FTLs aren't a GCAA matter. Even under EASA the documents are only guidelines.
It is up to the operator to set up the scheme, and the Authority to approve it.
There is no way ULR factoring would have been approved under JAR, though EASA is a different matter.
In the UAE , if the operator puts it in the manual and the GCAA approve it, it's legal.
That doest't mean it's right.......