- SVF & PTS — CBUAE
SVF & PTS Under the CBUAE
How Stored Value Facilities and Payment Token Services intersect under the Central Bank of the UAE — and what it means for wallet operators, stablecoin issuers, and fintech platforms.
We Analyse
⏳
Regulatory perimeter triggers
💰
Capital exposure (AED 15m + 5% vs PTS tiers)
🏛️
Custody architecture
⚠️
Reserve governance
🔄
Safeguarding mechanics
⚙️
Dual-licence structuring
01 / The Big Picture
One Regulator, Two Distinct Prudential Regimes
Both SVF and PTS are regulated by the CBUAE. They are not interchangeable — they regulate different forms of "stored value." Understanding the boundary is critical before launching wallet or token functionality.
Stored Value Facilities
SVF
Typical Models
- E-wallets holding AED balances
- Prepaid cards
- Super apps with stored fiat balances
- Marketplace wallets holding customer funds
Prudential Core
- Minimum paid-up capital: AED 15M
- Ongoing capital: ≥ 5% of Float
- Float segregation mandatory
- Redemption certainty required
⬤ SVF is Float-focused.
Payment Token Services
PTS
Regulated Activities
- Issuing Payment Tokens (e.g., stablecoins)
- Facilitating exchange of Payment Tokens
- Merchant acceptance of Payment Tokens
- Custody of Payment Tokens
- Buying/selling Payment Tokens
Prudential Core
- Category I licensing under RPSCS
- Tiered capital based on transaction volume
- White paper approval (for issuance)
- Reserve governance & enhanced AML
⬤ PTS is token-centric.
02 / Where They Overlap
Where SVF and PTS Intersect
The regimes may intersect where a platform combines fiat storage with token functionality. Each scenario requires distinct regulatory treatment.
01
A Wallet Holds Fiat and Tokens
Fiat Storage → SVF
+
Token Storage → PTS
02
A Stablecoin Is Backed by Fiat Float
Token Issuance → PTS
+
Float Protection → SVF
03
Fiat-to-Token Conversion Inside a Wallet
Fiat → SVF
+
Token → PTS
⚠ Capital Escalation
03 / Capital Comparison
Capital Comparison — SVF vs PTS
SVF capital scales with Float. PTS capital scales with activity and transaction exposure.
Requirement
SVF
PTS
Base Capital
AED 15M
Category I thresholds
Ongoing Capital
≥ 5% of Float
Transaction-based tier
Float / Reserve Segregation
Mandatory
Reserve governance required
White Paper
No
Required for issuance
Custody Controls
Float-focused
Key management-focused
Escalation Trigger
Float growth
Transaction volume growth
04 / Decision Tree
Structuring Decision Tree
Misclassification can lead to capital miscalculation, licensing rejection, enforcement exposure, and banking disruption.
1
Are customers prepaying fiat stored electronically?
→ Likely SVF
2
Are you issuing blockchain-based payment tokens?
→ PTS
3
Are you doing both?
→ Dual exposure
4
Are tokens merely accepted but not issued or custodied?
→ Perimeter analysis
05 / Prudential Differences
Prudential Focus — Side by Side
The supervisory lens differs materially between the two regimes.
SVF Prudential Focus
- Protection of customer Float
- Redemption certainty
- Insolvency priority
- Liquidity sufficiency
PTS Prudential Focus
- Token reserve integrity
- Market integrity
- Custody security
- Blockchain transparency
- Cross-border AML risk
06 / Common Mistakes
Common Structuring Mistakes
- Assuming a stablecoin wallet automatically qualifies as SVF
- Treating token reserves as "float" under SVF
- Launching fiat wallet first, adding tokens later without licence variation
- Underestimating capital escalation when token features are added
- Ignoring white paper approval obligations
07 / Dual Exposure
When You May Need Both
Regulatory structuring should be undertaken before launch.
A super app holds fiat wallet balances and stablecoins
A payment platform issues proprietary tokens backed by fiat
A marketplace holds fiat funds and settles merchants in tokens
A wallet allows token custody alongside fiat storage
08 / Our Services
How We Structure SVF–PTS Models
🔬
Regulatory Perimeter Mapping
Classify model under SVF, PTS, or both
🔄
Dual-Licence Feasibility
Assess viability of combined licensing
📊
Capital Modelling
AED 15m + 5% vs PTS tier analysis
🛡️
Float vs Reserve Architecture
Design safeguarding for both regimes
🏛️
Governance Alignment
Cross-regime governance frameworks
⚖️
AML Risk Segmentation
Token-enhanced AML frameworks
📝
White Paper Drafting
PTS issuance documentation support
🤝
Regulator Engagement
Full CBUAE application management
Quick Takeaways
Key Facts
SVF regulates stored fiat value
PTS regulates blockchain-based payment tokens
Both supervised by CBUAE
Capital frameworks differ materially
Dual exposure requires deliberate structuring
Adding tokens = regulatory reclassification
09 / FAQs
Frequently Asked Questions
No. Blockchain-based Payment Tokens fall under PTS, not SVF. The distinction is between fiat stored value and token-based instruments.
Yes, but this may trigger Category I licensing under PTS and significant capital escalation. Licence variation is required before launching token features.
No. They are subject to separate reserve governance rules. Float protection concepts under SVF do not substitute for PTS reserve requirements.
Yes, but structuring must align capital, governance, and AML frameworks across both regimes. Dual-licence feasibility should be assessed before application.
Get Started
Structure Your Fiat + Token Model Correctly
Whether your platform handles fiat storage, token issuance, or both — we map the regulatory perimeter, model capital exposure, and manage dual-licence structuring under the CBUAE.