• SVF Capital — CBUAE

Capital Requirements for SVF Licence

Minimum paid-up capital, float-linked capital maintenance, prudential buffers, and how to structure your Stored Value Facility licence under the CBUAE.
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We Deliver

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Board-ready capital models

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Float-exposure calculations

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Capital maintenance dashboards

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Stress tests & liquidity modelling

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Capital commitment letters

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Regulator-facing confirmation packs

We turn CBUAE SVF capital rules into board-ready models, float-exposure calculations, capital maintenance dashboards, stress tests, capital commitment letters, and regulator-facing confirmation packs.

01 / Why Capital Matters

Why Capital Matters Under the SVF Regime

The CBUAE applies a prudential, float-sensitive capital framework to SVF licensees. Capital is not symbolic — it determines your ability to operate, grow, and maintain regulatory standing. Unlike transaction-tiered regimes, SVF capital is float-centric and prudentially driven.

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Your ability to hold customer Float

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Supervisory intensity

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Governance expectations

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Liquidity sustainability

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Wind-down readiness

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Grant & refuse licences

02 / At a Glance

The Capital Requirements — At a Glance

Capital must be fully paid-up, unencumbered, permanently available, and held in eligible capital form.

Requirement

Threshold

Minimum Paid-Up Capital

AED 15M

Ongoing Aggregate Capital Funds

≥ 5% of total Float

Eligible Capital Items

Paid-up capital + Reserves (excl. revaluation) + Retained earnings

Deductions

Accumulated losses + Goodwill

Requirement 01

Base Capital

AED 15M

The fixed prudential floor. Every SVF licensee must maintain this minimum paid-up capital at all times.

  • Deposited in a UAE-regulated bank
  • Free from encumbrances
  • Not dependent on short-term shareholder loans
  • Supports operational continuity & insolvency resilience

Requirement 02

Float-Linked Capital — 5% Rule

≥ 5% of total Float

In addition to paid-up capital, Aggregate Capital Funds must equal or exceed 5% of total customer Float.

  • Scales with business growth automatically
  • Increases as Float increases
  • Requires continuous monitoring
  • Most common area of operator underestimation

03 / Aggregate Capital Funds

Understanding Aggregate Capital Funds

If accumulated losses reduce capital below required levels, remediation is mandatory.
  • Eligible Capital Components
  • Paid-up capital
  • Reserves (excluding revaluation reserves)
  • Retained earnings
  • Mandatory Deductions
  • Accumulated losses
  • Goodwill

04 / Critical Distinction

Float vs Capital — Critical Distinction

Float safeguarding is separate and mandatory. Capital does not replace float protection.

Capital

  • Licensee's own funds
  • Prudential buffer
  • Supports sustainability
  • Risk absorption

Float

  • Customer funds
  • Redemption obligation
  • Must be segregated
  • Cannot be used for operations

05 / Beyond Minimum

Prudential Best Practice

CBUAE sets minimum thresholds. Prudential governance requires more. Operating at bare minimum invites supervisory scrutiny.

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Capital Buffer ≥ 20–30%

Above regulatory minimum

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Float Growth Stress Modelling

Project capital needs at scale

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12-Month Liquidity Runway

Operational continuity assurance

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Quarterly Stress Testing

Scenario-based capital assessment

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Board-Approved Capital Policy

Governance documentation

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Capital Coverage Ratio ≥ 1.25

Prudential headroom target

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Operating at bare minimum invites supervisory scrutiny. We recommend building buffers that demonstrate prudential maturity to the CBUAE.

06 / Growth Scenarios

Capital & Float Growth Scenarios

The 5% rule can exceed the AED 15m base over time. Rapid growth = rapid capital pressure.

Float Level

5% Capital Required

Relative Pressure

AED 50m

AED 2.5m

Below base

AED 100m

AED 5m

Below base

AED 250m

AED 12.5m

Approaching base

AED 500m

AED 25m

Exceeds AED 15m base

07 / Source of Funds

Source of Funds & Regulatory Expectations

Capital must be permanent and regulator-available. The CBUAE expects full transparency on the origin, structure, and governance of capital.

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Transparent UBO structure

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Legitimate source of funds

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Auditor confirmation (where required)

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No encumbrances

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Board capital approval resolution

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Capital contingency plan

08 / Regulatory Scrutiny

What CBUAE Will Examine

Capital adequacy is ongoing supervision — not a one-time filing.

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Is paid-up capital genuinely available?

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Is the 5% Float calculation accurate?

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Are capital deductions properly applied?

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Is capital buffer adequate?

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Is Float reconciliation robust?

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Can the firm survive stress scenarios?

09 / Common Mistakes

Common Structuring Mistakes

These are the errors we see most frequently during SVF capital structuring. Each one can delay or derail your licensing application.
  • Underestimating Float growth impact
  • Ignoring 5% escalation exposure
  • Relying on shareholder loans not converted into capital
  • Operating at bare minimum capital
  • Failing to model accumulated loss impact
  • Weak capital governance documentation

10 / Our Services

Our Capital Structuring Support

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SVF Capital Modelling

AED 15m + 5% overlay calculations

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Float Growth Stress Testing

Scenario-based capital projections

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Capital Adequacy Dashboards

Real-time monitoring frameworks

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Commitment Templates

Shareholder capital commitment letters

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Board Capital Resolutions

Governance-ready board documentation

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Confirmation Letters

Regulator-ready capital confirmations

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Float Governance Frameworks

Segregation and reconciliation design

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Wind-Down Modelling

Liquidity and exit scenario planning

Quick Takeaways

Key Capital Facts

AED 15M

Minimum paid-up capital

≥ 5%

Ongoing capital vs total Float

Goodwill Excluded

From eligible capital calculation

Losses Deducted

Accumulated losses reduce capital

Scales With Float

Growth increases capital exposure

Min ≠ Prudent

Minimum capital ≠ prudent capital

11 / FAQs

Frequently Asked Questions

Is the AED 15m capital negotiable?

No. It is the fixed paid-up capital floor mandated by the CBUAE. There is no discretion to reduce this threshold.

Does the 5% Float rule replace paid-up capital?

No. It is in addition to the AED 15m requirement. Both thresholds must be met concurrently at all times.

Can retained earnings count toward capital?

Yes, provided accumulated losses and goodwill deductions are properly applied first. Net retained earnings after deductions contribute to eligible aggregate capital funds.

Is capital reviewed after licensing?

Yes. Capital adequacy is subject to continuous supervision, including ongoing reporting, periodic assessments, and potential stress testing at the CBUAE’s discretion.

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Structure Your SVF Capital Correctly

From AED 15m base capital through float-linked 5% modelling, stress testing, and regulator-facing packs — we deliver board-ready capital frameworks that satisfy CBUAE expectations.

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