Author: Neethi Zenith, Senior Legal Consultant, Al Adly & Co
KEY TAKEAWAYS
For businesses evaluating UAE crypto licensing, fintech expansion or payment infrastructure opportunities, the key implications are as follows:
- Crypto.com is the first publicly announced VASP to receive a full CBUAE Stored Value Facilities licence.
- The development reinforces the distinction between VARA-regulated virtual asset activity and CBUAE-regulated payment services.
- Businesses offering wallet functionality, stored value, merchant acceptance or payment settlement may need to assess both regulatory frameworks.
- The approval creates a practical pathway for VASPs seeking regulated payment functionality in the UAE.
- Dirham-backed stablecoins are beginning to move into regulated commercial payment environments.
- UAE crypto licensing should be analysed at the product design stage rather than after launch.
Why the SVF Licence Matters
The Stored Value Facilities framework, governed by the Central Bank of the UAE, regulates digital wallets and prepaid payment instruments that hold customer funds for future use.
Until now, no publicly announced Virtual Asset Service Provider had received a full SVF licence from the CBUAE. Crypto.com secured in-principle approval in October 2025 and full authorisation on 11 May 2026.
To understand why this matters, it is important to distinguish between the UAE’s two primary regulatory layers for digital asset businesses:
License or regime | Primary Regulator | Core Function | BUSINESS RELEVANCE |
|---|---|---|---|
VARA Licence | Dubai Virtual Assets Regulatory Authority | Virtual Asset Services, including Exchange, Brokerage and Custody | Essential for many Dubai-based VASP Models |
CBUAE SVF licence | Central Bank of the UAE | Stored Value Facilities, Digital Wallets and Prepaid Instruments | Relevant where Customer value, Wallet use or Settlement is involved |
CBUAE-Approved Dirham-Backed Stablecoin Use | Central Bank of the UAE | Settlement or Payment Value Linked to UAE Dirhams | Relevant for regulated Payment flows and Merchant-facing Models |
Holding both licences positions Crypto.com to operate across a broader spectrum of regulated digital asset activity in the UAE, from exchange and custody services through to regulated payment infrastructure and settlement functionality.
For businesses evaluating market entry, the distinction is increasingly important because virtual asset permissions do not automatically extend to regulated payment functionality, stored value arrangements or settlement services. Regulatory treatment often depends on customer fund flows, custody arrangements, redemption mechanics, settlement processes and the overall operating model.
Based on publicly available announcements at the time of writing, Crypto.com appears to be the first publicly disclosed VASP in the UAE to hold both a VARA licence and a full CBUAE SVF licence.
Commercial Use Cases
The SVF licence directly activates or advances several commercial arrangements that were previously pending regulatory approval. Each reflects deeper integration of digital assets into regulated payment environments within the UAE economy.
Active now: Dubai Department of Finance
Dubai’s Department of Finance announced a partnership framework enabling certain government-related payment flows through Crypto.com infrastructure, subject to implementation procedures and regulatory parameters.
All settlement activity is conducted in UAE dirhams or CBUAE-approved dirham-backed stablecoins, insulating government accounts from cryptocurrency price volatility.
The initiative aligns with the Dubai Cashless Strategy, which targets 90% cashless transactions across public and private sectors. According to public statements by Dubai officials, the transition is expected to contribute at least AED 8 billion annually to the emirate’s economy.
Pending approval: Emirates Airlines
A memorandum of understanding signed in July 2025 in the presence of HH Sheikh Ahmed bin Saeed Al Maktoum contemplates the integration of Crypto.com Pay into Emirates’ booking systems.
If implemented following final approvals, Emirates could become one of the world’s largest airlines to facilitate regulated crypto-linked payment functionality. Final CBUAE approval remains pending.
Pending approval: Dubai Duty Free
According to public announcements and memoranda of understanding signed in 2025, Crypto.com’s payment infrastructure may eventually extend to both physical retail stores and online platforms at Dubai International Airport.
If approved and implemented, the arrangement could enable regulated crypto-funded retail transactions at one of the world’s busiest aviation hubs.
Importantly, the SVF framework does not replace existing virtual asset regulations. Businesses engaging in virtual asset activities may still require separate authorisations depending on the nature of the activity, customer flows, custody arrangements and settlement mechanics.
What This Signals
The licence reflects more than a single company milestone.
First, the market appears to be moving toward a more segmented regulatory structure, with businesses seeking both virtual asset activity and regulated payment functionality potentially requiring parallel approvals from VARA and the CBUAE.
Second, the CBUAE is actively engaging with VASPs. The progression from in-principle approval in October 2025 to full authorisation in May 2026 shows that the CBUAE now has an operational pathway for authorising regulated payment activity connected to virtual asset businesses.
Third, the approval process appears staged and compliance-heavy. Crypto.com first secured a VARA licence before pursuing SVF approval, which suggests that regulatory credibility and operational readiness are important prerequisites before payment functionality linked to digital assets is authorised.
Fourth, dirham-backed stablecoin infrastructure is now entering live commercial environments. This is a practical development, not a theoretical one, and it shows how regulated digital asset settlement may function within broader payment ecosystems.
Fifth, competitive dynamics among UAE VASPs may shift materially. As the only publicly announced VASP currently holding an SVF licence, Crypto.com appears to hold an early advantage in regulated digital asset payment infrastructure within the UAE market. Whether other VASPs pursue similar approvals will shape the next phase of the sector.
What It Means For Market Participants
For businesses evaluating UAE crypto licensing or Dubai fintech expansion, the distinction between trading permissions and regulated payment functionality is increasingly important. Regulatory analysis should also focus on how value moves through the system, who controls customer funds and how settlement occurs.
VASPs
The SVF route now appears established. VASPs with robust compliance frameworks and an existing VARA licence have a clearer reference point for pursuing regulated payment functionality through the CBUAE framework.
Sequencing and compliance expectations should not be overlooked. The development reinforces the importance of strong VARA compliance foundations before expanding into broader payment and settlement activity.
Fintech Operators
The integration of dirham-backed stablecoins into government-related payment flows creates a live regulatory precedent. Businesses building payment infrastructure around CBUAE-approved stablecoins now have a government-linked operational reference model.
This is a clear example of stablecoin functionality moving into regulated commercial use within the UAE.
New Entrants
Businesses entering the UAE digital asset market should assess both VARA and CBUAE frameworks at the earliest structuring stage. VARA regulates virtual asset activities, while the CBUAE payment services framework governs stored value and regulated payment functionality.
Businesses that assess both frameworks during the design phase are better positioned to avoid licensing delays, restructuring, banking challenges and post-launch compliance remediation.
Merchants and Payment Participants
The proposed Emirates and Dubai Duty Free integrations, still subject to final CBUAE approval, could materially expand regulated crypto-linked payment acceptance across major UAE commercial environments.
Businesses participating in payments, retail infrastructure, hospitality, aviation or digital commerce should monitor these developments closely.
Al Adly & Co. Perspective
This development reinforces a point we consistently discuss with fintech and digital asset clients: regulatory mapping is not the final step before launch, it is the starting point.
The Crypto.com SVF approval demonstrates that the UAE’s digital asset regulatory environment is moving into operational payment infrastructure. For well-prepared applicants, this creates significant opportunities. For businesses that underestimate regulatory mapping, governance requirements or payment-services implications, it may also create significant compliance risk.
At the same time, the governance, compliance and operational investment required to reach that stage remains substantial.
For founders, operators and investors, the better question is not whether a crypto product is generally possible. The better question is whether the proposed customer journey, transaction flow, custody structure, settlement mechanism and supporting documentation are correctly mapped against the relevant UAE regulatory frameworks.
Planning a Venture
Whether you are launching a virtual asset platform, integrating digital asset payments, building a wallet solution, exploring stablecoin settlement or expanding an existing fintech business into the UAE, regulatory planning should begin before product launch.
Al Adly & Co. advises founders, fintech operators, investors and digital asset businesses on UAE crypto licensing, VARA applications, CBUAE regulatory requirements, payment services frameworks, AML/CFT compliance and cross-border structuring.
Contact Al Adly & Co. to assess your regulatory pathway and identify applicable licensing requirements for your UAE market-entry, expansion or product-launch strategy. Early regulatory analysis can reduce licensing delays, restructuring costs and compliance risk.
Disclaimer
This article is provided for general informational purposes only and does not constitute legal or regulatory advice. Requirements relating to virtual assets, payment services, fintech activities and stablecoin infrastructure in the UAE may change and depend on the specific business model and operating structure involved. Specific legal advice should be obtained before undertaking regulated activities.
Speak to the Team at Al Adly & Co.
If you would like to assess your regulatory exposure under UAE cybercrime, fintech, or virtual asset laws, the team at Al Adly & Co. advises businesses operating across mainland UAE, DIFC, ADGM, and VARA-regulated environments.
Ahmed Adly and his team provide legal guidance on cybercrime risk, regulatory compliance, and crypto-related structuring for companies operating in the UAE digital economy.
Neethi Zenith
Senior Legal Consultant
Neethi Zenith is a Legal Consultant at Al Adly & Co, where she advises founders, executives, and investors on corporate structuring, regulatory compliance, and cross-border legal strategy across the UAE and Egypt.
Her work focuses on turning complex legal requirements into clear, executable strategies, helping businesses enter, operate, and scale in high-growth markets with confidence.