Introduction: From Reform to Execution

Saudi Arabia’s financial reforms have moved from blueprint to build-out. Vision 2030 and the Financial Sector Development Program (FSDP) have liberalised foreign access, deepened the primary and secondary markets for debt, and modernised post-trade infrastructure across the exchange (Saudi Exchange), the central counterparty (CCP; Muqassa) and the depository (Edaa).

The results are visible in both the policy and the plumbing: relaxation of foreign ownership constraints in sensitive real estate exposures via listed routes, a consultation to open the main market to non-resident investors and the first regulated electronic bond alternative trading system (ATS) to standardise institutional trading. These steps are documented in Capital Market Authority (CMA) and exchange releases during 2024–25 and pave the way for issuers, intermediaries and foreign managers in the next 12–24 months.

How to Read This Article

Rather than itemise every rule change, this article focuses on three developments that will shape behaviour and capital flows:

• opening up the market – from eligibility to true usability;
• digitisation at scale – open banking, data/artificial intelligence (AI) guardrails and practical adoption; and
• financing the real economy through sukuk/bonds, ESG-linked products and retail savings.

Each section explains what is changing, why it matters commercially and what participants should do now.

Theme 1: Opening the Market – From Eligibility to Usability

Saudi policy is shifting focus away from eligibility towards how global capital can operate effectively in the market. The pivot is clear in three areas: direct access for non-resident investors, offshore servicing permissions for capital market institutions (CMIs), and trading/connectivity upgrades that institutionalise workflows and create less friction for international money.

Direct non-resident access and the sunset of swaps

On 1 October 2025, the CMA opened a consultation on draft amendments to remove the qualified foreign investor (QFI) gate for the main market and discontinue swap structures as the primary access tool for non-resident foreigners. This proposal would allow foreign investors to access the market without meeting qualification thresholds, replacing synthetic exposure with full ownership and voting rights. If the amendments are adopted, brokers and global managers will need to review their execution, corporate action and settlement arrangements as part of the move from swap books, and update their best execution policies accordingly.

Offshore securities business licence (OSBL) as a staging tool

In mid-2025, the CMA published a draft framework for an OSBL to permit CMIs to conduct defined securities business from within the Kingdom, on behalf of non-resident clients, subject to conditions and the regional headquarters (RHQ) regime. In practice, this would allow international firms to sequence entry – ie, to begin with offshore client coverage and distribution within OSBL parameters; add local execution/custody when trading volumes are sufficient; and then consider fuller onshore permissions to match resident clients directly. The consultation materials set out the service scope, authorisation features and compliance guardrails.

Real estate exposure in the holy cities: what has changed?

Since 27 January 2025, foreign investors can invest (up to 49%) in listed Saudi companies that own real estate within the boundaries of Makkah and Madinah. This expands equity exposure to those markets via listed vehicles, while restrictions on direct ownership remain, and fund-level participation continues to be governed by CMA circulars specific to investments in the holy cities. For equity and REIT specialists, this change increases the investable universe and indexability, while preserving the statutory protections relating to direct real estate ownership.

Connectivity and price formation

The first regulated bond ATS

In October 2025, Tradeweb disclosed its CMA approval to operate an ATS for local sukuk and debt instruments and announced the first electronic marketplace for Saudi Riyal–denominated (SAR) bonds under CMA supervision. For dealers and asset managers, an ATS standardises request-for-quote (RFQ)/streaming protocols, broadens counterparty reach and simplifies best-execution, especially when paired with CCP netting at Muqassa. The practical upside is better price discovery and more scalable workflows for local-currency fixed income.

Operational usability omnibus accounts (what has changed and why it matters)

In July 2025, Edaa (the Securities Depository Centre Company) introduced omnibus accounts for traded securities, following a similar roll-out for debt instruments in late 2024. The new framework allows a custody member to open a single account in a CMI’s name to hold securities for multiple underlying clients. According to Edaa, the objective is to enhance market attractiveness and operational efficiency for asset managers. In practice, the model supports more streamlined block trading and post-trade allocation while reducing administrative steps compared with investor-level segregated accounts. Investor protections remain in place under existing custody and regulatory frameworks, so the change increases efficiency without altering ownership rights or transparency.

Global context and investor implications

The omnibus model is standard in most mature markets, but its introduction in Saudi Arabia is a material change for cross-border managers. It allows global firms to replicate the operating models they use in Europe, the USA and Asia, reducing any friction caused by adding Saudi allocations to global portfolios. For domestic asset managers, it levels the playing field by giving them access to a tool that their international peers have come to expect. The broad effect is to make Saudi securities more index-friendly: international index providers and custodians can now treat holdings in a manner consistent with other emerging markets, which over time should support their inclusion in global benchmarks and help deepen passive flows.

Theme 2: Digital Rails, Data and AI Guardrails

Market stability and risk management

As Saudi Arabia’s markets become more integrated with global capital flows, stability safeguards are advancing in step with access reforms. Growing foreign participation, evolving settlement infrastructure and new financial instruments have led the CMA, Tadawul, Muqassa and Edaa to reinforce their risk-management and business-continuity frameworks. The focus now includes scenario testing, liquidity contingency measures and co-ordinated crisis-response planning across market institutions. Together, these initiatives show a market preparing for cross-border volatility and aligning its post-trade governance and technical standards with those of leading G20 peers.

Open banking moves from pilots to production

Saudi open banking has progressed beyond framework design. The Saudi Central Bank’s programme now supports both account information services (AIS) and, following its September 2024 release, payment initiation services (PIS). For brokers, asset managers and wealth platforms, this opens the prospect of moving funds via application programming interface (API) rails rather than card-based workflows, and of enhancing cash visibility via direct data links. These rails are now being viewed less as experimental and more as foundational infrastructure for onboarding, cash-flow top-ups and treasury sweeps.

PDPL: from policy drafting to live compliance

The Personal Data Protection Law (PDPL) has been fully enforceable since 14 September 2024, and compliance is now about operating discipline rather than paperwork. Financial institutions are expected to provide evidence of data mapping, localisation and lawful cross-border transfers, and to calibrate their procurement processes so that no new vendor is onboarded without the relevant safeguards. Legacy supplier contracts that touch Saudi personal data should be reviewed and updated, and product teams should work towards “data minimisation by design” as a default. The practical upshot is continuous monitoring and periodic reassessment, not a one-off remediation exercise.

Generative AI: proportionate model governance

Guidance from the Saudi Data & AI Authority moves generative AI from high-level principles to specific responsibilities. Organisations developing or deploying models should document pre-deployment testing for reliability and bias, record training data provenance and maintain role-based access controls with human oversight of client-facing outputs. In the context of banks and capital market institutions, this suggests a proportionate model risk framework that aligns research, client service and surveillance pilots with these expectations. The practical result is that experimentation may increase without compromising control standards.

Cross-border fintech partnerships

A striking feature of Saudi Arabia’s digital agenda is the emphasis on international interoperability. Open banking standards are being shaped in a way that aligns with Europe’s Payment Services Directive 2 (PSD2) and the UK’s Open Banking Implementation Entity (OBIE) frameworks, making it easier for global fintechs to port solutions into the Kingdom with minimal technical adaptation. At the same time, the PDPL’s localisation requirements mean firms must strike a balance: data can be shared through secure APIs for payments and aggregation, but hosting and processing obligations remain anchored in Saudi infrastructure.

For foreign institutions, this creates both opportunity and compliance work. The opportunity lies in scaling proven products, robo-advice, digital wallets and SME lending engines in a fast-growing market. The compliance work lies in structuring data flows, contractual safeguards and joint ventures to satisfy Saudi requirements without fragmenting global platforms. The result is that fintech growth in Saudi Arabia is both outward-facing and anchored in the sovereign control of data, a duality that international players must learn to navigate.

Fintech as a driver of inclusion and scale

Beyond infrastructure, digital rails are also expanding the reach of financial services. Open banking is enabling a wave of payment-fintech and savings apps that can connect consumers and SMEs directly to capital market products, while PDPL ensures that the personal data transferred is properly safeguarded. For international institutions, Saudi Arabia’s regulatory clarity on data and AI is an advantage: it reduces the uncertainty often found in emerging markets and allows firms to transplant their compliance frameworks with fairly modest localisation requirements.

The combination of new digital rails and firm guardrails means innovation can be scaled without undermining trust. For 2026, the clear challenge is integration: banks and CMIs must move beyond sandbox pilots and embed digital tools into their core business lines. That means treating API-based connectivity, consent management and AI oversight not as side projects, but as matters high on the agenda of mainstream risk, audit and product committees.

What to do now (2026 lens)

Recommendations include:

• treat account information services (AIS)/payment initiation services (PIS) as production infrastructure and embed them into funding and treasury workflows;
• align PDPL controls with procurement and vendor management so that localisation and transfer requirements are enforced contractually and in practice; and
• produce a concise AI governance playbook covering the testing of artefacts, audit trails and escalation paths, before scaling any client-facing use case.

These steps translate policy into usable capacity and reduce the need for reworking as volumes grow.

Theme 3: Debt, ESG-linked Finance and Retail Savings

Sukuk and bonds as primary channels

Saudi issuers increasingly treat the sukuk and bond market as a core financing route alongside bank lending, rather than a back-up option. The CMA’s strategic direction emphasises continued expansion of this market, particularly in the unlisted segment, and official FSDP reporting shows sustained growth since 2017, with a broader mix of sovereign, government-related entity (GRE) and corporate issuers returning to market. For treasurers, this means that documentation and familiar international standards are converging, investor outreach is deeper and more diversified, and execution windows are becoming more predictable across the curve. The practical upside is a clearer playbook for repeat issuance and liability management, with fewer one-off exceptions and faster approvals.

Sustainable formats are now mainstream

Green and sustainability-linked instruments are increasingly a feature of Saudi issuance. Issuers are aligning frameworks with International Capital Market Association (ICMA) principles and obtaining second-party opinions. The CMA’s Guidelines for Issuing Green, Social, Sustainable and Sustainability-Linked Debt create a de-facto “comply-or-explain” expectation for labelled SAR-denominated deals, and require disclosure of any non-compliance in the issuance framework or offering documents. In practice, transactions that prepare key performance indicators (KPIs) early, establish credible baselines and secure external reviews tend to be executed more smoothly through global accounts. At the same time, foreign participation in Saudi debt is growing (albeit from a low base) as the domestic market deepens.

Financing Vision 2030’s giga-projects

The clearest beneficiaries of Saudi Arabia’s deepening debt market include large-scale projects such as NEOM and Red Sea Global, which require multi-year funding lines in multiple currencies. Sukuk and ESG-labelled instruments have emerged as effective financing channels, blending Sharia compliance with sustainability frameworks recognised by global investors – for example, green sukuk issued by Saudi Electricity Company and green bond issuance by the Public Investment Fund (PIF) attracted strong international demand. On the policy front, the CMA’s Guidelines for Issuing Green, Social, Sustainable and Sustainability-Linked Debt set a de-facto “comply-or-explain” expectation for labelled SAR-denominated issuances, while the Saudi Exchange’s ESG disclosure guidelines for listed issuers remain voluntary. In practice, market participants say that issuers of labelled offerings now prepare disclosure documentation aligned with both the domestic rules and global best-practice frameworks; investors, in turn, gain regulated access to major development programmes through instruments increasingly structured to match international ESG norms.

Retail savings deepen the base

The National Debt Management Center’s “Sah” savings sukuk adds a durable retail leg to the investor base. Regular subscription windows and clearly communicated terms give individuals a simple government-backed savings product, while helping to anchor local liquidity throughout the cycle. For banks and wealth platforms, integrating Sah into default savings journeys improves rate transparency, encourages disciplined saving and broadens domestic participation beyond institutional buyers. Over time, this retail layer supports secondary-market resilience and complements institutional demand for new issues.

Linking retail to market depth

Retail participation through Sah has significance beyond personal savings. It anchors local liquidity in government securities, creates a predictable bid for sovereign issuance, and establishes an investor base that can graduate over time to corporate sukuk and equity markets. By familiarising individuals with investment products, pricing mechanics and redemption cycles, Sah contributes to a more financially literate population and a healthier demand stack for capital markets.

Over the medium term, retail savings products can also act as stabilisers. In periods of global volatility, a consistent domestic bid from households provides ballast against outflows from international investors. For policymakers, this is an important complement to the CMA’s efforts to attract foreign capital: the stronger the domestic base, the more resilient the market is to global shocks.

What to do now (2026 lens)

Issuers should design sustainability-linked KPIs and verification pathways at the start of the transaction, treating them as core terms, not add-ons, and should consider a dual-track approach (listed and unlisted) to balance speed and pricing. Distributors and arrangers can deepen international coverage for SAR credit while building retail participation by embedding Sah into client journeys and nudging reinvestment at maturity. The result is a healthier demand stack for global institutions, local professionals and retail savers, which lowers execution risk and is in line with the current trajectory of policy and investor appetite.

Conclusion: what’s next?

Saudi Arabia’s financial reforms have moved from “opening the doors” to ensuring that the market is genuinely usable. The next phase will be about execution: operationalising direct access for foreign investors, embedding digital rails into day-to-day finance, and turning retail savings into a permanent feature of the demand base. The Kingdom’s regulators have shown they are willing to match international standards in settlement, disclosure and data protection, while retaining Saudi control in areas such as real estate exposure and AI governance.

For corporates, the message is to prepare early: governance, disclosure and sustainability metrics should be built into strategy before seeking capital. For financial institutions, the imperative is to align global policies with Saudi-specific rules, particularly in data, ESG reporting and product governance. For investors, the opportunity is clear: Saudi Arabia is no longer a closed or frontier market, but a jurisdiction aligning itself with global practice at speed. As Vision 2030 enters the final stretch, the Kingdom is positioning itself as a financial hub where foreign capital, domestic innovation and long-term savings meet.