As the summer months draw to a close and stakeholders prepare for the final quarter of 2025, lawyers, lenders and sponsors alike are confronting an evolving financing environment in the UAE. Several structural and regulatory developments suggest that distressed lending and restructuring activity will rise in the near term. This note highlights the growing role of non-bank capital providers, key legal updates and practical considerations for those navigating the market.

A shifting financing landscape

Federal Law Decree No 51 of 2023 concerning Financial Restructuring and Bankruptcy (the New Bankruptcy Law) came into effect in the UAE on 1 May 2024 and repealed the previous bankrupcty law, Federal Decree Law No 9 of 2016 (the Old Bankruptcy Law). All regulations issued under the Old Bankruptcy Law remain in force until new regulations are published, which will further clarify a number of points.