🇱🇻 Latvia vs 🇦🇪 United Arab Emirates (Dubai - VARA): e-money licensing compared
Decision context and regulator route
Choosing between Latvia and United Arab Emirates (Dubai - VARA) for a e-money licence starts with who you will answer to: Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023 on one side, Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto. on the other, via the Two tiers: (1) Licensed electronic money institution (full EMI licence) and (2) Registered electronic money institution (lighter-touch registration tier for smaller issuers, restricted to issuing e-money and providing only payment instrument issuance or money remittance) - both under the Law on Payment Services and Electronic Money (transposing EMD2) and the No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal. respectively. The two regimes differ on 10 of 10 tracked decision dimensions, including capital requirement and timeline to authorisation. Every figure behind the comparison carries a last-verified date and a primary source.
Latvia: verified 2026-07-03 · United Arab Emirates (Dubai - VARA): verified 2026-07-15
| Dimension |
🇱🇻 Latvia
partly open
Verified 2026-07-03
|
🇦🇪 United Arab Emirates (Dubai - VARA)
analogue
partly open
Verified 2026-07-15
|
|---|---|---|
| Licence type | Two tiers: (1) Licensed electronic money institution (full EMI licence) and (2) Registered electronic money institution (lighter-touch registration tier for smaller issuers, restricted to issuing e-money and providing only payment instrument issuance or money remittance) - both under the Law on Payment Services and Electronic Money (transposing EMD2) | No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal. |
| Regulator | Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023 | Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto. |
| Capital requirement | Latvia capital requirement is included in the £349 pass. | United Arab Emirates (Dubai - VARA) capital requirement is included in the £349 pass. |
| Timeline to authorisation | Latvia 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 | Latvia local substance is included in the £349 pass. | United Arab Emirates (Dubai - VARA) local substance is included in the £349 pass. |
| Application cost | Latvia application cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) application cost is included in the £349 pass. |
| Ongoing cost | Latvia ongoing cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) ongoing cost is included in the £349 pass. |
| Passporting | Latvia passporting is included in the £349 pass. | United Arab Emirates (Dubai - VARA) passporting is included in the £349 pass. |
| EMIs authorised | Latvia emis authorised is included in the £349 pass. | United Arab Emirates (Dubai - VARA) emis authorised is included in the £349 pass. |
| Key restrictions | Latvia key restrictions is included in the £349 pass. | United Arab Emirates (Dubai - VARA) key restrictions is included in the £349 pass. |
| Safeguarding | Latvia safeguarding is included in the £349 pass. | United Arab Emirates (Dubai - VARA) safeguarding is included in the £349 pass. |
| Recent changes | Latvijas Banka continues actively granting new EMI licences (e.g. NorthernTech SIA, AP Operations SIA, Fibonatix in 2025-2026); Latvia is increasingly featured on fintech shortlists. As of 2025, 3 new companies received EMI licences. PSD3/PSR (final texts April 2026, OJ publication expected mid-to-late 2026) will apply directly (PSR) and require transposition (PSD3) within 18 months. | 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 | Latvia 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
🇱🇻 Latvia (verified 2026-07-03): Latvijas Banka continues actively granting new EMI licences (e.g. NorthernTech SIA, AP Operations SIA, Fibonatix in 2025-2026); Latvia is increasingly featured on fintech shortlists. As of 2025, 3 new companies received EMI licences. PSD3/PSR (final texts April 2026, OJ publication expected mid-to-late 2026) will apply directly (PSR) and require transposition (PSD3) within 18 months.
🇦🇪 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 Latvia and United Arab Emirates (Dubai - VARA)?
Latvia: Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023. United Arab Emirates (Dubai - VARA): Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto..
What licence do you need in Latvia compared with United Arab Emirates (Dubai - VARA)?
In Latvia the authorisation route is Two tiers: (1) Licensed electronic money institution (full EMI licence) and (2) Registered electronic money institution (lighter-touch registration tier for smaller issuers, restricted to issuing e-money and providing only payment instrument issuance or money remittance) - both under the Law on Payment Services and Electronic Money (transposing EMD2); 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 Latvia 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/latvia-vs-uae-vara.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.