- SVF & RPSCS — CBUAE
SVF & RPSCS Under the CBUAE
How Stored Value Facilities and the Retail Payment Services & Card Schemes Regulation interact — and how to structure your payment model without triggering unintended capital or licensing exposure.
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SVF & RPSCS licensing triggers
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Capital thresholds (AED 15m + 5% vs Cat I–IV)
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Safeguarding obligations
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Supervisory escalation pathways
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Dual-regime structuring strategy
01 / The Big Picture
Two Payment Regimes, One Regulator
Both SVF and RPSCS are regulated by the Central Bank of the UAE. They are complementary but distinct regimes. Understanding which applies — or whether both apply — is critical before launching a payment product.
Stored Value Facilities
SVF
Common Models
- E-wallets storing AED balances
- Prepaid cards
- Closed-loop retail wallets
- Marketplace platforms holding balances
Prudential Characteristics
- Minimum paid-up capital: AED 15M
- Ongoing capital: ≥ 5% of total Float
- Mandatory Float segregation
- Redemption certainty & liquidity controls
⬤ SVF is Float-focused.
Retail Payment Services & Card Schemes
RPSCS
Payment Services Covered
- Payment Account & Instrument Issuance
- Merchant Acquiring & Aggregation
- Domestic & Cross-Border Fund Transfers
- Payment Initiation & Account Info Services
- Payment Token Services (Category I)
Prudential Characteristics
- Tiered capital (Category I–IV)
- Transaction-volume-based escalation
- Safeguarding & AML/CFT compliance
- Operational resilience
⬤ RPSCS is transaction-focused.
02 / Where They Intersect
Where SVF and RPSCS Intersect
Overlap occurs when a business both stores prepaid funds (SVF) and provides payment services beyond mere storage (RPSCS). Dual analysis is required in these scenarios.
SVF
RPSCS
Wallet + Merchant Acquiring
If a wallet holds Float and also acquires merchants, dual analysis is required.
SVF
RPSCS
Wallet + Fund Transfer
If stored value is used to facilitate domestic or cross-border transfers, RPSCS may apply in addition to SVF.
SVF
RPSCS
Prepaid + Payment Aggregation
Aggregation activity may fall under RPSCS even if stored value is governed by SVF.
03 / Key Distinctions
Key Regulatory Distinctions
SVF protects customer value. RPSCS regulates payment activity.
Feature
SVF
RPSCS
Core Focus
Stored prepaid value
Payment service execution
Capital Model
AED 15m + 5% Float
Category-based tier
Escalation Trigger
Float growth
Transaction volume
Safeguarding
Float segregation
Client fund protection
Redemption Obligation
Mandatory
Not always applicable
Supervisory Lens
Liquidity & insolvency risk
Transactional & systemic risk
04 / Decision Checklist
Structuring Decision Checklist
Four questions to determine your regulatory perimeter. Misclassification can result in under-capitalisation, enforcement exposure, and application rejection.
1
Are customers pre-funding balances stored electronically?
→ SVF likely
1
Are you executing transfers or acquiring merchants?
→ RPSCS likely
1
Are you only holding value without facilitating transfers?
→ SVF only
1
Are you combining wallet storage with fund transfers?
→ Dual exposure
05 / Capital Comparison
Capital Comparison — SVF vs RPSCS
SVF capital typically exceeds lower RPSCS categories. Float-heavy models can become capital-intensive quickly.
Pure SVF Wallet
AED 15m + 5% Float
SVF + PSP Combined
Higher prudential
Category I PSP
AED 1.5m – 3m
Category II PSP (Cross-Border)
AED 1m – 2m
Category III PSP (Domestic)
AED 500k – 1m
06 / Supervisory Intensity
Supervisory Intensity Scale
As Float increases, liquidity and redemption oversight intensify.
Low
Category IV
(Payment Initiation)
Moderate
Category III
(Domestic PSP)
High
Category II
(Cross-Border PSP)
Very High
SVF with
Large Float
07 / Common Mistakes
Common Structuring Mistakes
- Assuming every wallet is an RPSCS payment account
- Ignoring SVF Float obligations
- Structuring acquiring under SVF without RPSCS licence
- Underestimating 5% Float capital escalation
- Expanding from storage into transfers without licence variation
08 / Dual Exposure
When You May Need Both Regimes
Regulatory perimeter analysis should be conducted before scaling.
A wallet stores prepaid funds and facilitates transfers
A marketplace holds balances and pays merchants
A fintech holds customer funds and executes cross-border remittance
A super app combines stored value, acquiring, and fund transfers
09 / Our Services
How We Structure SVF–RPSCS Models
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Regulatory Classification
Map your model to SVF, RPSCS, or both
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Capital Modelling
AED 15m + 5% vs Category tier analysis
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Float Safeguarding
Segregation architecture design
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Client Fund Protection
RPSCS safeguarding alignment
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Governance Design
Framework for dual-regime compliance
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AML Risk Segmentation
Cross-regime AML framework
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Licence Variation Strategy
Expansion pathway planning
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Application Management
Full CBUAE filing for both regimes
Quick Takeaways
Key Facts
SVF regulates stored prepaid value
RPSCS regulates payment service execution
Both fall under CBUAE supervision
Capital frameworks differ materially
Storage + transfers may trigger dual exposure
Proper structuring prevents capital inefficiency
10 / FAQs
Frequently Asked Questions
No. If it only stores prepaid value, it may fall under SVF exclusively. The regulatory classification depends on the specific activities performed.
No. They regulate different activities. SVF governs stored prepaid value; RPSCS governs payment service execution. Both may apply simultaneously.
Yes, where the business model requires it. Firms combining storage with payment services may need dual licensing under both regimes.
SVF generally has a higher fixed capital floor (AED 15m + 5% Float) compared to RPSCS category-based tiers, which start from AED 500k.
Get Started
Structure Your Payment Model Correctly
Whether your model triggers SVF, RPSCS, or both — we map the regulatory perimeter, model capital exposure, and manage the full licensing process under the CBUAE.