🇭🇰 Hong Kong vs 🇦🇪 United Arab Emirates (Dubai - VARA): e-money licensing compared
Decision context and regulator route
Hong Kong's public No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584). and United Arab Emirates (Dubai - VARA)'s public No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal. are set out side by side. Licence type, regulator and public recent-change notes are open; the full dated and sourced comparison is included with access.
Hong Kong: verified 2026-08-15 · United Arab Emirates (Dubai - VARA): verified 2026-10-01
| Dimension |
🇭🇰 Hong Kong
analogue
partly open
Verified 2026-08-15
|
🇦🇪 United Arab Emirates (Dubai - VARA)
analogue
partly open
Verified 2026-10-01
|
|---|---|---|
| Licence type | No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584). | No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal. |
| Regulator | Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime. | Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto. |
| Capital requirement | Hong Kong capital requirement is included in the £349 pass. | United Arab Emirates (Dubai - VARA) capital requirement is included in the £349 pass. |
| Timeline to authorisation | Hong Kong 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 | Hong Kong local substance is included in the £349 pass. | United Arab Emirates (Dubai - VARA) local substance is included in the £349 pass. |
| Application cost | Hong Kong application cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) application cost is included in the £349 pass. |
| Ongoing cost | Hong Kong ongoing cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) ongoing cost is included in the £349 pass. |
| Passporting | Hong Kong passporting is included in the £349 pass. | United Arab Emirates (Dubai - VARA) passporting is included in the £349 pass. |
| EMIs authorised | Hong Kong emis authorised is included in the £349 pass. | United Arab Emirates (Dubai - VARA) emis authorised is included in the £349 pass. |
| Key restrictions | Hong Kong key restrictions is included in the £349 pass. | United Arab Emirates (Dubai - VARA) key restrictions is included in the £349 pass. |
| Safeguarding | Hong Kong safeguarding is included in the £349 pass. | United Arab Emirates (Dubai - VARA) safeguarding is included in the £349 pass. |
| Recent changes | The separate Stablecoins Ordinance (Cap. 656) came into force 1 August 2025 and is administered by the HKMA. In April 2026 the HKMA granted the first stablecoin issuer licences, to Anchorpoint and HSBC, both for HKD-referenced stablecoins, requiring at least HK$25m paid-up capital and segregated reserve assets. SVF licensees under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584, the analogue regime in this row) are recognised as permitted offerors under the Stablecoins Ordinance and have a clear pathway to stablecoin issuance, but SVF and stablecoin-issuer licences remain two distinct licence types. | 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 | Hong Kong 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
🇭🇰 Hong Kong (verified 2026-08-15): The separate Stablecoins Ordinance (Cap. 656) came into force 1 August 2025 and is administered by the HKMA. In April 2026 the HKMA granted the first stablecoin issuer licences, to Anchorpoint and HSBC, both for HKD-referenced stablecoins, requiring at least HK$25m paid-up capital and segregated reserve assets. SVF licensees under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584, the analogue regime in this row) are recognised as permitted offerors under the Stablecoins Ordinance and have a clear pathway to stablecoin issuance, but SVF and stablecoin-issuer licences remain two distinct licence types.
🇦🇪 United Arab Emirates (Dubai - VARA) (verified 2026-10-01): 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 Hong Kong and United Arab Emirates (Dubai - VARA)?
Hong Kong: Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime.. United Arab Emirates (Dubai - VARA): Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto..
What licence do you need in Hong Kong compared with United Arab Emirates (Dubai - VARA)?
In Hong Kong the authorisation route is No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584).; 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 Hong Kong vs United Arab Emirates (Dubai - VARA) comparison?
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Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.