CMA Regulatory Glossary
Authorized Person (AP): An entity licensed by the CMA to conduct one or more capital market activities (dealing, arranging, managing, advising, custody). Tokenization platforms require AP status for activities involving tokenized securities. Six categories exist with different capital requirements ranging from SAR 2 million to SAR 50 million.
Capital Market Law (CML): Royal Decree M/30 (2003), as amended. The primary legislation establishing the CMA and governing all securities activities in Saudi Arabia. The 2021 amendment expanded CMA jurisdiction to include digital assets qualifying as securities.
Committee for the Resolution of Securities Disputes (CRSD): The CMA’s quasi-judicial body that adjudicates disputes between investors and authorized persons, including disputes arising from tokenized securities offerings.
Corporate Governance Regulations: CMA rules governing board composition, disclosure, and shareholder rights for listed companies and investment funds. Applicable to SPVs and fund structures used for real estate tokenization.
Fintech Lab: The CMA’s regulatory sandbox operating within an ecosystem of 261 fintech companies with cumulative investment of SAR 7.9 billion ($2.1 billion). Innovative financial products — including tokenized real estate — are tested under controlled conditions before permanent licensing. Participants receive temporary authorization with limited customer and transaction volume. REGA has separately approved 9 PropTech sandbox platforms for real estate tokenization.
Investment Fund Regulations: CMA regulations governing publicly offered and private investment funds, including Real Estate Investment Traded Funds (REITs). Tokenized real estate funds must comply with these regulations or operate under sandbox exemptions.
Offer of Securities Regulations: Rules governing the public offering of securities, including prospectus requirements, investor suitability, and ongoing disclosure obligations. Applicable to tokenized real estate offerings classified as securities.
Qualified Foreign Investor (QFI) [ABOLISHED]: Formerly a non-Saudi institutional investor meeting minimum asset requirements (SAR 1.875 billion). The QFI concept was abolished entirely in February 2026, with direct access now open to all foreign investors. This landmark reform eliminates asset-threshold barriers to Saudi capital market participation, including tokenized securities.
Real Estate Investment Traded Fund (REIT): A CMA-regulated investment fund that owns and manages income-producing real estate, listed on Tadawul. Saudi REITs provide the regulatory precedent for tokenized real estate.
Securities: Under Article 2 of the CML, includes shares, debt instruments, investment fund units, and any other instrument or right classified by CMA as a security. Tokenized real estate interests meeting the securities definition trigger full CMA regulatory compliance.
Tadawul: The Saudi Exchange, operated by Saudi Tadawul Group. The GCC’s largest stock exchange by market capitalization (SAR 10.2 trillion). Future tokenized securities may trade on Tadawul or on CMA-licensed alternative trading systems.
Alternative Trading System (ATS): A non-exchange trading venue authorized by CMA for matching buy and sell orders in securities. Tokenized real estate may be listed on CMA-licensed ATS platforms rather than the main Tadawul board, enabling 24/7 trading and lower listing costs while maintaining CMA regulatory oversight.
Client Suitability: CMA requirement that authorized persons assess whether an investment product is suitable for a particular client based on their financial situation, investment objectives, risk tolerance, and knowledge. For tokenized real estate, platforms must verify that investors understand the risks specific to tokenized assets before enabling token purchases.
Continuous Disclosure: CMA obligation for securities issuers to promptly disclose material events that may affect securities prices. For tokenized real estate, continuous disclosure triggers include: significant changes in property valuation, major tenant departures, construction delays for off-plan tokens, regulatory changes affecting the property, and natural disasters or force majeure events.
Edaa (Securities Depository Center): The central depository for securities listed on Tadawul. Edaa maintains records of securities ownership and processes settlement. If tokenized real estate securities are listed on Tadawul or an ATS, Edaa may serve as the central registry — potentially integrating with blockchain-based ownership records.
Insider Information: Material non-public information about a security or its issuer. CMA’s insider trading regulations apply to tokenized securities — individuals with advance knowledge of property valuations, tenant decisions, or regulatory rulings must not trade tokens until the information is publicly disclosed.
Market Making: The activity of providing continuous buy and sell quotes for a security to ensure liquidity. CMA may require or incentivize market makers for tokenized real estate securities to ensure that investors can exit positions at fair prices. Market making for tokenized RE is expected to operate differently from equities due to the lower trading volumes and larger bid-ask spreads typical of illiquid asset classes.
Private Placement Exemption: CMA rules allowing securities offerings to qualified investors (minimum SAR 1 million investment or institutional status) without the full prospectus requirements of a public offering. Many early tokenized real estate offerings are expected to launch as private placements before transitioning to public offerings as the market matures.
Prospectus: The CMA-approved disclosure document required for public securities offerings, containing comprehensive information about the issuer, the securities, the risks, and the use of proceeds. Tokenized real estate prospectuses must include: property valuations, rental income projections, platform fee schedules, smart contract risk disclosures, and Shariah compliance opinions.
Regulatory Sandbox Application: The formal process for applying to CMA’s Fintech Lab. Applications must include: business model description, technology architecture, risk management framework, customer protection measures, and exit strategy (plan for transitioning to permanent licensing or winding down).
See also: CMA Securities Rules | CMA Entity Profile | REGA Wafi Terminology | Blockchain Standards | Investment Terminology | Vision 2030 Glossary | Fintech Sandbox Tracker | AML/CFT Compliance
Updated March 19, 2026