Pin and benchmark
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| Dimension |
Pinned 🇭🇰 Hong Kong analogue partly open Verified 2026-08-15
|
🇦🇪 United Arab Emirates (Dubai - VARA)
analogue
partly open
Verified 2026-07-15
|
|---|---|---|
| Licence type | No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584). | No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal. |
| Regulator | Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime. | Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto. |
| Capital requirement | Hong Kong capital requirement is included in the £349 pass. | United Arab Emirates (Dubai - VARA) capital requirement is included in the £349 pass. |
| Timeline to authorisation | Hong Kong 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 | Hong Kong local substance is included in the £349 pass. | United Arab Emirates (Dubai - VARA) local substance is included in the £349 pass. |
| Application cost | Hong Kong application cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) application cost is included in the £349 pass. |
| Ongoing cost | Hong Kong ongoing cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) ongoing cost is included in the £349 pass. |
| Passporting | Hong Kong passporting is included in the £349 pass. | United Arab Emirates (Dubai - VARA) passporting is included in the £349 pass. |
| EMIs authorised | Hong Kong emis authorised is included in the £349 pass. | United Arab Emirates (Dubai - VARA) emis authorised is included in the £349 pass. |
| Key restrictions | Hong Kong key restrictions is included in the £349 pass. | United Arab Emirates (Dubai - VARA) key restrictions is included in the £349 pass. |
| Safeguarding | Hong Kong safeguarding is included in the £349 pass. | United Arab Emirates (Dubai - VARA) safeguarding is included in the £349 pass. |
| Recent changes | 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. | 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 | Hong Kong difficulty rating is included in the £349 pass. | United Arab Emirates (Dubai - VARA) difficulty rating is included in the £349 pass. |
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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