing Regime for Financial Services Firms

The Board of Directors of the Qatar Financial Markets Authority (QFMA) has issued Decision No. 3 of 2026, introducing the Instructions for the International License to Practice Certain Activities in International Financial Markets (the Instructions).

The Instructions create a regulatory framework under which QFMA-licensed financial services firms may, with prior QFMA approval, conduct specified activities in international financial markets. The new regime forms part of Qatar's broader effort to develop its capital markets and expand access to international investment opportunities while maintaining regulatory oversight and investor protection.

Permitted Activities

Subject to prior QFMA approval, licensed firms may conduct one or more of the following activities in international financial markets:

• Executing client orders in international securities markets.
• Executing orders for the firm's own account (i.e., proprietary trading).
• Investment management in securities.
• Investment custody.
• Any other activity the QFMA may determine.

Eligibility Requirements

The regime is available only to existing QFMA-licensed financial services firms. Applicants must demonstrate net equity of at least 75% of paid-up capital, possess the necessary experience and competencies, and submit detailed documentation covering their organizational structure, operational procedures, internal controls, and risk management framework. Firms may only conduct permitted activities through natural persons individually accredited by the QFMA.

Once approval is granted, firms must satisfy all operating conditions within six months of the date of QFMA approval. Failure to do so will render the approval null and void, although the QFMA may extend this period where adequate justification is provided.

Key Operational Restrictions

The Instructions prohibit firms from, among other things:

• Executing transactions without ensuring that sufficient client funds are available.
• Financing client transactions using either the firm's funds or client assets.
• Engaging in margin trading in international financial markets.
• Opening joint accounts with more than one beneficiary.
• Making cash payments to clients.

Client Agreements

Client agreements must address matters including disclosure of risks of international market trading, order execution procedures, ownership registration arrangements, fees, and settlement arrangements. Electronically signed agreements must include a clause confirming that the client's electronic approval constitutes their signature and acknowledgment of all terms and conditions.

Where a client seeks leverage, a signed declaration must be attached specifying the leverage ratio requested and setting out the associated risks. Firms must notify clients promptly of all transactions executed on their behalf, and must provide account statements at least quarterly for active accounts.

Omnibus Accounts

Firms may deal in international financial markets on behalf of clients through omnibus accounts, provided they:

• Do not reflect client orders in internal records until executed in the international financial markets.
• Maintain detailed records of all movements on client accounts.
• Segregate their own investments and cash balances from those of their clients, showing them separately in all financial statements.

International Intermediaries and Foreign Investment Funds

Firms are prohibited from dealing with any international intermediary or foreign investment fund that is not licensed or registered by the competent authorities in its country.

Before commencing trading — and annually thereafter — firms must submit to the QFMA information about the markets, instruments, and intermediaries through which they intend to operate, together with documents evidencing the licensing or registration of international intermediaries and foreign investment funds (unless listed on a regulated market), and copies of all relevant agreements. Those agreements must meet minimum content requirements covering governing law, dispute resolution, fees, settlement mechanics, information access rights, and an obligation on the intermediary or fund to notify the firm immediately of any material change affecting its license or registration.

Marketing Requirements

All promotional materials by firms — including website and social media content — must carry clear warnings about the risks associated with international financial markets.

Key Takeaways

Firms intending to apply for an international license should consider, among other things: staff accreditation status; relationships with foreign intermediaries and investment funds; client agreements (including electronic signature provisions); asset segregation and recordkeeping arrangements; the required annual QFMA notification process; and marketing materials and investor communications.