Islamic Finance Accounting 2026: AAOIFI vs IFRS — What UAE CFOs Must Change
2026 marks the year Islamic financial institutions must speak multiple accounting and regulatory languages at once.
As IFRS, AAOIFI, CBUAE, and ESG frameworks converge, CFOs can no longer rely on single-framework reporting models.
The landscape has shifted from optional alignment to mandatory multi-framework fluency.
Islamic Finance Accounting 2026 moves from conceptual debate to operational reality. IFRS 18’s new performance presentation requirements come into force in 2027, with retrospective comparatives required, meaning Islamic banks must rebuild their internal reporting structures now.
At the same time, AAOIFI’s FAS 43 overhauls Takaful accounting starting 2025, while draft Shari’ah Standard 62 is already influencing sukuk structuring decisions before its final release.
In addition, the UAE Federal Decree Law 2025 finance restructures the supervisory architecture of the UAE financial system and elevates the Shari’ah Compliance Function UAE to a formal control function.
This convergence creates a reporting ecosystem where no single framework dominates.
Instead, CFOs must produce, defend, and reconcile multiple valid representations of financial performance — each required by regulators, auditors, boards, investors, and Shari’ah committees.
New Supervisory & Shari’ah Governance Architecture
Before considering accounting standards, CFOs must understand the regulatory environment that oversees and tests them. The 2025–26 governance reforms tie financial reporting, risk management, and Shari’ah oversight together in ways that materially reshape institutional control frameworks.
Federal Decree-Law No. 6 of 2025: The Consolidated Supervisory Perimeter
The new CBUAE law replaces historically segmented oversight with a unified supervisory environment covering banks, insurers, Takaful operators, fintech entities, virtual-asset intermediaries, money service businesses, and digital service providers.
For Islamic institutions, this consolidation is profound. Previously, accounting, Shari’ah governance, risk, and compliance functions could operate semi-autonomously. The new regime eliminates those silos.
Prudential reporting, Shari’ah controls, governance expectations, financial disclosures, and risk frameworks must now align across the entire group.
CFOs need integrated systems capable of reconciling Shari’ah-aligned treatments under AAOIFI, prudential expectations under CBUAE rulebooks, and statutory obligations under IFRS. Partial alignment is no longer viable in an environment where regulation explicitly connects governance failures with financial reporting weaknesses.
A New Enforcement Environment
Regulatory change is no longer just a future risk.
The CBUAE is now carrying out deeper reviews, shortening inspection cycles, and moving quickly from identifying issues to requiring formal fixes.
Penalties are no longer limited to financial fines — reputational impact is also becoming a real concern. Regulators expect institutions to show clear, well-documented remediation plans supported by testing and internal reviews.
This means CFOs can no longer rely on reactive compliance. Waiting for supervisory findings before acting is no longer sufficient. Instead, institutions must design controls in advance and maintain forward-looking remediation plans that connect governance, finance, and compliance functions to regulatory expectations — well before inspections begin.
Shari’ah Compliance Function as a Second-Line Control
Under the updated Shari’ah governance rules, the Shari’ah Compliance Function is no longer just an advisory role. It is now a formal control function with clear oversight responsibility.
This changes how accountability works across the organisation.
Business teams are expected to spot and report any issues that could affect Shari’ah compliance. Finance teams must build Shari’ah checks directly into day-to-day accounting processes, rather than treating them as a separate review. Internal audit is also expected to test Shari’ah controls with the same level of seriousness as financial and regulatory controls.
As a result, Shari’ah compliance is no longer separate from financial reporting. It directly affects how income is recorded, how non-permissible income is handled, how profits are calculated and distributed, and how financial information is presented. These are all areas that now sit firmly within the CFO’s responsibility.
Automation of NSCI, Purification, and Shari’ah Audit Trails
Non-Shari’ah-compliant income should not be tracked using manual spreadsheets. Institutions need automated systems that can clearly identify income that may not be Shari’ah-compliant, spot contract issues, flag missed purification entries, and record any system overrides.
Purification processes must be fully traceable. Each entry should show when it was made, why it was required, and who approved it. This ensures that the process can be reviewed and verified at any time.
Every Shari’ah-related decision, whether it is an exception, an internal judgement, or a ruling by a Shari’ah committee, must be recorded properly. These decisions should be clearly linked to the related accounting entries and show how they affect distributable profit, AAOIFI UAE. This clarifies and makes transparent the link between Shari’ah oversight and financial reporting.
CFO Action Points for New Supervisory & Shari’ah Governance Architecture
The Federal Decree-Law No. 6 of 2025 introduces a unified regulatory framework that consolidates oversight for banks, insurers, Takaful operators, and other financial entities under the CBUAE.
CFOs need to ensure that financial reporting, Shari’ah governance, and compliance functions are aligned with the new supervisory environment and to prepare for enforcement and audit requirements proactively.
- CFOs should review and upgrade their reporting systems to handle IFRS requirements, AAOIFI treatments, and regulatory reporting across the group. This helps remove silos and ensures financial and compliance information flows smoothly under the CBUAE’s unified framework.
- Governance and compliance should work as one. Shari’ah oversight, prudential reporting, and financial disclosures need to be aligned to eliminate gaps, overlaps, or inconsistent practices that could raise regulatory concerns.
- CFOs also need to prepare for audits and inspections in advance, rather than reacting after issues are identified. Simple monitoring processes should be in place to spot potential compliance or governance issues early and address them before CBUAE reviews.
- Clear remediation plans should already exist for likely risk areas. This allows issues to be fixed quickly if needed and reduces the risk of penalties or reputational damage during regulatory reviews.
- Finally, Shari’ah controls should be built directly into everyday accounting processes. Teams should be able to identify and report Shari’ah-related issues; internal audit should test these controls regularly; and systems should automatically track non-Shari’ah-compliant income and purification entries, so all decisions are properly recorded and reflected in profit calculations under AAOIFI.
By taking these steps, CFOs will be well-positioned to meet the CBUAE’s increasingly stringent regulatory expectations, ensuring proactive compliance while maintaining strong Shari’ah governance and financial reporting integrity.
The Multi-GAAP Reporting Stack
2026 forces institutions to recognize that Islamic financial performance cannot be expressed through a single accounting lens. IFRS, AAOIFI, and CBUAE rulebooks each produce legitimate but different views of the same business.
The role of the CFO is to harmonize, explain, and reconcile these views without diminishing their distinct purposes.
A Reporting Environment with No Single “Truth”
Islamic institutions must simultaneously comply with:
- IFRS, for statutory and investor reporting
- AAOIFI, for Shari’ah-aligned financial treatment and profit-allocation logic
- CBUAE supervisory standards and governance expectations
- ISSB and sustainability disclosure frameworks, where climate and ESG factors intersect with Islamic finance ethics
This requires multi-tag ERP systems, modular reporting engines, and governance structures that can support multiple interpretations of the same transaction.
IFRS 18 and the Reconstruction of Islamic Bank Reporting
IFRS 18 introduces three mandatory subtotals: operating profit, profit before financing and income taxes, and profit or loss, while imposing strict classification rules across operating, investing, financing, tax, and discontinued categories.
For Islamic institutions, this reshapes how Murabaha income, Ijarah structures, Mudaraba returns, and sukuk portfolios are positioned within the income statement. Some Islamic products differ from their conventional counterparts, requiring judgment and documentation to justify categorization.
This classification determines how external stakeholders interpret performance, affecting cost-of-funds metrics, efficiency ratios, margin analysis, and the visibility of Islamic financing structures.
IFRS 18 is not merely a presentational change; it is a narrative reset.
Management Performance Measures and the Distributable-Profit Debate
IFRS 18 also requires Management Performance Measures (MPMs), including those derived from Islamic structures, to be reconciled with IFRS subtotals. This is especially significant for Islamic institutions where:
- Profit-sharing pools
- PER/IRR mechanisms
- Smoothing techniques, and
- AAOIFI-defined distributable-profit policies
CFOs must now provide transparent bridges explaining how internal AAOIFI-aligned performance measures relate to IFRS results — a core friction in AAOIFI vs IFRS UAE reporting.
Takaful Reporting Under FAS 43 and IFRS 17
AAOIFI’s FAS 43 requires Takaful funds to be kept separate and clearly explains how Qard Hasan works and how operators should record their income through Wakala fees and Mudarib shares. This approach follows Shari’ah principles but differs from IFRS 17, which may require participant funds to be included in the group financial statements when control exists.
Because of this difference, CFOs need to maintain two views of the same business: one set of records for AAOIFI and Shari’ah reporting, and another for IFRS group reporting. To do this properly, finance systems must be able to handle both treatments simultaneously without errors or loss of control.
The End of the IFRS 9 Prudential Filter
As the UAE removes the prudential adjustment for IFRS 9, credit losses now fully impact regulatory capital. This means changes in expected credit losses will directly affect CET1 capital.
For Islamic institutions, this creates a challenge because IFRS 9 and AAOIFI FAS 30 look at risk differently. IFRS 9 focuses on how cash flows behave, while AAOIFI FAS 30 looks at the economic sharing of risk.
Because of this, sukuk, profit-sharing contracts, and other Islamic financing arrangements may yield different impairment results under each framework.
As a result, there can be noticeable differences between IFRS profit, distributable profit under AAOIFI, and regulatory capital figures.
CFOs must clearly explain these differences and show how each number is calculated.
Sukuk, Balance Sheets & Draft AAOIFI Standard 62
Sukuk structures are undergoing a structural re-evaluation as Standard 62 pushes the market toward genuine asset backing. This has immediate implications for derecognition, consolidation, SPPI outcomes, and investor expectations.
A Turning Point in Sukuk Design
Draft Shari’ah Standard 62 shifts the definition of Shari’ah-compliant sukuk from asset-based exposure toward enforceable, beneficial ownership of underlying assets.
This introduces new expectations on legal transfer, risk allocation, and asset-backed substance. Some jurisdictions may struggle with asset-transfer laws, creating fragmentation, but the trend is clear: sukuk must demonstrate genuine risk transfer, not merely formal arrangements.
Issuer Accounting Under the New Regime
For issuers, sukuk structures must now be evaluated against IFRS derecognition and consolidation tests. Asset-backed arrangements may satisfy IFRS criteria for derecognition, but structures that retain significant risks and rewards will continue to be consolidated.
Accounting outcomes, therefore, depend not only on legal form but on the economic reality of risk transfer — a central question where AAOIFI expectations and IFRS principles intersect.
Investor Classification and SPPI Outcomes
On the investor side, asset-backed sukuk may fail IFRS 9’s SPPI test, pushing them into Fair Value Through Profit or Loss (FVTPL) and introducing measurement volatility.
This marks a departure from the traditional amortized-cost treatment and further intensifies the differences between IFRS 9 and AAOIFI’s FAS 30 impairment models. This divergence demands dual-model tracking and transparent classification policies.
The Practical Market Adjustment (2025–2027)
Issuers are already redesigning sukuk documentation, involving legal, Shari’ah, IFRS, and AAOIFI specialists from the earliest structuring stages.
Rating agencies are signaling that more equity-like structures will require enhanced disclosure and may fall outside traditional fixed-income mandates.
CFOs need to look at sukuk as more than just funding instruments. Each structure affects financial reporting, capital ratios, disclosures, investor messaging, and how credit risk is viewed.
To manage this, CFOs should review the existing sukuk portfolio, understand the true economic substance of each structure, test how outcomes differ under IFRS and AAOIFI, and ensure Shari’ah decisions are clearly reflected in accounting results.
Although Sukuk Standard 62 is not yet final, it is already influencing how sukuk are structured and reported, and CFOs need to prepare now.
Digital Assets, Tokenisation & ESG
Digital finance and sustainability sit firmly inside the supervisory perimeter. CFOs must now evaluate digital instruments and ESG-linked structures with the same rigour applied to sukuk and Takaful reporting.
- Article 62 and the Expansion of the Regulatory Perimeter
Article 62 of the new CBUAE law formally brings digital-asset activities, including tokenised financial instruments, virtual-asset payments, digital platforms, wallets, and DeFi systems, within the scope of regulated financial services.
Islamic institutions must determine whether their digital initiatives constitute regulated activity and how these innovations intersect with Shari’ah and IFRS requirements.
- Digital Custodianship and Shari’ah-Screened Digital Products
Digital custodians must demonstrate asset segregation, secure key management, and reserve validation. For Islamic institutions, Shari’ah screening introduces an additional layer of due diligence, particularly where digital rights resemble underlying financial claims.
- Multi-Framework Valuation Challenges
Under IFRS, digital instruments are usually treated either as intangible assets or as financial assets, depending on what rights they give to the holder.
Under AAOIFI, the treatment differs depending on whether the instrument is Shari’ah-compliant and how risk is shared.
Tokenised sukuk brings these two worlds together by combining sukuk structures with blockchain-based records. Because of this, CFOs need valuation systems that can track price changes under IFRS while also showing how income, profits, and losses are treated under AAOIFI rules.
- ESG-Linked Sukuk and ISSB Disclosures
ESG-linked sukuk often include conditions or performance targets that can change how and when cash is paid. Under IFRS 9, this can affect how these sukuk are classified and may increase volatility in reported results. With the prudential filter ending, any climate-related adjustments can now directly impact capital levels.
At the same time, new sustainability reporting requirements require institutions to clearly explain how climate risks are managed, how transition plans are designed, and how ESG features align with Islamic finance principles.
Clear documentation is now essential to demonstrate to regulators, investors, and Shari’ah stakeholders how these structures work and how risks are managed.
- Digital Asset Governance Requirements
CFOs must implement fair-value controls, chain-of-custody audit trails, Shari’ah substantiation for digital instruments and multi-GAAP asset registers to maintain regulatory and Shari’ah credibility.
The CFO’s 2026 Roadmap — From Compliance to Translation
Compliance with individual standards is no longer enough.
CFOs must orchestrate a transformation program that harmonizes frameworks, systems, people, and disclosure practices into a unified financial narrative. This transformation includes aligning Islamic Finance Accounting 2026 practices, bridging the gap between AAOIFI vs IFRS UAE, and ensuring comprehensive compliance with Shari’ah and IFRS requirements.
Phase 1: Diagnostic Assessment
The diagnostic phase helps CFOs clearly understand all reporting and regulatory requirements that apply to Islamic finance in the UAE. This includes statutory reporting under IFRS 18 Islamic Banks, Shari’ah-based requirements under AAOIFI standards, CBUAE regulatory rules, and Takaful consolidation models.
At this stage, CFOs need to assess how operating profit will be defined and presented for Islamic banks under IFRS 18, review sukuk structures using SPPI and consolidation tests, and evaluate Takaful entities under FAS 43 vs IFRS 17. They should also prepare a clear AAOIFI vs IFRS UAE gap analysis to show where accounting treatments differ.
This work helps quantify the scale of change, plan resources properly, and ensure the institution is ready to manage Islamic Finance Accounting 2026 in a multi-framework reporting environment.
Phase 2: Systems Architecture
A modern finance stack must accommodate multi-framework reporting, including multi-tag ERP systems, automated NSCI and purification workflows, dual-ledger capability for Takaful and sukuk, and modules that support tokenised sukuk accounting and other digital-asset treatments.
Without system automation, institutions will not meet supervisory expectations under the UAE Federal Decree Law 2025 on finance or ensure compliance with the Shari’ah Compliance Function in the UAE. Building a system architecture that supports these diverse frameworks is crucial to maintaining compliance and operational efficiency.
Phase 3: Communication & Disclosure
CFOs must unify their reporting voice.
This includes producing IFRS–AAOIFI bridge statements, explaining sukuk structures and their classification logic, and articulating how IFRS 9 provisioning (post-prudential filter) affects CET1 and profit-distribution policies.
The narrative must be coherent across analysts, boards, regulators, and Shari’ah scholars. Establishing a consistent communication strategy will help avoid confusion and misinterpretations while aligning with the UAE CFO’s Islamic finance compliance standards.
Phase 4: Talent & Capability Development
Finance teams require hybrid expertise in IFRS 18, AAOIFI, sukuk structuring, digital-asset treatment, and Shari’ah governance.
CFOs must transition from number-reporters to financial translators, professionals who can interpret multiple frameworks into a single enterprise strategy. As Sukuk Standard 62 and FAS 43 vs IFRS 17 Takaful evolve, developing talent to bridge the gap between Shari’ah and financial reporting will become increasingly critical to ensuring compliance with these standards.
Where Taxadepts UAE Fits In
Institutions navigating today’s regulatory convergence need more than technical advice; they need a partner that can see the full picture. ADEPTS UAE brings together accounting, regulatory, and Shari’ah expertise in one integrated advisory platform, helping Islamic financial institutions move from compliance pressure to strategic clarity.
We support CFOs and boards across the full lifecycle of Islamic Finance Accounting 2026 — from aligning IFRS and AAOIFI frameworks to preparing for IFRS 18, navigating FAS 43 vs IFRS 17 for Takaful, and assessing the practical impact of Sukuk Standard 62 on balance sheets and disclosures.
Our teams work closely with management to translate complex standards into clear reporting structures, defensible accounting positions, and regulator-ready documentation.
Beyond standards implementation, ADEPTS helps institutions stay ahead of supervisory expectations under the UAE’s evolving regulatory framework.
This includes compliance diagnostics under Federal Decree-Law No. 6 of 2025, SPPI and consolidation assessments for sukuk, ESG and ISSB integration, and advisory support for emerging areas such as digital assets and tokenised Islamic instruments.
What sets ADEPTS apart is not just technical depth, but execution. We bridge theory and practice, aligning accounting outcomes with Shari’ah governance, regulatory expectations, and board-level decision-making — so CFOs can report with confidence, defend positions under scrutiny, and lead through change.
Conclusion
2026 marks a defining shift for Islamic finance in the UAE. CFOs are no longer simply responsible for compliance under individual standards; they are now required to act as financial translators, aligning IFRS 18, AAOIFI requirements, CBUAE supervisory expectations, sustainability reporting, and evolving sukuk structures into one coherent financial narrative.
Institutions that invest early in strong reporting architecture, integrated governance, skilled finance teams, and clear communication will be better positioned to manage scrutiny, explain outcomes, and maintain stakeholder confidence.
In this environment, compliance is no longer just a regulatory obligation — it becomes a source of credibility, resilience, and long-term competitive advantage.
FAQs:
It’s the overlap of three frameworks at once: updated IFRS rules, evolving AAOIFI standards, and tighter CBUAE supervision. None fully replaces the others, so CFOs must express one financial reality through multiple reporting lenses at the same time.
The law strengthens the regulatory perimeter and expects clearer accountability for Shari’ah-aligned activities. It doesn’t redefine Shari’ah governance, but it elevates expectations around oversight, documentation and financial reporting discipline.
CFOs will need tighter audit trails, clearer segregation of Shari’ah-sensitive transactions, and more coordinated workflows between Finance, Risk and SCF teams. The mandate essentially formalises practices that were already becoming necessary.
IFRS 18 introduces a standardised “operating profit” subtotal and highlights management-defined performance measures, making Islamic banks’ core earnings more visible. Because it also brings finance costs and profit-sharing effects into focus, CFOs need to prepare early.
These contracts don’t always behave like conventional interest-based instruments, so mapping their returns into IFRS 18’s subtotals requires judgement. The challenge is aligning economic reality with the new presentation rules without misrepresenting performance.
FAS 43 keeps participant and shareholder funds strictly separate, while IFRS 17 and consolidation rules often pull them back together. This creates two valid views of the same business that CFOs must reconcile.
Because each framework treats fund boundaries differently, one ledger cannot serve both purposes. Dual-view reporting avoids conflicts between Shari’ah-aligned statements and IFRS group requirements.
Stricter asset-backing may shift risks away from the issuer and toward investors, which can affect balance-sheet recognition, collateral requirements and rating assumptions. The risk isn’t negative by default — but it does require careful structuring.
Tawarruq provides a structure that is easier to align with ownership and transfer requirements while avoiding some asset-transfer hurdles. As standards tighten, issuers may favour structures that are simpler to defend.
Capital ratios will reflect full expected-credit-loss movements with no add-backs. This makes provisioning decisions more visible and increases sensitivity to model changes.
FAS 30 looks at risk-sharing economics, while IFRS 9 focuses on cash-flow characteristics and SPPI rules. This means a contract may be compliant under AAOIFI yet still fall into a different IFRS measurement category.
Their classification depends on both financial rights and Shari’ah character. Without clear documentation, valuation and recognition can become challenging under both IFRS and AAOIFI.
Because the two frameworks allocate income and impairment differently. A bridge statement prevents misunderstandings by showing how each number is derived.
MPMs must now be disclosed consistently and reconciled to IFRS figures. Auditors will review how they are defined, calculated and used — especially when linked to Shari’ah-based distribution models.
Teams need blended IFRS–AAOIFI expertise, stronger Shari’ah coordination, and systems that support dual-ledger reporting and digital-asset classification. The capability gap is now a strategic issue, not an operational one.
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