🇭🇰 Hong Kong vs 🇦🇪 United Arab Emirates (Dubai - VARA): e-money licensing compared

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 2026-07-15): 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.