UAE retail payment services and stored value facility licences.

What you get

How the firm obtains the licence

1. Scoping and proposal. The category, the choice between onshore, ADGM and DIFC, the capital for the projected volumes and its source, and the stored value position are confirmed in writing, with a pre-application meeting with the CBUAE Licensing Division arranged.
2. Application pack. The application form and annex, the business plan, controllers’ accounts, fit and proper forms, the independent assessment reports kept under six months old at sign-off and the policies before filing with the CBUAE.
3. Banking. The escrow account for funds in transit or the segregated float accounts, and the bank guarantee for a stored value facility’s paid-up capital, are arranged through the firm’s relationships before the decision.
4. Regulator engagement. CBUAE requests are answered by the set date through one process with the evidence assembled, so the application stays active, until the decision; the regulation sets no period for payment service providers.

Key people, banking and technology

You will need a chief executive and deputy based in the UAE, senior managers based there and, for a stored value licence, a compliance officer and an MLRO.

One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.

Who needs the licence

A business providing or promoting in the UAE any of the nine retail payment services, payment account issuance, payment instrument issuance, merchant acquiring, payment aggregation, domestic fund transfers, cross-border fund transfers, payment token services, payment initiation and payment account information, needs a licence under the Retail Payment Services and Card Schemes Regulation, Circular 15/2021. Licensed banks are deemed licensed, with notification and a No Objection Letter for certain services; finance companies are exempt only for issuing credit cards; card scheme operators hold a separate licence under Article 18. A business issuing or operating a stored value facility, a prepaid balance redeemable with third parties, needs a prior licence under the Stored Value Facilities Regulation, except for a single-purpose facility; transactions involving a stored value facility fall under that regulation rather than the payment services regulation, and advertising a facility to the UAE public without a licence is prohibited. Firms in the financial free zones apply instead to the ADGM or DIFC regulator, described below.

Licence categories under the Retail Payment Services and Card Schemes Regulation

What the CBUAE requires

• Legal form and location. For payment services, a juridical person incorporated in the UAE under Federal Law No. 2 of 2015, with the chief executive and alternate ordinarily resident in the UAE, other senior management based there unless the CBUAE allows otherwise, and personal and payment data stored in the UAE. For a stored value facility, incorporation in the State including the free zones but excluding the financial free zones, the chief executive and key personnel based in the State, and issuing the facility as the principal business.
• Controllers and governance. A controller holding 20% or more of shares or votes needs prior CBUAE approval and must be fit and proper. An organisational structure with compliance, risk management and internal audit functions; annual audits of the financial statements and of payment systems and controls; records kept five years; immediate notification of breaches of major regulatory requirements; the licensed services as the principal business, with ancillary services approved in advance and placed in a separate entity where required. A stored value facility issuer’s board, senior management and controlling shareholders are approved as fit and proper before licensing, with separate compliance and internal audit, an annual board-approved risk assessment and an appointed AML compliance officer and MLRO.
• Safeguarding. A payment service provider may hold user funds only in transit: where settlement is within 24 hours the funds are kept separate and insulated from creditors; where longer, they are held in a separate escrow account at a bank or covered by insurance or a bank guarantee from an unaffiliated provider. A stored value facility holds its float in segregated accounts with licensed banks or a CBUAE-recognised foreign bank, or under a bank guarantee or insurance, reconciled daily, managed for liquidity rather than return, and without currency mismatch other than AED against US dollars.
• Ongoing capital. Aggregate capital funds, paid-up capital, reserves excluding revaluation reserves and retained earnings, less accumulated losses and goodwill, at or above the initial requirement at all times, stepping up automatically after three consecutive months above AED 10 million of monthly transactions; Category IV holds professional indemnity insurance in an amount the CBUAE decides; a stored value facility holds at least 5% of total float.
• Application pack. A pre-application meeting with the CBUAE Licensing Division, encouraged for payment service providers and strongly encouraged for stored value facilities; the application form with its annex: business plan, controllers’ accounts, fit and proper forms, independent assessment reports and policies. The stored value facility annex has 19 items, including a three-year business plan, a certified paid-up capital report, independent assessment reports on seven areas no more than six months old at sign-off, float policies and three years of audited accounts of the controlling shareholders.

Capital

New applicants are assessed on projected volumes and disclose the source of capital; the CBUAE may require more than the minimum and may attach conditions such as storage limits.

Timing

Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.

Fees and costs

Exemptions and the smallest category

A single-purpose stored value facility is outside the regulation. The CBUAE may exempt cash reward, digital product, bonus point and restricted-group schemes, and schemes with a float up to AED 500,000 and no more than 100 customers, after sandbox testing. For payment services, Category IV, payment initiation and account information only, carries AED 100,000 of capital regardless of volume.

ADGM: money services under the FSRA

In Abu Dhabi Global Market the regulated activity of Providing Money Services, covering currency exchange, money remittance and payment services, sits in the Financial Services Regulatory Authority’s prudential Category 3C. The base capital requirement under PRU 3.3 is US$250,000 by default; currency exchange carries an expenditure-based minimum of 13/52 of annual audited expenditure, or 18/52 when combined with payment services; money remitters and payment account providers carry a variable requirement of 1.25% of the first US$10 million of monthly payment volume, 0.5% of the next US$90 million, 0.25% of the next US$150 million and 0.125% thereafter, with higher tiers for combined or payment account business; fiat-referenced token intermediation alone carries US$50,000. Under the FEES rules the application fee is US$15,000 with an annual supervision fee of US$15,000 for currency exchange or money remittance, and US$25,000 each for payment services. A physical presence on Al Maryah Island or Al Reem Island is required. The FSRA publishes no processing timeline.

DIFC: money services under the DFSA

In the Dubai International Financial Centre the financial service of Providing Money Services is carried on by a Category 3D firm authorised by the Dubai Financial Services Authority. Under the Fees Module, the application fee is US$25,000 where the firm issues stored value, US$15,000 where it neither issues stored value nor only transmits money, US$10,000 for money transmission only and US$5,000 for arranging or advising; the annual base fee is the same amount, with US$10,000 for arranging or advising, plus US$1,000 per US$1 million of expenditure. The DFSA states that application fees across all financial services range from US$15,000 to US$70,000. The base capital for a Category 3D firm is set in the DFSA’s prudential rulebook. The DFSA publishes no authorisation timeline.

Geographic scope

A CBUAE licence covers onshore UAE. Abu Dhabi Global Market and the Dubai International Financial Centre are financial free zones with their own regulators, and there is no passporting between the three regimes; a stored value facility applicant may not be incorporated in a financial free zone. Groups serving the Gulf alongside Europe pair the UAE licence with a UK EMI licence or an EU authorisation; the firm obtains each.

Why applications are delayed

The regulations set out how the CBUAE handles applications. A stored value facility application remains a draft until complete; where requested information is not supplied by the set date the application is suspended, and a suspension of six months or more generally requires a new application; independent assessment reports older than six months at sign-off are refreshed. A refusal of a card scheme licence must state reasons. Under Article 21 a provider without a licence at the end of the transition period may be ordered to cease. The points settled before filing are the category, the UAE entity and resident chief executive, the capital and its source, the safeguarding arrangement and the independent assessments.

Banking

A payment service provider holds funds in transit in a separate escrow account with a UAE bank, or under insurance or a guarantee; a stored value facility holds its float in segregated accounts with licensed banks or a CBUAE-recognised foreign bank, reconciled daily, with an unconditional bank guarantee for its paid-up capital. The firm arranges these through institutions that serve regulated firms in the UAE, during the application, so the firm trades on licensing. See banking and payment processing.

Questions firms ask

References

1. CBUAE Rulebook: Retail Payment Services and Card Schemes Regulation
2. CBUAE Rulebook: Stored Value Facilities Regulation
3. CBUAE: press release on the Retail Payment Services and Card Schemes Regulation
4. ADGM FSRA: getting started guide
5. ADGM FSRA: amendments to the FEES rules
6. DFSA: fees

This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.