United Arab Emirates: fintech & payments regulation

Who regulates

• Central Bank of the UAE (CBK)

  Federal regulator for payment services, exchange businesses, open finance, and general financial institutions.

  ^[1][2][3][4]

• Virtual Assets Regulatory Authority (VARA)

  Regulator for virtual assets and related activities in Dubai.

  ^[5][6][7]

• Financial Services Regulatory Authority (FSRA)

  Regulator for financial services, virtual assets, and fiat-referenced tokens in the Abu Dhabi Global Market (ADGM).

  ^{[8][9][10][11]}

• Dubai Financial Services Authority (DFSA)

  Regulator for financial services, including crypto tokens and money services, in the Dubai International Financial Centre (DIFC).

  ^[12][13]

Core laws & rules

• Federal Decree-Law No. 6 of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business (2025)

  Establishes the CBK as an independent federal public institution with autonomy, defining its core objectives including currency stability and financial system integrity.

  ^[1]

• Payment Token Services Regulation (2024)

  Establishes the licensing and registration framework for digital payment token services, defining issuance, conversion, and custody/transfer categories.

  ^[3]

• Exchange Business Regulation (2025)

  Establishes a comprehensive licensing and supervisory framework for entities conducting currency exchange and money transfer activities.

  ^[2]

• Virtual Assets and Related Activities Regulations 2023 (2023)

  Enacted by VARA to govern virtual assets and related activities across all Dubai zones, mandating licensing and AML/CFT compliance.

  ^[6]

• Financial Services and Markets (Amendment No. 1) Regulations 2026 (2026)

  Amends the 2015 ADGM framework, designating the FSRA as the AML Supervisory Authority and imposing strict compliance obligations.

  ^[8]

Licensing & registration

• Payment Token Services

  The CBK mandates licensing for digital payment token services, covering issuance, conversion, and custody/transfer, with explicit prohibitions on certain activities.

  ^[3]

• Exchange Business

  Entities conducting currency exchange and money transfer activities must obtain specific license categories from the CBK as defined in the 2025 Regulation.

  ^[2]

• Virtual Asset Services (VARA)

  VARA requires licensing for virtual asset service providers, with a three-tier classification system for issuers (Category 1 requiring reserve assets) and strict marketing approvals.

  ^[5][6][7]

• Virtual Assets & Fiat-Referenced Tokens (FSRA ADGM)

  FSRA requires authorization for virtual asset activities, fiat-referenced token intermediation, and digital investment management, with specific capital requirements for token intermediation.

  ^[9][14][10]

• Crypto Tokens & Money Services (DFSA DIFC)

  DFSA regulates crypto tokens and money services under the DIFC framework, requiring licensing and compliance with updated conduct and prudential modules.

  ^[12][13]

Restrictions & warnings

• The CBK's Payment Token Services Regulation explicitly prohibits certain activities, and Restricted Licence Banks are prohibited from providing retail banking services to natural persons.

  ^[3][15]

• VARA mandates that businesses obtain approval or a no-objection confirmation before offering regulated virtual asset activities, and Category 1 issuers must maintain reserve assets.

  ^[7][5]

• FSRA requires specific permissions for staking activities and mandates robust internal policies and client consent for asset encumbrance in transfer and settlement services.

  ^[16][17]

Direction of travel

• The regulatory landscape is evolving with the CBK's Open Finance Regulation establishing an API Hub and licensed ecosystem, and FSRA introducing frameworks for fiat-referenced tokens and digital investment management.

  ^[4][11]

• Regulators are strengthening AML/CFT supervision, with FSRA designated as the AML supervisory authority in ADGM and CBK issuing guidance on correspondent banking risks.

  ^[8][18]

Sources

1. Federal Decree-Law No. 6 of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business · 2025-09-16
2. Exchange Business Regulation · 2025-06-26
3. Payment Token Services Regulation · 2024-08-31
4. Open Finance Regulation · 2025-07-22
5. Virtual Asset Issuance Rulebook · 2025-06-19
6. Virtual Assets and Related Activities Regulations 2023 · 2025-06-19
7. Marketing Regulations on Virtual Assets and Related Activities 2024 · 2024-01-01
8. Financial Services and Markets (Amendment No. 1) Regulations 2026 · 2026-04-30
9. Financial Services and Markets (Amendment No. _) Regulations 2025 · 2025-09-09
10. Guidance on Regulation of Virtual Asset Activities in ADGM · 2025-06-06
11. Supplementary Guidance on Digital Investment Management · 2025-11-04
12. DFSA Consultation Paper 153: Updates on the Regulation of Crypto Tokens · 2024-01-04
13. Notice of Consultation Paper Release – DFSA Proposals on Money Services, Crypto Tokens and Crowdfunding · 2023-04-27
14. Amendments to the Prudential Rulebook (PRU) · 2025-09-09
15. Restricted Licence Banks Regulation · 2022-05-15
16. Consultation Paper No. 10 of 2025 – Proposed Framework for the Staking of Virtual Assets · 2025-01-01
17. VA Transfer and Settlement Services Rulebook · 2025-06-19
18. Guidance for Licensed Financial Institutions on Correspondent Banking and Expectations for Managing Correspondent Banking Relationships · 2025-11-07