🇫🇮 Finland vs 🇦🇪 United Arab Emirates (Dubai - VARA): e-money licensing compared
Decision context and regulator route
Finland and United Arab Emirates (Dubai - VARA) take recognisably different routes to e-money authorisation. In Finland the route is the Toimilupa (authorisation) as an e-money institution under the Act on Payment Institutions (Laki maksulaitoksista, 297/2010), transposing EMD2; a lighter registration-only regime exists for issuers whose average outstanding e-money does not exceed EUR 5 million (exempt/small e-money issuer tier) overseen by Finanssivalvonta (Financial Supervisory Authority, FIN-FSA); in United Arab Emirates (Dubai - VARA) it is the No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal. under Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto.. The two regimes differ on 10 of 10 tracked decision dimensions, including capital requirement and timeline to authorisation. The free columns below are open to everyone; the decision figures unlock with a pass, each one dated and sourced.
Finland: verified 2026-07-15 · United Arab Emirates (Dubai - VARA): verified 2026-07-15
| Dimension |
🇫🇮 Finland
partly open
Verified 2026-07-15
|
🇦🇪 United Arab Emirates (Dubai - VARA)
analogue
partly open
Verified 2026-07-15
|
|---|---|---|
| Licence type | Toimilupa (authorisation) as an e-money institution under the Act on Payment Institutions (Laki maksulaitoksista, 297/2010), transposing EMD2; a lighter registration-only regime exists for issuers whose average outstanding e-money does not exceed EUR 5 million (exempt/small e-money issuer tier) | No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal. |
| Regulator | Finanssivalvonta (Financial Supervisory Authority, FIN-FSA) | Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto. |
| Capital requirement | Finland capital requirement is included in the £349 pass. | United Arab Emirates (Dubai - VARA) capital requirement is included in the £349 pass. |
| Timeline to authorisation | Finland timeline to authorisation is included in the £349 pass. | United Arab Emirates (Dubai - VARA) timeline to authorisation is included in the £349 pass. |
| Local substance | Finland local substance is included in the £349 pass. | United Arab Emirates (Dubai - VARA) local substance is included in the £349 pass. |
| Application cost | Finland application cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) application cost is included in the £349 pass. |
| Ongoing cost | Finland ongoing cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) ongoing cost is included in the £349 pass. |
| Passporting | Finland passporting is included in the £349 pass. | United Arab Emirates (Dubai - VARA) passporting is included in the £349 pass. |
| EMIs authorised | Finland emis authorised is included in the £349 pass. | United Arab Emirates (Dubai - VARA) emis authorised is included in the £349 pass. |
| Key restrictions | Finland key restrictions is included in the £349 pass. | United Arab Emirates (Dubai - VARA) key restrictions is included in the £349 pass. |
| Safeguarding | Finland safeguarding is included in the £349 pass. | United Arab Emirates (Dubai - VARA) safeguarding is included in the £349 pass. |
| Recent changes | FIN-FSA introduced a new model for submitting financial information in payment institutions' authorisation applications during 2026, and a new processing fee schedule took effect 1 January 2026, signaling active modernisation of the authorisation pipeline. No Finland-specific PSD3/PSR transposition milestone found beyond the general EU timeline. | Transition deadline 16 September 2026 applies to in-scope entities. This traces to Article 184 of Federal Decree-Law No. 6 of 2025 (Article text pending direct confirmation from the CBUAE rulebook) (the new consolidated Central Bank Law, which significantly expanded CBUAE's remit to cover payment services using virtual assets and technology providers facilitating financial services): the law was published in the Official Gazette on 15 September 2025 and took effect the following day, and Article 184 gives all persons newly brought into scope a one-year reconciliation period from that effective date, extendable at the Central Bank's discretion. This is separate from the older, narrower Payment Token Services Regulation (Circular 2/2024, effective 31 August 2024), whose own Article 40 sets a one-year transition period from that regulation's commencement (around 31 August 2025) for firms already providing payment token services when that narrower regulation first took effect; the two transition periods should not be conflated. |
| Difficulty rating | Finland difficulty rating is included in the £349 pass. | United Arab Emirates (Dubai - VARA) difficulty rating is included in the £349 pass. |
The two regimes differ on 10 of 10 tracked decision dimensions, including capital requirement and timeline to authorisation. Unlock the pass to see each figure with its source and verification date.
What changed recently
🇫🇮 Finland (verified 2026-07-03): FIN-FSA introduced a new model for submitting financial information in payment institutions' authorisation applications during 2026, and a new processing fee schedule took effect 1 January 2026, signaling active modernisation of the authorisation pipeline. No Finland-specific PSD3/PSR transposition milestone found beyond the general EU timeline.
🇦🇪 United Arab Emirates (Dubai - VARA) (verified 2026-07-15): Transition deadline 16 September 2026 applies to in-scope entities. This traces to Article 184 of Federal Decree-Law No. 6 of 2025 (Article text pending direct confirmation from the CBUAE rulebook) (the new consolidated Central Bank Law, which significantly expanded CBUAE's remit to cover payment services using virtual assets and technology providers facilitating financial services): the law was published in the Official Gazette on 15 September 2025 and took effect the following day, and Article 184 gives all persons newly brought into scope a one-year reconciliation period from that effective date, extendable at the Central Bank's discretion. This is separate from the older, narrower Payment Token Services Regulation (Circular 2/2024, effective 31 August 2024), whose own Article 40 sets a one-year transition period from that regulation's commencement (around 31 August 2025) for firms already providing payment token services when that narrower regulation first took effect; the two transition periods should not be conflated.
Quick answers
Who regulates e-money licensing in Finland and United Arab Emirates (Dubai - VARA)?
Finland: Finanssivalvonta (Financial Supervisory Authority, FIN-FSA). United Arab Emirates (Dubai - VARA): Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto..
What licence do you need in Finland compared with United Arab Emirates (Dubai - VARA)?
In Finland the authorisation route is Toimilupa (authorisation) as an e-money institution under the Act on Payment Institutions (Laki maksulaitoksista, 297/2010), transposing EMD2; a lighter registration-only regime exists for issuers whose average outstanding e-money does not exceed EUR 5 million (exempt/small e-money issuer tier); in United Arab Emirates (Dubai - VARA) it is No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Finland vs United Arab Emirates (Dubai - VARA) comparison?
The interactive benchmark lets you pin either jurisdiction and add up to five peers; a Founder Pass or Pro subscription unlocks every gated figure with its source and verification date. This page stays free at /e-money/compare/finland-vs-uae-vara.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.