finpeel Answers · UAE · updated 2026-08-14
If the wallet meets the CBUAE definition of a Stored Value Facility (SVF), an onshore provider generally needs authorisation under the CBUAE Stored Value Facilities Regulation, subject to the regulation's scope and exclusions. Merely holding or passing funds is not, by itself, enough to conclude that a product is an SVF.
The key question is whether the product is a facility against which value is stored for later use, not simply whether money touches the platform. The legal structure of the stored value, who issues it, where it can be used and how customers redeem or spend it determine whether the SVF regime is engaged.
A wallet can also perform other regulated functions. For example, payment transfers, payment-account services or other retail payment services can engage the Retail Payment Services and Card Schemes Regulation, while payment-token activity can engage the Payment Token Services Regulation.
Do not use a simple rule such as 'customer money equals SVF'. Map the product against the current SVF definition and scope, then test separately for any retail-payment, open-finance or payment-token activity that sits beside it.
Regulator: Central Bank of the UAE (CBUAE)
Primary sources: CBUAE — Stored Value Facilities Regulation · CBUAE — Payment Token Services Regulation
Directional — not legal advice. Verify with the regulator before committing.
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