SKU-03UAE3 weeksNew
Payment token readiness sprint
Know exactly which of the Central Bank’s payment token rules apply to you, and file with a plan the regulator can follow.
The outcome you can measure
Three numbers at the end of week 3
01 · A dateYour filing date with the Central BankFor a licence, registration or non-objection, with the steps to get there.
02 · A gap countGaps to the payment token rulesAcross scope, safeguarding, controls and reporting, ranked.
03 · A money figureCost to comply, plus capitalAED 1.5M or 3M for conversion or custody and transfer, depending on volume.
Why now
- Three servicesIssuing, converting, and holding or transferring payment tokens are all regulated by the Central Bank.
- VASPs tooVARA licensees need a non-objection registration to hold or transfer foreign stablecoins. Their grace period was extended by a year, not removed.
- RestrictedForeign stablecoins can be used only to buy virtual assets, and only if the issuer is registered.
- BannedAlgorithmic stablecoins and privacy tokens are prohibited outright.
Sources: CMS on the Payment Token Services Regulation; Cryptoverse Lawyers on capital; DLA Piper (October 2026). Not legal advice.
Who it’s for
A good fit
- VARA-licensed VASPs holding or transferring stablecoins
- Exchanges planning dirham stablecoin conversion
- Payment firms adding stablecoin acceptance
Not the right start
- Issuing your own dirham stablecoin: see issuer architecture
- A legal opinion: I work alongside your counsel
What you get, and how it runs
- A scope map: which services fall under the Central Bank, and which stay with VARA
- The licence, registration or non-objection path you need
- A gap assessment against the rules
- Capital and safeguarding plan
- A filing plan, timeline and board summary
- Week 1Scope map of your services, tokens and flows
- Week 2Gap assessment and capital model
- Week 3Filing plan, timeline and board summary
What I need from you
- Your CCO as sponsor
- Your VARA licence, conditions and current policies
- Flow-of-funds and token flow data
Where it leads
The licence-to-live operating model to build what the filing promises, and settlement and reconciliation design for the bank side.
How we’d work
Fixed feeQuoted after a 30-minute scoping call, half on signing.
In DubaiBased in Dubai; working sessions with your team on site.
IndependentI don’t resell custody or compliance software. fazeZERO, which I contract through, won’t bid on build work from my advice without your written consent.
Not legal adviceI work alongside your legal counsel on regulatory interpretation and filings.
Next step
Tell me how stablecoins move through your business.
A 30-minute call is enough to confirm the fit, the fee and a start date.