UNITED ARAB EMIRATES Law and Practice Contributed by: Arnold Krutilins and Gabrielle Margerison (nee Lowe), White & Case LLP
• the CBUAE’s key criteria for designating a retail payment service; • the licensing and designation process for retail payment services; and • the ongoing requirements of designated retail pay - ment services. Retail Payment Services and Card Schemes Regulation (the “RPSCS Regulation”) This framework applies to retail payment service pro - viders and card scheme providers, setting out the conditions applicable to the granting and maintaining of licences to carry out retail payment services and card schemes in “onshore UAE”, the ongoing obli - gations of retail payment service and card scheme providers and the powers of the CBUAE with respect to the supervision of retail payment service provid - ers and the ongoing reporting requirements for card schemes. “Onshore UAE” – Virtual Assets In “onshore UAE”, virtual assets fall under the jurisdic - tion of the CMA, the VARA and the CBUAE. The CMA The CMA is responsible for overseeing the regula - tion of virtual assets and related services pursuant to Cabinet Decision No 111/2022 (the “VA Decision”). According to the VA Decision, any person that wishes to carry out virtual asset-related activities must obtain a licence from the CMA (or the competent authority at the emirate level (where one exists)). In July 2024, the SCA (now CMA) issued its guidelines relating to the Regulation of Virtual Assets and Virtual Assets Service Providers. On 1 January 2026, the CMA Law reconsti - tuted the SCA as the CMA. In parallel, the Capital Mar - kets Law introduced a revised federal framework for onshore capital markets regulation. The new regime expands the perimeter for regulated financial activities and increases administrative and criminal sanctions for market misconduct. Pre-existing Cabinet decision and SCA resolutions continue to apply to the extent not conflicting with the CMA Law and the Capital Mar - kets Law, until replaced or repealed. The VARA The VARA is the authority responsible for regulating, supervising and overseeing virtual assets and related
activities in the emirate of Dubai (excluding the DIFC), in line with the Dubai Virtual Assets Law (the “DVAL”) and its Executive Regulations and Rulebooks. In 2023, the DVAL rolled out its comprehensive virtual asset licensing framework and a number of global market players obtained full operational licences. In May 2025, VARA published Version 2.0 of its activity-based Rulebooks, including strengthened controls around margin trading and token distribution services, with a transition period for impacted VASPs to implement The CBUAE is responsible for regulating activities relating to payment tokens (ie, stablecoins) pursuant to the RPSCS Regulation, while the CBUAE’s Stored Value Facilities Regulation (the “SVF Regulation”) reg - ulates crypto and virtual assets insofar as they may be accepted in exchange for the storage of value. In June 2024, the CBUAE published the PTS Regulation which established a comprehensive framework for licensing and supervising digital payment services. It covers: • payment token issuance; • payment token conversion; and • payment token custody and transfer. “Offshore UAE” – Virtual Assets and Payment Services In the ADGM, the Financial Services Regulatory Authority (the “FSRA”) regulates virtual assets and virtual asset-related activities. The FSRA’s “Virtual Asset Framework” sets out provisions targeting a range of risks associated with virtual asset-related activities, including risks relating to money laundering and financial crime, consumer protection, technology governance, custody and exchange operations. The FSRA subsequently issued “Guidance – Regulation of Virtual Asset Activities in ADGM” to provide further support to persons when carrying out virtual asset- related activities in the ADGM to interpret its rules and regulations. Payment services are also regulated by various ADGM regulations and FSRA rules. In 2025, the FSRA implemented amendments to its digital asset framework (including changes to the process for “accepted virtual assets”) and, in late 2025, final - ised rule changes relating to fiat-referenced tokens, effective 1 January 2026. the updates. The CBUAE
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