UAE licensing and functions
Which licence or registration covers each regulated function.
Licensing decision tree by venue
Function matrix
| Function | Authority / rule | Operational note |
|---|---|---|
| Issue AED stablecoin | CBUAE Art. 5, Art. 26 | DPT issuer + accepted white paper. |
| Issue foreign payment token into UAE | CBUAE Art. 5 | Federal issuer route still applies. |
| Convert payment tokens | CBUAE Art. 5, Art. 8 | Licence or non-objection path. |
| Custody / transfer of payment tokens | CBUAE Art. 5, Art. 23 | Federal safeguarding layer. |
| Issue FRT in ADGM | ADGM FRT | Distinct regulated activity in ADGM. |
| Use FRT in ADGM activity | ADGM VA Guidance | Accepted FRT only. |
| Provide VA custody / dealing in ADGM | ADGM VA Guidance | FSP required for each activity set. |
| Use non-fiat crypto tokens in DIFC | DFSA GEN 3A.2.1 | Firm-led suitability since 2026-01-12. |
| Use Fiat Crypto Tokens in DIFC | DFSA Policy | DFSA-suitable fiat token only. |
| Provide crypto-token custody in DIFC | COB 15.4 | Client-asset controls attach. |
| Issue VA in Dubai | VARA Issuance, Category 1 | Category 1 issuance requires licence. |
| Market into Dubai | VARA Marketing | Applies to domestic and foreign entities. |
| Offer qualified-only products in Dubai | VARA QI circular | Classification + suitability + consent. |
| Operate as VASP outside Dubai | CMA–VARA cooperation | Federal lane outside VARA perimeter. |
| Security / commodity token outside ADGM | CMA consultation | Draft, not final. |
| Cross-border settlement chain | CBUAE PTSR + venue rulebook | Each step needs its own permission basis. |