Kuwait CMA Registered Persons: The Eleven Positions, the PQP and the 30-Hour Figure That Is Not Yours

Kuwait regulates who may hold senior and client-facing roles in a licensed financial firm through eleven named Registered Employment Positions, a Professional Qualification Programme with a hard phase-in date, and a continuing professional development programme that exists in the bylaws by cross-reference. There is also a thirty-hour CPD figure circulating about Kuwait that applies to a completely different population.

This guide works through Module Five (Securities Activities and Registered Persons) of the Executive Bylaws of Law No. 7 of 2010 and the Capital Markets Authority's Professional Qualification Programme pages.

Two caveats before the detail

First, the English Module Five carries an unusually blunt disclaimer. The translation is "provided solely for reference", "may be used for guidance but not for legal purposes", and "Only the Arabic original shall be considered for legal proceedings and legal actions before the competent courts of jurisdiction". The CMA adds that it "shall not be responsible for any mistake, error and/or misinterpretation". Everything below should be checked against the Arabic.

Second, the document has no single version statement. Its cover reads January 2025, its page stamps run from November 2015 to August 2026, and its file name carries a 2026 revision reference. Confirm you are working from the current issue.

The eleven Registered Employment Positions

Article 3-2-2 lists them:

1. Chief Executive Officer
2. Senior Executive
3. Financial Manager
4. Risk Management Officer
5. Internal Audit Officer
6. Sharia Audit Officer, for persons licensed to operate in accordance with Islamic Sharia principles
7. Compliance Officer
8. Representative of Securities Activities — with sub-items (a) to (n), each a representative of a named activity, such as a securities broker registered in a securities exchange, or a collective investment scheme manager's operations officer
9. Senior Investment Advisor
10. Senior Asset Valuator
11. "Any other Employment Positions that the Authority deems are Registered Employment Positions"

Separately, Article 3-2 states that membership of the board of directors of a Licensed Person "is considered a Registered Position" — a distinct concept from a Registered Employment Position, and worth not conflating.

Three hard operational rules

These are the provisions most likely to catch a firm out, and all three are verbatim:

• No practising before approval. "Individuals are prohibited from practicing any registered job until the Application for Registration has been approved by the Authority." There is no interim or acting route in the article
• Vacancies have deadlines. Where a Registered Employment Position falls vacant, the Licensed Person "shall fill the vacancy within a period not exceeding six months" — and for the CEO, "a replacement shall be appointed within a period not exceeding one year"
• Renewal failure cancels automatically. The Licensed Person must submit the renewal "not later than one month before the end of the registration period". If it does not, "the registration of the individual registered in that job shall be cancelled automatically." No notice, no grace period, no discretion

That last one is the sharpest administrative risk in the module: a missed diary date removes a person's registration, and under the first rule they may then not practise.

Qualifications: the PQP and where its detail sits

Article 3-3-1(3) requires a candidate to "Pass the qualification examinations as determined by the Authority in the Professional Qualifications Program", and Article 3-3 says "Appendix 3 of this Module includes the qualifications, the requirements set in Professional Qualifications Program and the experience required of each Candidate."

Article 3-3-3 is the enabling power: the Authority "may take all necessary procedures to verify the technical and professional abilities that qualify a candidate for Registered Employment Positions, including setting the necessary rules and conditions and passing qualification exams set by the Authority as specified in the Professional Qualifications Program and the possibility of holding an interview".

The CMA describes the programme's purpose as being "intended to raise the level of professional competence, technical ability and legal knowledge of those occupying the Registered Employment Positions of Licensed Persons through professional education and qualifications examinations", and says it "represents a main part of the Fit and Proper Rules".

An access problem worth knowing about. The programme "consists of three different qualifications", and the table naming them and setting out how mandatory each is is published as an image on the CMA's site rather than as text. The CMA's Professional Qualifications Matrix page returned a server error when accessed. And the Appendix 3 body — the position-by-position mapping of qualifications and experience — is not present in the extractable text of the Module Five PDF. So the three qualification names and the per-position requirements have to be obtained from the CMA directly or from the Arabic original. This guide does not state them rather than guessing.

The phase-in, which has now closed

The CMA ran the PQP in two stages, and the dates still matter for anyone assessing a long-serving registrant:

• Preliminary phase from 1 October 2019. Persons already registered were "exempted from the PQP ... within two years from the date of the preliminary implementation phase"
• Applications submitted between the phases were exempt "until renewal for their registration ... where passing the technical and regulatory qualifications becomes a condition for renewing the registration"
• Mandatory phase extended to 1 October 2021. From then, "The PQP is mandatory for applicants who submit an application for nomination or registration", so passing becomes a condition of applying

The practical effect is that the qualification requirement now bites at two moments: on application, and on renewal for those who came in under the transitional exemption.

Exemptions and equivalence

The CMA "has set a policy of exempting from the requirements of the PQP for Registered Employment Positions for holders of certain recognized professional certificates and those possessing specific years of experience", by reference to Appendix 3. As with the qualifications table, the determinants are published as an image.

Two experience provisions are in the bylaw text itself:

• CEO and Senior Executive — "exempted from the requirement of experience in a financial or banking institution, if the applicant has acquired at least 7 years of experience in a company whose main activity is in the area of consulting or asset valuation"
• Sharia Auditor — must meet the qualifications for Sharia Auditing Officer in Appendix 3, "provided that the experience of the Sharia Auditor shall not be less than five years in Sharia Auditing"

There is also a broad institutional power: the Authority "may exempt the Licensed Person from the requirements of Registered Positions and Employment Positions stated in this Module, or impose additional conditions, in accordance with the type of activity to be licensed".

CPD: it exists, and its content is in Appendix 28

The bylaw creates the obligation by cross-reference. The fit-and-proper article states: "The person registered in Registered Employment Positions shall comply with the Continuous Professional Program for persons registered in Registered Employment Positions as set forth in Appendix (28) of this Module." The contents page titles Appendix 28 "The Continuous Professional Development (CPD) Program for Registered Persons in Registered Employment Positions".

So a CPD obligation exists and is mandatory for everyone in the eleven positions. Its hours, period, qualifying activities, recording and reporting are all in Appendix 28, whose body is not present in the extractable text of the published English PDF. This guide does not state figures it could not read.

And here is the trap. There is a thirty-hour figure in Module Five, and it does not apply to registered persons. Article 3-4-2, item 8 requires "at least thirty hours per year for the members of the review and audit team" — an obligation on external auditors, repeated in the annual report requirement at Article 3-4-5. Anyone citing "30 hours CPD in Kuwait" for a compliance officer or a securities representative is quoting the auditor provision.

Consequences

The module does not attach a specific sanction to a CPD or qualification failure. It relies on the general fit-and-proper mechanism: "If any of the conditions of fit and proper rules ceases to exist, the Authority may cancel or suspend the registration of the Registered Person and it may re-register such person in the event that such conditions are met." Article 3-1-2 adds a general power to cancel the registration of any Registered Person "in the event of not fulfilling the conditions and provisions related to their work".

Note that re-registration is expressly contemplated once conditions are met, which is more forgiving than the Japanese revocation chain and less automatic than Kuwait's own renewal rule.

No record-keeping or retention requirement for registered persons appears in the extractable text. The absence provision at Article 3-2-16 deals with authorising a deputy, not with CPD relief.

On examinations and training providers

The CMA names CISI in connection with the programme. Two points from the CMA's own page are worth knowing if you are buying training: CISI "does not offer training" and instead "accredits external partners", and "The training for any of the qualifications in the PQP is optional rather than mandatory" — it is the examination that is required, not attendance at a course.

Three things to check

First, your renewal diary. One month before expiry, or the registration is cancelled automatically.

Second, whether anyone registered under the transitional exemption has since renewed — because passing the qualifications became a renewal condition.

Third, that nobody in your firm is planning against the thirty-hour auditor figure as though it were the registered-persons CPD requirement.

Among the Gulf regimes, Bahrain publishes its 15 CPD hours and seven record categories in the rulebook itself, while Kuwait places the equivalent detail in an appendix and an image. Our guide to the UAE Central Bank's CPD and training plan requirements covers the third of the three. Structured CPD programmes can serve the Appendix 28 obligation once its terms are confirmed with the CMA.

Sources and limits: written from the English translation of Module Five (Securities Activities and Registered Persons) of the Executive Bylaws of Law No. 7 of 2010, and the Kuwait CMA's Professional Qualification Programme, implementation, exemption policy and CISI pages, all read in October 2026. The CMA states the translation is for reference only and that the Arabic original governs. Appendix 3 and Appendix 28 are listed in the contents but their bodies are not in the extractable text of the published PDF, and the CMA's qualifications matrix page returned a server error — so the three PQP qualifications, the per-position qualification and experience requirements, and all CPD hours, periods and reporting rules are deliberately not stated here. General information about published rules, not legal or compliance advice.