What changed in March 2026
The CMA published a draft robo-advisory framework on 26 August 2025 (CMA_N_3852) and closed the consultation on 24 September 2025. On 5 March 2026 it announced Board approval (CMA_N_3994), with the amended CMIR and Glossary linked from the announcement. The Glossary amendment is Resolution 1-26-2026 of 2 March 2026. The CMIR file linked from the announcement cites Resolution 2-3-2026 of 7 January 2026, so the approval date and the announcement date differ.
Before the framework, robo-advisory ran through the FinTech Lab: it was among the permit models listed in 2021, and robo-advisory firms are still on the CMA's live list of test companies.
How the CMA defines it
The Glossary defines a robo-advisory service as a licensed CMI's use of algorithms and modern technology to manage clients' investments according to pre-determined investment strategies, "with no or limited human intervention".
Two points follow from that wording. The service is discretionary management of client investments, so it sits in the Managing activity. And it has to be delivered by a licensed CMI; there is no standalone robo-advisory licence for a firm to hold on its own.
Which licence can offer it
| CMI licence | Robo-advisory allowed? | Minimum capital (in force) | Study fee and annual renewal (SAR) |
|---|---|---|---|
| Managing investments | Yes | One year of expected expenses | 30,000 |
| Managing investments and operating funds | Yes | SAR 20 million | 60,000 |
| Advising only | No | One year of expected expenses | 20,000 |
| Arranging only | No | One year of expected expenses | 20,000 |
Capital: CMIR Art 6(g). Fees: CMA circular of 27 October 2020 (Arabic only; amounts not confirmed as current).
Conditions a robo-advisory service must meet
- No concentration in a single asset or a single issuer.
- Foreign securities only where they are supervised by a regulator with standards at least equivalent to the CMA's.
- Fair, clear disclosure on the platform of the role the algorithms play and the risks involved.
- Advance notice to the CMA of portfolio strategies and of material updates to them.
- Controls over algorithm integrity, with periodic testing completed at least 10 days before a strategy is offered to clients.
- Disclosure of the track record since inception, net of actual expenses, published on the firm's website.
- A registered IT Officer, kept registered at all times.
The IT Officer requirement
The IT Officer is a registrable function under CMIR Art 19, and Art 20(b)(5) makes its registration mandatory at all times for a CMI that offers robo-advisory. It sits alongside the CEO, CFO, Compliance Officer and MLRO that every CMI must keep registered. The same function is registrable for CMIs arranging securities crowdfunding.
Pick someone who can own the algorithm controls, the pre-launch testing and the information-security arrangements, and who can answer CMA questions on them. Registered persons must be resident in the Kingdom unless the CMA exempts them.
The May 2026 draft amendments would extend IT Officer registration to every CMI that uses a technology platform and require technology and information-security arrangements to be tested at least annually. That draft had not been adopted at our last check in October 2026.
Legal form, people and documents
Because robo-advisory needs a Managing licence, the firm must take one of the legal forms in CMIR Art 6(f), such as a joint stock company or a subsidiary of a local bank, established in the Kingdom with its head office there. A limited liability company that only holds an advising licence cannot offer the service.
A CMI limited to managing investments needs at least two registered persons, one of them the CEO, and managing licensees need at least two registered portfolio managers. It may outsource the CFO function to a SOCPA-licensed accounting firm and the Compliance Officer or MLRO function to another CMI, a SOCPA-licensed accounting firm or a Saudi law firm. The CMA's exam route for the managing activity is CME-4A and CME-4B.
Annex 3.1 of the CMIR lets firms limited to managing investments, arranging or advising skip some application documents. Robo-advisory applicants get a narrower version of that exemption, so expect to file more than a conventional managing-only applicant. Full detail is in the CMI licence guide.
AI advice and the edges of the perimeter
The CMA continues to use the FinTech Lab for newer models. It granted permits for artificial intelligence in advisory to Sindbad.Tech in December 2025 and Lamha Tanbu in August 2026, and cancelled the Tatwir Aliddikhar robo-advisory permit at the company's request in July 2026. A product that fits the new robo-advisory rules and can comply with them is expected to seek a licence; a genuinely new model may still be a Lab candidate.
Unlicensed advice is enforced. In March 2026 a person was fined SAR 250,000 after conviction for providing advisory services on social media without a licence.
The market is growing quickly. CMA figures put assets managed on fintech platforms at SAR 6.41 billion in the fourth quarter of 2025, up 87% on a year earlier, across 534,571 portfolios.
From licence to launch
Hold the right licence
A Managing licence, either new or as a variation of an existing CMI licence. See the CMA licences hub for the route map.
Register the IT Officer
File the registration through the CMA portal along with the CEO, CFO, Compliance Officer and MLRO.
Notify the strategies
Give the CMA advance notice of each portfolio strategy, and of material updates later.
Test the algorithms
Run and document integrity testing at least 10 days before the strategy is offered to clients.
Publish the disclosures
Explain the algorithms' role and the risks on the platform, and publish the track record since inception net of actual expenses.
Common questions
Is there a separate robo-advisory licence?
No. Robo-advisory is a service that only CMIs licensed for Managing Investments, or Managing Investments and Operating Funds, may offer.
Can an advising-only firm run a robo-advisor?
No. The service manages client investments with discretion, which needs a Managing licence and one of the legal forms in CMIR Art 6(f).
Can robo portfolios hold foreign securities?
Yes, if the securities are supervised by a regulator whose standards are at least equivalent to the CMA's. Concentration in a single asset or issuer is not allowed.
How far ahead of launch must we test the algorithms?
Testing must be done at least 10 days before a strategy is offered to clients, and the CMA must have had advance notice of the strategy.
Primary sources
Last reviewed: 11 October 2026
General information, not legal advice. Saudi rules change; we confirm every requirement against the regulator's current text before you file.
