🇩🇪 Germany vs 🇦🇪 United Arab Emirates (Dubai - VARA): e-money licensing compared

What changed recently

🇩🇪 Germany (verified 2026-07-03): PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file.

🇦🇪 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.