Kuwait's New Bank Customer Protection Guide: What Boards and Treasury Teams Must Do Before April 2026

The Central Bank of Kuwait's Circular No. 2/RB/RBA/619/2026, issued on 26 March 2026, alongside the updated Bank Customer Protection Guide, marks the most consequential overhaul of Kuwait's retail and commercial banking conduct rules in over a decade. The Guide must be fully implemented across all locally incorporated banks by April 2026, with several knock-on obligations for corporate borrowers, fintech partners, and any business that processes payments through a Kuwait-licensed institution.

Three Changes That Demand Immediate Attention

1. Complaint response window cut from 15 to 5 working days. Any customer-facing entity — bank or otherwise — that routes complaints through a Kuwaiti bank must align its internal SLAs accordingly. Boards should expect the regulator to test this metric in supervisory reviews.

2. Mandatory APR disclosure across every credit product. The Annual Percentage Rate must now appear in standardized form on every consumer credit instrument, including credit cards and personal loans. For corporate finance teams, this changes how loan facilities are marketed and how comparison disclosures are drafted in offer letters.

3. Capital adequacy and liquidity adjustments. The same circular tightens prudential ratios while creating temporary breathing room for credit flow in light of regional geopolitical pressure. Treasury teams structuring revolving facilities or syndicated loans should re-model covenants against the new floors.

What This Means for Businesses Operating in Kuwait

For Kuwaiti corporates: existing credit facility documentation entered into before March 2026 should be reviewed for upcoming interest rate disclosures, refinancing windows, and consent clauses. Pricing terms negotiated under the old regime may no longer comply.

For foreign companies with Kuwaiti banking relationships: customer protection obligations now flow through to your local payment processors. Service agreements with Kuwaiti banks should be revisited to confirm who carries liability for the 5-day complaint window when disputes touch your end-customers.

For fintechs: APR disclosure rules will reach embedded finance products by extension. Anyone offering buy-now-pay-later, instalment plans, or revolving credit through a Kuwaiti bank partner will need standardized rate disclosures in their UX.

WEFAQ's Recommended Action Before the April Deadline

We advise reviewing three documents before implementation: (i) standard customer terms and conditions, (ii) any banking-as-a-service or referral agreement with a CBK-regulated institution, and (iii) board-level risk policy on consumer credit. Where existing facility agreements include APR-related representations, an amendment letter is typically sufficient; where the customer flow is more complex, a structural review may be warranted.