🇩🇪 Germany vs 🇦🇪 United Arab Emirates (Dubai - VARA): e-money licensing compared
Decision context and regulator route
Germany and United Arab Emirates (Dubai - VARA) are commonly considered side by side for e-money authorisation. In Germany the route is the E-Geld-Institut under the ZAG. overseen by BaFin, with the Deutsche Bundesbank.; 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 public licence and regulator fields below are open to everyone; the complete sourced comparison is included with access.
Germany: verified 2026-10-16 · United Arab Emirates (Dubai - VARA): verified 2026-10-16
| Dimension |
🇩🇪 Germany
partly open
Verified 2026-10-16
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🇦🇪 United Arab Emirates (Dubai - VARA)
analogue
partly open
Verified 2026-10-16
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|---|---|---|
| Licence type | E-Geld-Institut under the ZAG. | No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal. |
| Regulator | BaFin, with the Deutsche Bundesbank. | Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto. |
| Capital requirement | Germany capital requirement is included in the £349 pass. | United Arab Emirates (Dubai - VARA) capital requirement is included in the £349 pass. |
| Timeline to authorisation | Germany 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 | Germany local substance is included in the £349 pass. | United Arab Emirates (Dubai - VARA) local substance is included in the £349 pass. |
| Application cost | Germany application cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) application cost is included in the £349 pass. |
| Ongoing cost | Germany ongoing cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) ongoing cost is included in the £349 pass. |
| Passporting | Germany passporting is included in the £349 pass. | United Arab Emirates (Dubai - VARA) passporting is included in the £349 pass. |
| EMIs authorised | Germany emis authorised is included in the £349 pass. | United Arab Emirates (Dubai - VARA) emis authorised is included in the £349 pass. |
| Key restrictions | Germany key restrictions is included in the £349 pass. | United Arab Emirates (Dubai - VARA) key restrictions is included in the £349 pass. |
| Safeguarding | Germany safeguarding is included in the £349 pass. | United Arab Emirates (Dubai - VARA) safeguarding is included in the £349 pass. |
| Recent changes | PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 16 October 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension. | The ordinary Article 184 reconciliation period under Federal Decree-Law No. 6 of 2025 ended on 16 September 2026, one year after the Decree-Law took effect. The CBUAE Board may extend the period at its discretion. The CBUAE states that earlier decisions, standards, guidelines and circulars continue until replaced. |
| Difficulty rating | Germany difficulty rating is included in the £349 pass. | United Arab Emirates (Dubai - VARA) difficulty rating is included in the £349 pass. |
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What changed recently
🇩🇪 Germany (verified 2026-10-16): PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 16 October 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.
🇦🇪 United Arab Emirates (Dubai - VARA) (verified 2026-10-16): The ordinary Article 184 reconciliation period under Federal Decree-Law No. 6 of 2025 ended on 16 September 2026, one year after the Decree-Law took effect. The CBUAE Board may extend the period at its discretion. The CBUAE states that earlier decisions, standards, guidelines and circulars continue until replaced.
Quick answers
Who regulates e-money licensing in Germany and United Arab Emirates (Dubai - VARA)?
Germany: BaFin, with the Deutsche Bundesbank.. United Arab Emirates (Dubai - VARA): Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto..
What licence do you need in Germany compared with United Arab Emirates (Dubai - VARA)?
In Germany the authorisation route is E-Geld-Institut under the ZAG.; 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 Germany 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/germany-vs-uae-vara.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.