LBMA and DMCC: Two Good Delivery Lists, Two Separate Systems

In the precious metals market, "Good Delivery" usually means London. Yet there is a second regime that the sector encounters today: Dubai's standard, which now operates under the name UAE Good Delivery. The two regimes use the same concept, but they differ in who governs them, where they are accepted and how they connect to Turkish law.

Who Governs Them?

The LBMA is the trade association of the London bullion market; it is not a state body but a private-law legal entity established by market participants. The Good Delivery List is maintained under the Association's own rules; according to its 2025 annual report, there are 104 refiners on the list, 66 refiners of them for gold.

In Dubai, by contrast, the regime was established by the state. The DMCC was established on the initiative of the Government of Dubai and is today a free zone authority owned by a Dubai wealth fund. The Dubai Good Delivery standard it launched in 2005 has operated since November 2021 as UAE Good Delivery, under a federal committee chaired by the UAE Ministry of Economy.

This difference shows in the outcome: in London, the rule-maker is the market itself; in Dubai, the rule-maker is a structure set up by the state.

What Is the Accreditation For?

LBMA Good Delivery concerns the acceptance of large bars in the London market and is open only to refiners. Its requirements are high: at least five years of existence, at least three years of refining in the metal applied for, annual production of at least 10 tonnes of gold or 50 tonnes of silver, and tangible net worth of at least GBP 15 million.

The Dubai regime was built around the region's way of trading: it was originally introduced for 1-kilogram bars of 995 fineness. The DMCC rules also provide for a separate accreditation for refiners with a shorter operating history. For this reason, the Dubai regime serves as an intermediate gateway for refiners that have not yet reached the London threshold.

Responsible Sourcing Rules

Both regimes are based on the OECD's guidance for conflict-affected and high-risk areas (CAHRA). At the LBMA, every refiner on the Good Delivery List is subject to the Responsible Sourcing Programme; it undergoes an independent audit every year, and the results are made public.

In the UAE, by contrast, the rule is a ministerial regulation: the Ministry of Economy's due diligence regulation on the responsible sourcing of gold has been mandatory for refiners from the audit period beginning on 1 January 2023. This regulation came into force during the period from 2022 to 2024 when the UAE was on the FATF's list of jurisdictions under increased monitoring; the UAE was removed from the list in February 2024.

How Do They Connect to Turkish Law?

This is where the real distinction lies. The LBMA enters Turkish legislation indirectly: Article 7 of Decree No. 32 on the Protection of the Value of Turkish Currency (32 sayılı Karar) ties the domestic purchase and sale of standard unprocessed precious metals produced by non-resident refiners to the Borsa İstanbul Refinery List; and that list is itself built on the LBMA Good Delivery List.

The Dubai regime, on the other hand, is not mentioned in Turkish legislation. Borsa İstanbul's Refinery List makes no reference to the UAEGD list. A bar from a refiner accepted in Dubai does not receive the same treatment in Türkiye unless that refiner is also on the Borsa İstanbul list. For a Turkish company, the significance of the Dubai regime is not legal but commercial: access to the Dubai market and its clearing and delivery infrastructure.

State Support and Other Certificates

The Ministry of Trade's list of market entry documents eligible for support includes three bodies for the precious metals and stones chain: the LBMA Good Delivery List, the DMCC item (Dubai Good Delivery, Market Deliverable Brand and Responsible Market Participant) and RJC certification. The support covers the costs of obtaining and renewing a listed document; training and consultancy services fall outside its scope.

In terms of accessibility, the picture is clear. LBMA and Dubai Good Delivery are open to refiners. For jeweller and jewellery businesses, the certificate open to every link in the chain is RJC certification. As there is no current publicly available rulebook from the DMCC for the third document in the DMCC item, its scope should be confirmed with the DMCC and the exporters' association before applying.

Which One Is for Whom?

The deciding criterion is not a threshold but the target market and buyer. For a refiner working with London-based banks and international buyers, the LBMA comes to the fore; for a refiner serving the Gulf and Indian markets, UAE Good Delivery does. Within Türkiye, however, the decisive factor is the Borsa İstanbul list.

What Should Be Done?

• Determine which list the target buyer recognises; state expressly in the contract whether "Good Delivery" means London or Dubai.
• When sourcing from a non-resident refiner, take the Borsa İstanbul Refinery List as the basis; the UAEGD list does not substitute for this requirement.
• Confirm the refiner's position on the list against the current list on the transaction date.
• Design responsible sourcing reporting from a single database that meets the LBMA, UAE and Borsa İstanbul requirements.
• If you are not a refiner, consider the RJC as your chain certificate.
• In your support application, show the cost of obtaining and renewing the document separately from consultancy costs.

Warning. The information in this article is for general information purposes and does not constitute a legal opinion. Foreign exchange and precious metals legislation is a frequently changing area; the amounts, rates, thresholds, time limits and dates in this article may change in line with the legislation in force. Verify the latest version of the legislation before every application and transaction. Current texts are available at mevzuat.gov.tr.

Source: LBMA, How to apply for Good Delivery accreditation · LBMA Responsible Sourcing Programme · LBMA Annual Report 2025 · DMCC Accreditation Rules v2/2020 · UAE Ministry of Economy, Due Diligence Regulations for Responsible Sourcing of Gold · DGCX announcement (21 July 2023) · Borsa İstanbul A.Ş. Refinery List (2 October 2026) · Decree No. 32, Article 7(4) · ANNEX-1/B Market Entry Documents Eligible for Support (26 June 2026) · Circular (Genelge) on Market Entry Document Support, Article 4

Related page: Refineries