Regulation of Cash Transactions in Kuwait: A Legal Analysis of Ministry of Commerce Resolution No. (32) of 2026

By By Lawyer Nuwair Al-Azmi – Dar Al Muhama Law Firm 5/24/2026
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The legal and commercial framework in the State of Kuwait is witnessing a rapid transformation aimed at strengthening financial governance and oversight of commercial transactions, in line with global trends supporting the digital economy and combating unlawful financial practices. Within this context, the Kuwaiti Ministry of Commerce and Industry issued Ministerial Resolution No. (32) of 2026 concerning the regulation of cash transactions for certain commercial and service activities. The Resolution prohibits the collection or payment of cash amounts exceeding ten Kuwaiti Dinars within specified activities and obliges companies and establishments to utilize approved electronic payment methods. This Resolution constitutes a significant regulatory measure with important economic and supervisory dimensions, reflecting the administrative legislator’s intention to enhance oversight of cash flows and reduce reliance on undocumented traditional transactions, thereby promoting greater financial transparency and reinforcing confidence in the commercial environment. The Resolution applies to a number of activities characterized by frequent direct daily transactions with the public, namely health institutes, men’s, women’s, and children’s salons, sports clubs, companies engaged in medical insect and rodent control, as well as activities relating to the import, export, and storage of public health pesticides. It is evident that the selection of these activities was not arbitrary, but rather based on the repetitive nature of their cash transactions and the potential difficulty of financially tracing such transactions if direct cash payments continued to be used. From a legal perspective, the Resolution is grounded in the regulatory authority vested in the administration pursuant to laws governing commerce and the protection of the national economy. The competent administrative authority possesses the power to issue executive resolutions intended to regulate economic activities in a manner that serves the public interest and preserves the integrity of the financial system. Furthermore, the Resolution aligns with national policies concerning anti-money laundering and counter-terrorism financing measures by enhancing the traceability and electronic documentation of financial transactions. The implementation of the Resolution imposes an obligation on companies and establishments subject thereto not to accept or make cash payments exceeding the prescribed limit, whether in relation to the conclusion of contracts, the provision of services, or the sale of goods. Payment must instead be effected through bank payment cards or other electronic payment methods approved by the competent banking authorities. This framework creates a documented financial record of commercial transactions, thereby facilitating financial, tax, and regulatory audit processes. Notwithstanding the regulatory benefits achieved by the Resolution, its practical implementation may give rise to certain challenges, particularly for small enterprises or activities that continue to rely partially on cash transactions in their day-to-day operations. It may also necessitate the provision of suitable technological infrastructure, as well as legal and procedural awareness programs for business owners and employees, to ensure full compliance with the provisions of the Resolution. Conversely, the anticipated positive effects appear far-reaching, as the Resolution contributes to supporting digital transformation, reducing the risks of financial evasion, limiting informal transactions, and enhancing confidence in the commercial and service sectors. It is also consistent with the State’s direction toward the development of electronic services and the realization of an economic vision founded upon transparency and efficiency. In conclusion, Ministerial Resolution No. (32) of 2026 represents an important legislative and regulatory step within the broader process of modernizing Kuwait’s commercial environment. It further confirms the public administration’s commitment to establishing the principle of electronic financial oversight and regulating commercial transactions in a manner consistent with modern economic and technological developments, while maintaining a balance between the freedom of commercial activity and the requirements of public economic order.

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