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🇫🇮 Finland partly open
Verified 2026-07-15
🇦🇪 United Arab Emirates (Dubai - VARA) analogue partly open
Verified 2026-07-15
Licence type Toimilupa (authorisation) as an e-money institution under the Act on Payment Institutions (Laki maksulaitoksista, 297/2010), transposing EMD2; a lighter registration-only regime exists for issuers whose average outstanding e-money does not exceed EUR 5 million (exempt/small e-money issuer tier) No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal.
Regulator Finanssivalvonta (Financial Supervisory Authority, FIN-FSA)
Verified 2026-07-02 Source: FIN-FSA: https://www.finanssivalvonta.fi/en/
Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto.
Verified 2026-07-03 Source: CBUAE
Capital requirement Finland capital requirement is included in the £349 pass. United Arab Emirates (Dubai - VARA) capital requirement is included in the £349 pass.
Timeline to authorisation Finland 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 Finland local substance is included in the £349 pass. United Arab Emirates (Dubai - VARA) local substance is included in the £349 pass.
Application cost Finland application cost is included in the £349 pass. United Arab Emirates (Dubai - VARA) application cost is included in the £349 pass.
Ongoing cost Finland ongoing cost is included in the £349 pass. United Arab Emirates (Dubai - VARA) ongoing cost is included in the £349 pass.
Passporting Finland passporting is included in the £349 pass. United Arab Emirates (Dubai - VARA) passporting is included in the £349 pass.
EMIs authorised Finland emis authorised is included in the £349 pass. United Arab Emirates (Dubai - VARA) emis authorised is included in the £349 pass.
Key restrictions Finland key restrictions is included in the £349 pass. United Arab Emirates (Dubai - VARA) key restrictions is included in the £349 pass.
Safeguarding Finland safeguarding is included in the £349 pass. United Arab Emirates (Dubai - VARA) safeguarding is included in the £349 pass.
Recent changes FIN-FSA introduced a new model for submitting financial information in payment institutions' authorisation applications during 2026, and a new processing fee schedule took effect 1 January 2026, signaling active modernisation of the authorisation pipeline. No Finland-specific PSD3/PSR transposition milestone found beyond the general EU timeline. 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.
Verified 2026-07-15 Source: CBUAE Rulebook, Article (40): Transition Period, Payment Token Services Regulation (primary, confirms the narrower/earlier transition and rules it out as the source of the 16 Sep 2026 date): https://rulebook.centralbank.ae/en/rulebook/article-40-transition-period ; independent secondary confirmations of Article 184 / Federal Decree-Law 6 of 2025, one appearing to quote CBUAE's own legislation explainer: https://www.glaco.com/blog/new-cbuae-law-no-6-of-2025-a-consolidated-overhaul-of-the-uae-financial-regulatory/ and https://chambers.com/articles/new-cbuae-law-no-6-of-2025-a-consolidated-overhaul-of-the-uae-financial-regulatory-framework ; original stored source retained: https://cms.law/en/are/legal-updates/the-new-cbuae-payment-token-services-regulation-10-things-you-need-to-know2
Difficulty rating Finland 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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Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.

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