• Mandatory Requirements — CBUAE

SVF Mandatory Licensing Requirements

Legal, prudential, float safeguarding, governance, AML, technology, and capital requirements every SVF issuer must meet before operating in the UAE.

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We Translate Regulation Into Implementation

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Regulatory perimeter analysis

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Capital planning (AED 15m + 5% Float)

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Governance buildout

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AML framework design

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Float safeguarding architecture

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Full application file management

We translate CBUAE SVF regulations into board-grade implementation: regulatory perimeter analysis, capital planning (AED 15m + 5% Float), governance buildout, AML framework design, float safeguarding architecture, and full application file management.

01 / Who Must Apply

Who Must Obtain an SVF Licence?

Any person issuing or operating a Stored Value Facility in the UAE (outside DIFC and ADGM) must obtain authorisation from the Central Bank before commencing operations.

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Carrying on SVF activity without a licence exposes the entity to regulatory sanctions, suspension orders, and enforcement action.

Regulated SVF Activities

  • Issuing stored value (prepaid electronic balances)
  • Operating non-device-based wallets (e-wallets)
  • Operating device-based stored value systems
  • Managing and safeguarding customer Float
  • Offering SVF schemes to UAE customers (incl. overseas targeting)

02 / Core Requirements

Core Licensing Requirements

SVF licensing is not a single filing — it is a multi-layered prudential assessment. Mandatory requirements fall into six pillars:

01

Legal & Corporate Structure

02

Capital & Prudential

03

Governance & Fit-and-Proper

04

AML / CFT Controls

05

Technology & Ops

06

Float Safeguarding

01

Legal & Corporate Structure Requirements

Shell or nominee structures without transparency will not satisfy licensing conditions.
  • Establish a UAE mainland legal entity (outside financial free zones)
  • Maintain physical premises in the UAE
  • Disclose Ultimate Beneficial Ownership (UBO)
  • Provide full shareholding transparency
  • Demonstrate lawful source of funds
  • Ensure constitutional documents permit SVF activity

02

Capital & Prudential Requirements

The SVF Regulation imposes a dual capital framework. Float growth directly increases capital exposure.

Base Requirement

AED 15M

Ongoing Requirement

≥ 5% of Float

Capital Must Be

  • Fully paid-up
  • Unencumbered
  • Deposited in a UAE-regulated bank
  • Excluding goodwill
  • Deducting accumulated losses

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Prudential best practice: maintain a 20–30% buffer above minimum.

03

Governance & Fit-and-Proper Requirements

Prior approval is required for Controlling Shareholders.

CBUAE Assesses

  • Competence of senior management
  • Integrity and reputation
  • Relevant financial services experience
  • Financial soundness
  • Regulatory history

Applicants Must Provide

  • CVs and supporting evidence
  • Role descriptions
  • Governance structure map
  • Board and committee charters

Key Roles Typically Required

CEO

Compliance Officer

MLRO

Finance Oversight

Risk Oversight

04

AML / CFT & Financial Crime Controls

AML frameworks must align with UAE federal AML legislation and FATF standards.
  • Enterprise-wide AML risk assessment
  • Risk-based customer due diligence (CDD)
  • Enhanced Due Diligence (EDD) for high-risk clients
  • Sanctions screening
  • Ongoing transaction monitoring
  • Suspicious Transaction Reporting (STR)
  • Recordkeeping framework

05

Technology & Operational Requirements

Technology maturity is a licensing condition — not a post-approval enhancement.
  • System architecture documentation
  • Technology risk assessment
  • Information security framework
  • Business Continuity & Disaster Recovery (BCDR) plan
  • Incident response framework
  • Access control management
  • Reconciliation systems

06

Float Safeguarding & Redemption Requirements

Float safeguarding is the core prudential focus of the SVF regime.

Float Must Be

  • Segregated from licensee's own funds
  • Reconciled on an ongoing basis
  • Protected from operational risks
  • Managed primarily for liquidity
  • Supported by documented redemption procedures

Licensees Must Demonstrate

  • Legal arrangements ensuring customer priority claim in insolvency
  • Sufficient liquidity for redemption at all times
  • Wind-down planning and execution capability

03 / Business Plan

Regulatory Business Plan Requirement

Applicants must submit a detailed Regulatory Business Plan. Under-capitalised or unrealistic projections commonly delay approval.

📈 Revenue projections

📉 Expense forecasts

📊 Float growth modelling

💰 Capital planning(AED 15m + 5%)

⚠️ Risk profile

👥 Client segmentation

🗺️ Product roadmap

🔒 Compliance infrastructure

04 / Recordkeeping

Recordkeeping & Disclosure Requirements

CBUAE may request records during inspection at any time. Mandatory systems must ensure:

  • Accurate books and records
  • Float reconciliation records
  • Customer ledger integrity
  • Marketing material retention
  • Complaint handling documentation
  • Audit trail capability

05 / Ongoing Obligations

Ongoing Licensing Obligations

Licensing is not a one-time approval. Material changes (ownership, governance, business scope) require regulatory approval.

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Continuous Capital Adequacy

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Maintenance of 5% Float Requirement

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Regulatory Reporting

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Incident Notification

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Supervisory Engagement

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Independent Compliance Review

06 / Common Failures

Common Licensing Failures

  • Underestimating Float-linked capital exposure
  • Weak segregation and safeguarding model
  • Incomplete source-of-funds documentation
  • Immature AML framework
  • Poor governance documentation
  • Unrealistic financial projections
  • Lack of UAE operational substance

07 / Our Services

How We Support SVF Licensing

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Regulatory Perimeter Analysis

Confirm SVF classification and licensing triggers

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Capital Modelling

AED 15m + 5% Float overlay calculations

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Float Safeguarding Architecture

Segregation, reconciliation, and redemption design

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Governance Framework Drafting

Board, committee, and Fit-and-Proper structures

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AML Implementation

Risk-based CDD, monitoring, and STR systems

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Technology Governance Structuring

IT, cyber, BCDR, and incident response alignment

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Application File Preparation

Production-ready licensing submissions

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Regulator Engagement

CBUAE query management and interview prep

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Post-Licence Compliance Buildout

Ongoing supervision and reporting readiness

Quick Takeaways

Key Facts

SVF licensing is mandatory before operation

Minimum paid-up capital: AED 15M

Ongoing capital ≥ 5% of Float

Float safeguarding is the core prudential pillar

Governance & AML readiness are essential

Supervision continues post-licence

08 / FAQs

Frequently Asked Questions

Is SVF licensing mandatory before launch?

Yes. No SVF activity may commence before licence issuance by the CBUAE.

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.

Can foreign wallet operators target UAE customers?

Targeted marketing to UAE customers may trigger licensing requirements. The CBUAE assesses cross-border exposure holistically.

Is capital reviewed after licensing?

Yes. Capital adequacy is subject to ongoing supervision, including periodic assessments and potential stress testing.

Get Started

Meet Every SVF Licensing Requirement

From regulatory perimeter analysis through capital modelling, governance buildout, AML implementation, and float safeguarding — we deliver board-grade licensing readiness under the CBUAE.

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