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Crypto (CASP / VASP) E-money (EMI)
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Dimension Pinned
🇩🇪 Germany partly open
Verified 2026-07-03
 🇦🇪 United Arab Emirates (Dubai - VARA) analogue partly open
Verified 2026-07-15
Licence type E-Geld-Institut under the ZAG.
Verified 2026-07-02 Source: BaFin
No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal.
Verified 2026-07-03 Source: CBUAE, https://rulebook.centralbank.ae/en/rulebook/retail-payment-services-and-card-schemes-regulation
Regulator BaFin, with the Deutsche Bundesbank.
Verified 2026-07-02 Source: BaFin, https://www.bafin.de/DE/Aufsicht/ZahlungsdienstePSD2/ZahlungsdienstePSD2_node.html
Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto.
Verified 2026-07-03 Source: CBUAE
Capital requirement Germany capital requirement is included in the £349 pass. United Arab Emirates (Dubai - VARA) capital requirement is included in the £349 pass.
Timeline to authorisation Germany 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 Germany local substance is included in the £349 pass. United Arab Emirates (Dubai - VARA) local substance is included in the £349 pass.
Application cost Germany application cost is included in the £349 pass. United Arab Emirates (Dubai - VARA) application cost is included in the £349 pass.
Ongoing cost Germany ongoing cost is included in the £349 pass. United Arab Emirates (Dubai - VARA) ongoing cost is included in the £349 pass.
Passporting Germany passporting is included in the £349 pass. United Arab Emirates (Dubai - VARA) passporting is included in the £349 pass.
EMIs authorised Germany emis authorised is included in the £349 pass. United Arab Emirates (Dubai - VARA) emis authorised is included in the £349 pass.
Key restrictions Germany key restrictions is included in the £349 pass. United Arab Emirates (Dubai - VARA) key restrictions is included in the £349 pass.
Safeguarding Germany safeguarding is included in the £349 pass. United Arab Emirates (Dubai - VARA) safeguarding is included in the £349 pass.
Recent changes PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file.
Verified 2026-07-03 Source: EU
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 Germany 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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