What is
an SVF?
A Stored Value Facility (SVF) is an arrangement — licensed by the Central Bank of the UAE under the Stored Value Facilities Regulation — in which a customer loads money or money's worth in advance, held as a balance that can later be used to pay for goods and services or transfer funds. Consumer wallets, prepaid accounts and closed-loop balances above the exempt thresholds are the classic cases.
Who needs an SVF licence?
Businesses issuing reloadable wallets or prepaid balances to UAE customers — consumer payment apps, super-app wallets, gift-card programmes beyond the exemptions, and platforms holding user balances before spending. The test is economic: if customers pre-fund and you hold the float, you are likely issuing stored value.
SVF vs RPS — the boundary
The SVF licence covers issuing stored value; the RPS licence covers performing payment services. Wallet-plus-payments models frequently need analysis across both regimes, and getting the boundary wrong is the most common application error.
What are the core obligations of an SVF licensee?
Safeguarding the float — customer money held segregated and protected — plus capital requirements, AML/KYC, technology and outsourcing standards, and CBUAE reporting. The float is customers' money in the regulator's eyes, and everything in the regime radiates from that principle.
Are there exemptions from SVF licensing?
Limited ones — genuinely closed-loop arrangements, certain small-scale or single-merchant schemes, and de-minimis programmes can fall outside the licence. The exemptions are narrow and fact-specific: a gift card that starts single-merchant and grows into a network can cross the line without anyone noticing.
Can a free-zone company hold an SVF licence?
The SVF regime is a CBUAE onshore authorisation; DIFC and ADGM operate their own money-services frameworks under the DFSA and FSRA. Which regime fits depends on where your customers are — onshore consumer wallets point to the CBUAE; financial-centre and B2B models may suit DIFC or ADGM.
Launching a wallet?
Senior counsel only. No associates. Direct engagement with the partner who will run your matter.
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