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On 3 June 2025, the Saudi Capital Market Authority published the cross-border passporting guide for investment funds, Passporting Guide. The Passporting Guide lays down guidelines for cross-border passporting and promotion in the Kingdom of Saudi Arabia, KSA, of investment funds registered in any Gulf Cooperation Council, GCC, country, GCC funds. The Passporting Guide, alongside the cross-border passporting regulations for investment funds, regulations, and the regulatory framework for the passporting of financial products between the regulators of financial markets in GCC states, are aimed at establishing a uniform framework under which fund managers of GCC funds may promote and offer investment funds to investors in the KSA through their agents. Additionally, the passporting guide and regulations detail how fund managers in the KSA can apply through the CMA for cross-registration in another jurisdiction within the GCC to promote and offer investment funds in that jurisdiction. Scope of application. The passporting guide and the regulations expand investors' access to investment fund offerings across the GCC through a passporting process for cross-registration of funds between the financial market regulators in the GCC states. Fund managers of GCC funds can rely on the passporting guide and the regulations to access the Saudi market more conveniently, using their registration with their home jurisdictions regulator, registered regulatory authority, as the basis for applying for cross-registration with the CMA, Host Regulatory Authority, for fund managers of KSA registered funds seeking access to other GCC jurisdictions. The CNA acts as the registered regulatory authority, while the target jurisdiction's equivalent regulatory authority serves as the host regulatory authority. The passporting framework provides an alternative process for offering units of foreign funds registered in GCC countries in the KSA without having to comply with the provisions that would otherwise be applicable to offering foreign funds under the investment funds regulations. Key provisions, simplified application procedure, fund managers of GCC funds wishing to cross-register with the CAMA can apply to the registered regulatory authority in their home jurisdiction, ensuring they meet the minimum standards set out in Annex 1 of the regulations. Upon completion of all required information and documents, the registered regulatory authority must decide on the application within 10 business days from the date of submission. Upon approval, the registered regulatory authority notifies the CMA and shares the fund documents and other required documentation. The CMA must then decide on the application within 10 business days of receiving the notice. If approved, both the CMA and the registered regulatory authority will publish the fund's name in their respective registers. The same process can be used to register funds with multiple host regulatory authorities across the GCC member states. Fund managers should note that a host regulatory authority may refuse registration where it considers this would prejudice national or public interest or breach applicable local law. Disclosure package and Arabic requirements. The fund document must be provided as part of the cross-border filing and must include the regulators' disclaimer language required by the minimum standards and must be available in the Arabic language. If the fund is a public fund, an Arabic summary of the fund document is required as part of the submission. Cross-registration of KSA registered funds. Fund managers of funds established and registered in the KSA can apply for cross-border passporting by submitting the form contained in Annex 2 of the passporting guide to the CMA. KSA fund managers must ensure they meet the minimum standards set out in Annex 1 of the regulations. Ongoing updates, registers, custody, and fees. If there is any change or error in application information between approval and the start of the promotion, the fund manager must notify both regulators within one business day. Both regulators maintain registers of approved cross-border funds, including the details regarding the fund, fund manager, agent, and effective date. The fund manager must appoint a custodian on a permanent basis, and each GCC state determines any applicable fees or exemptions for funds promoted in its jurisdiction. Promotion to KSA investors via locally licensed placement agent to promote and market units of a passported fund to investors in the KSA. The relevant GCC fund manager must appoint an agent. The agent must be a capital market institution licensed and authorized by the CMA to engage in dealing, investment management, or fund operation activities, and must ensure compliance with all relevant requirements. Agents must also file required declarations and documents with the CMA, maintain a local register of KSA unit holders, relay unit holder communications to the fund manager, provide information on how to submit complaints and how such complaints are monitored and addressed, and report offering results and material changes. If the minimum subscription amount is not met, agents are responsible for refunding subscription amounts to KSA unit holders. Agents for private funds are required to promote and offer units exclusively by private placement and only to qualified and institutional investors, and the disclaimer under the offering document for such funds is required to incorporate language reflecting the limitation on distribution to these investors only. Dispute resolution. The CMA Committee for the Resolution of Securities Disputes has jurisdiction to adjudicate any disputes arising from the offering of units of a cross-registered fund in the KSA. Implications for market participants. The cross-border passporting framework allows for the offering of units of GCC funds to KSA investors with relative ease. Conversely, managers of KSA-based funds can offer funds to investors in other GCC jurisdictions through a similarly streamlined process. For fund managers, the regime offers a clearer route to access GCC investors through a single cross-border registration process. However, fund managers must comply with host country rules on promotion, including the requirement to appoint an agent licensed by the host regulatory authority. Market participants should also factor in the practical compliance items that tend to drive timelines in the KSA, including the required disclosure package, plus the ongoing obligation to notify both regulators promptly of any changes or errors in submitted information. Conclusion. The GCC passporting regime introduces a structured pathway for eligible funds to be registered and promoted across GCC markets, while preserving the host regulatory authority's ability to refuse, condition, or restrict cross-border registration where needed. For fund managers of GCC funds looking to offer funds to KSA investors, the main considerations will be appointing a locally licensed agent and ensuring the funds disclosure package and ongoing update obligations are properly managed from the outset. As cross registration gains traction across GCC jurisdictions, both investors and fund managers of GCC funds registered outside the KSA stand to benefit from expanded opportunities to participate in the Saudi financial market.