The licensing matrix

E-money institution licence (Konzession) under the E-Geldgesetz 2010 (E-Money Act 2010), Austria's EMD2 transposition; credit institutions licensed under the Banking Act (BWG) may also issue e-money without a separate EMI licence

Financial Market Authority Austria (Finanzmarktaufsicht, FMA)

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Etablissement de monnaie electronique (EME) under the Law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions (transposing EMD2/PSD2); a 'limited' e-money institution exemption tier (etablissement de monnaie electronique limite) also exists for small-scale issuers under Art. 111 of the same law

National Bank of Belgium (Banque Nationale de Belgique / Nationale Bank van Belgie, NBB/BNB)

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Electronic Money Institution licence under the Law on Payment Services and Payment Systems (Zakon za platezhnite uslugi i platezhnite sistemi), transposing EMD2; a small/exempt EMI registration tier also exists for issuers below EMD2 activity thresholds

Bulgarian National Bank (BNB) - Balgarska narodna banka

Bulgaria adopted the euro on 1 January 2026 at the fixed rate of EUR 1 to BGN 1.95583, with institutional capital converting into euro. PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Authorisation to issue electronic money under Croatia's Electronic Money Act (transposing EMD2); a distinct 'small electronic money institution' (mala institucija za elektronički novac) exemption tier exists for issuers below the EMD2 threshold, with its own HNB registration track

Croatian National Bank (Hrvatska narodna banka, HNB)

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Electronic Money Institution (EMI) authorisation under The Electronic Money Laws of 2012-2018 and The Provision and Use of Payment Services and Access to Payment Systems Laws of 2018 to 2025 (transposing EMD2/PSD2); a Small EMI / exempt tier also exists under the same framework for issuers below EMD2 thresholds

Central Bank of Cyprus (CBC) - Licensing Section

The Central Bank of Cyprus issued new 2025 EMI authorisation, governance and suitability directives. PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Electronic money institution licence under Act No. 370/2017 Coll. on Payment System (transposing EMD2); a separate 'small-scale electronic money issuer' (malý vydavatel elektronických peněz) exemption tier also exists for issuers below the EMD2 activity threshold

Czech National Bank (Česká národní banka, ČNB)

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Tilladelse som e-pengeinstitut under Lov om betalinger (Payment Services Act, LBK nr 1013 af 21/08/2024), transposing EMD2; a 'begraenset tilladelse til at udstede elektroniske penge' (limited/small e-money licence) exemption tier also exists for smaller-scale issuers

Finanstilsynet (the Danish Financial Supervisory Authority / Danish FSA)

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Operating licence (tegevusluba) for e-money institutions under the Payment Institutions and E-money Institutions Act (Makse- ja e-raha asutuste seadus, MERAS), Estonia's EMD2 transposition

Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, FSA)

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

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)

Finanssivalvonta (Financial Supervisory Authority, FIN-FSA)

FIN-FSA introduced a new 2026 payment-institution application model and fee schedule. PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Etablissement de monnaie electronique.

ACPR (part of the Banque de France). Not the AMF, which handles markets and crypto.

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

E-Geld-Institut under the ZAG.

BaFin, with the Deutsche Bundesbank.

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Authorised electronic money institution or registered electronic money institution under the Financial Services (Electronic Money) Regulations 2020. This is a full e-money regime rather than an analogue.

Gibraltar Financial Services Commission (GFSC).

LN 2026/053 took effect on 26 March 2026 and requires e-money institutions to notify the GFSC at least 30 days before declaring a dividend and obtain a no-objection. The Financial Services (Payment Services) (Amendment) Regulations 2026 and Financial Services (Electronic Money) (Amendment) Regulations 2026 were both made on 16 July 2026; their substantive effect remains review-needed because only their official titles and dates were retrievable.

Electronic money institution licence under Law 4021/2011 (Articles 9-30, Greece's EMD2 transposition) as updated by Law 4537/2018 (PSD2 transposition); Bank of Greece maintains a public register of Greek EMIs and of foreign EMIs passporting into Greece

Bank of Greece (Τράπεζα της Ελλάδος)

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584).

Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime.

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.

Authorisation for e-money issuing institutions (elektronikuspénz-kibocsátó intézmény) per MNB's dedicated licensing guide, Hungary's EMD2 transposition track, separate from payment institution licensing

Magyar Nemzeti Bank (MNB, Hungarian central bank, acting as financial supervisor)

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Operating licence for electronic money institutions under Iceland's Act No. 114/2021 on Payment Services (EMD2/PSD2 transposition, as an EEA EFTA state)

Central Bank of Iceland (Seðlabanki Íslands), Financial Supervisory Authority functions merged into the Central Bank of Iceland from 1 January 2020 (formerly Fjármálaeftirlitið / FME, a standalone authority 1999-2019)

Iceland's EEA implementation timing also depends on incorporation through the EEA Agreement. PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

E-Money Institution or Small E-Money Institution under the European Communities (Electronic Money) Regulations 2011.

Central Bank of Ireland (CBI).

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Istituto di Moneta Elettronica (IMEL), authorised under Legislative Decree 11/2010 / TUB (Testo Unico Bancario) implementing EMD2, per Banca d'Italia's 'Disposizioni di vigilanza per gli Istituti di Pagamento e gli IMEL'. No separate branded 'small IMEL' tier distinct from general PSD2 exemption thresholds was confirmed; Italy's framework centers on the full IMEL authorisation.

Banca d'Italia (Bank of Italy) - Vigilanza (Supervision) function

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

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)

Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023

Latvijas Banka continued granting new EMI licences during 2025 and 2026. PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

E-money institution licence under the E-Geldgesetz (EGG, E-Money Act of 17 March 2011), Liechtenstein's EMD2 transposition; FMA-Guidance 2018/18 sets out the licensing process

Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA)

Liechtenstein's EEA implementation timing also depends on incorporation through the EEA Agreement. PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania.

Bank of Lithuania (Lietuvos bankas).

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base.

Commission de Surveillance du Secteur Financier (CSSF)

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Electronic Money Institution under the Financial Institutions Act (Cap. 376).

Malta Financial Services Authority (MFSA).

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

No EMI. IFPE (Institucion de Fondos de Pago Electronico) under the Ley Fintech.

CNBV together with Banco de Mexico (Banxico).

Continuing CNBV and Banxico secondary rules. On 6 May 2026 Senator Alejandro Murat introduced a Senate bill to regulate peso-pegged stablecoins (Activos Virtuales Estables), naming authorised ITFs (including IFPEs) and credit institutions as permitted issuers under Banxico supervision; it remains a bill before committee, not enacted law.

Electronic Money Institution licence under the Dutch Financial Supervision Act (Wet op het financieel toezicht - Wft), implementing EMD2; an exempted/excepted EMI status also exists for smaller issuers who do not need a full DNB licence

De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor)

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

E-pengeforetak (e-money institution) licence under Lov om e-pengeforetak (Act on E-Money Institutions, 2002) and Forskrift om e-pengeforetak (Regulation on E-Money Institutions, 2011), transposing EMD2; no separate small/exempt e-money tier (unlike the limited-authorisation option available to payment institutions for low-volume money transfer only)

Finanstilsynet (The Financial Supervisory Authority of Norway)

Norway's EEA implementation timing also depends on incorporation through the EEA Agreement. PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Authorisation as a national electronic money institution (krajowa instytucja pieniądza elektronicznego), Poland's EMD2 transposition, granted and supervised by KNF, with entry into KNF's public register of payment service providers and e-money issuers (e-rup.knf.gov.pl)

Polish Financial Supervision Authority (Komisja Nadzoru Finansowego, KNF)

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Instituicao de Moeda Eletronica under the RJSPME (Decree-Law 91/2018).

Banco de Portugal.

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Authorisation as an electronic money issuing institution (instituție emitentă de monedă electronică) granted by BNR, Romania's EMD2 transposition track; BNR is also the designated competent authority for MiCA electronic money tokens (EMTs) issued by credit institutions and e-money institutions under its supervision

National Bank of Romania (Banca Națională a României, BNR)

Romania's BNR remains the e-money competent authority, separate from ASF's MiCA supervision. PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

No EMI. Major Payment Institution (MPI) licence under the Payment Services Act, covering e-money issuance and account issuance. Standard PI for smaller volumes.

Monetary Authority of Singapore (MAS).

Continuing MAS refinements to the PSA.

Permit (povolenie) to issue electronic money granted by NBS on the basis of a written application, Slovakia's EMD2 transposition; NBS maintains and supervises a register of licensed electronic money institutions

National Bank of Slovakia (Národná banka Slovenska, NBS)

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Approval (dovoljenje) to operate as an electronic money institution under the Payment Services, Electronic Money Issuing Services and Payment Systems Act (ZPlaSSIED), Slovenia's EMD2/PSD2 transposition; a 'hybrid' e-money institution designation exists for firms combining e-money issuance with other payment services or business activities

Bank of Slovenia (Banka Slovenije)

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Entidad de Dinero Electronico (EDE), authorised under Ley 21/2011, de 26 de julio, de dinero electronico, and Real Decreto 778/2012 (as amended by Real Decreto 736/2019). Spain recognises 'entidades de dinero electronico hibridas' (hybrid EMIs) and an exemption/light regime under art. 14 of Real Decreto-ley 19/2018 for small-scale e-money issuers below activity thresholds, analogous to a 'small EMI' tier.

Banco de Espana (Bank of Spain)

Spain will need to align its separate payment-institution and e-money statutes with the single PSD3 framework. PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

Tillstand att ge ut elektroniska pengar (e-money institution licence) under lagen (2011:755) om elektroniska pengar, transposing EMD2; a lighter-touch registration tier ('registrerad utgivare av elektroniska pengar' for small-scale issuers below EMD2 thresholds) also exists

Finansinspektionen (FI, the Swedish Financial Supervisory Authority)

PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 15 August 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.

No EMI. Closest is the FINMA FinTech licence (Banking Act Art. 1b), deposits up to CHF 100m, no interest, no lending. Larger operations need a banking licence.

FINMA.

Federal Council launched public consultation on 22 October 2025 on FinIA amendments to replace the FinTech licence with two new categories: a payment instrument institution licence (permitting stablecoin issuance, removing the CHF 100m deposit cap) and a crypto-institution licence. Consultation closed 6 February 2026. Entry into force expected in 2027 at the earliest, so the current FinTech licence and its CHF 100m cap remain in effect for now.

No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal.

Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto.

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.