🇦🇪 United Arab Emirates (Dubai - VARA) vs 🇬🇧 United Kingdom: e-money licensing compared
Decision context and regulator route
Choosing between United Arab Emirates (Dubai - VARA) and United Kingdom for a e-money licence starts with who you will answer to: Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto. on one side, Financial Conduct Authority (FCA). on the other, via the No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal. and the Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. respectively. The public fields are shown below, with the full dated and sourced comparison included with access.
United Arab Emirates (Dubai - VARA): verified 2026-07-15 · United Kingdom: verified 2026-08-15
| Dimension |
🇦🇪 United Arab Emirates (Dubai - VARA)
analogue
partly open
Verified 2026-07-15
|
🇬🇧 United Kingdom
Free in full
Verified 2026-08-15
|
|---|---|---|
| Licence type | No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal. | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto. | Financial Conduct Authority (FCA). |
| Capital requirement | United Arab Emirates (Dubai - VARA) capital requirement is included in the £349 pass. | AEMI GBP 350,000 initial plus own funds 2% of average outstanding e-money. SEMI no initial capital, capped below EUR 5m outstanding. |
| Timeline to authorisation | United Arab Emirates (Dubai - VARA) timeline to authorisation is included in the £349 pass. | About 6 to 12 months including pre-application (statutory 3 months from a complete application). |
| Local substance | United Arab Emirates (Dubai - VARA) local substance is included in the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | United Arab Emirates (Dubai - VARA) application cost is included in the £349 pass. | FCA application fee GBP 5,640 for an authorised EMI (Category 5) or GBP 1,130 for a small EMI (Category 3). Professional and implementation costs are project-specific. |
| Ongoing cost | United Arab Emirates (Dubai - VARA) ongoing cost is included in the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | United Arab Emirates (Dubai - VARA) passporting is included in the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | United Arab Emirates (Dubai - VARA) emis authorised is included in the £349 pass. | Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe. |
| Key restrictions | United Arab Emirates (Dubai - VARA) key restrictions is included in the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | United Arab Emirates (Dubai - VARA) safeguarding is included in the £349 pass. | Segregation or insurance or comparable guarantee. FCA Supplementary safeguarding regime (Policy Statement PS25/12, published 7 August 2025) in force from 7 May 2026: daily reconciliations, monthly regulatory reporting, annual safeguarding audit by a qualified auditor, resolution pack, third-party due diligence; audit exemption below GBP 100k. Stage 2 CASS-style statutory trust (Post-Repeal Regime) still under FCA review, not yet confirmed. |
| Recent changes | 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. | FCA safeguarding reform live from 7 May 2026 (first monthly REP027 return fell due 21 July 2026). HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026, proposes rebuilding the PSRs 2017 and EMRs 2011 into a single FCA-rulebook framework spanning fiat, tokenised deposits and UK qualifying stablecoins; it closes 6 October 2026. |
| Difficulty rating | United Arab Emirates (Dubai - VARA) difficulty rating is included in the £349 pass. | 4. Rigorous on financial crime and safeguarding, very large market. |
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What changed recently
🇦🇪 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.
🇬🇧 United Kingdom (verified 2026-08-15): FCA safeguarding reform live from 7 May 2026 (first monthly REP027 return fell due 21 July 2026). HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026, proposes rebuilding the PSRs 2017 and EMRs 2011 into a single FCA-rulebook framework spanning fiat, tokenised deposits and UK qualifying stablecoins; it closes 6 October 2026.
Quick answers
Who regulates e-money licensing in United Arab Emirates (Dubai - VARA) and United Kingdom?
United Arab Emirates (Dubai - VARA): Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto.. United Kingdom: Financial Conduct Authority (FCA)..
What licence do you need in United Arab Emirates (Dubai - VARA) compared with United Kingdom?
In United Arab Emirates (Dubai - VARA) the authorisation route is No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal.; in United Kingdom it is Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full United Arab Emirates (Dubai - VARA) vs United Kingdom 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/uae-vara-vs-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.