finpeel Answers · UAE · updated 2026-08-14
It depends on what the gateway actually does. A pure technology layer can have a different outcome, but if the business itself performs a regulated service such as Payment Aggregation, Merchant Acquiring, funds transfer or another Retail Payment Service, CBUAE authorisation is required unless an exemption applies.
Do not decide the perimeter from the marketing label “gateway”. Map whether the company receives or controls funds, contracts with merchants for regulated payment services, acquires transactions or merely provides software to a licensed provider.
If the platform also provides Open Finance, stored value or payment-token functions, test those frameworks separately.
Regulator: Central Bank of the UAE (CBUAE)
Primary sources: CBUAE — Retail Payment Services and Card Schemes Regulation
Directional — not legal advice. Verify with the regulator before committing.
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