How to Obtain EMI License in UAE

Electronic money, or e-money, has simplified our lives as the fintech industry develops new technologies to make purchasing goods and services more accessible. Suppose you want to offer payment services as an Electronic Money Institution (EMI) in UAE, in that case, you will need to apply with a financial regulator (DFSA or FSRA) to obtain an Electronic Money Institution license.

The Dubai International Financial Center (DIFC) and Abu Dhabi Global Market (ADGM) are two of  the main Financial Free Zones within the UAE with their own civil and commercial laws, that grants financial entrepreneurs the opportunity in obtaining an  EMI License in the UAE.

At the hearts of the DIFC and ADGM models is an independent risk-based regulator, the Dubai Financial Services Authority (DFSA) and the Financial Services Regulatory Authority (FSRA), which grants financial licenses and regulates the activities of all banking and financial institutions within the Free Zones.


An EMI is an institution that has the authorization to issue prepaid cards, electronic wallets, and other forms of e-money that individuals and businesses can use to make payments.


An EMI can conduct business throughout the UAE and beyond once it obtains a license. Customers can exchange traditional cash for e-money that the EMI issues and store their e-money in e-wallets that the EMI creates. Then, customers can make payments with the funds in their e-wallets. When they run out of funds in their e-wallet, they can load more funds by exchanging cash for e-money.



There are several requirements an EMI must meet to obtain a license in the UAE. These requirements include:

  • Establishing an operational presence in the UAE, including a physical office and local staff
  • Having adequate financial and non-financial resources to manage and operate the EMI
  • Demonstrating suitable management and employee experience to operate the EMI
    • Directors (at least 2, preferably 3-4) – can be outsourced (NEDs).
    • Senior Executive Officer (SEO) – In-house, UAE resident (can be a Director).
    • Risk Officer (RO) – can be outsourced.
    • Finance Officer (FO) – can be outsourced (can also be an Executive Director/Senior Manager).
    • Money Laundering Reporting Officer (MLRO) – can be outsourced, UAE resident (can be a CO).
    • Compliance Officer (CO) – can be outsourced, UAE resident (can be an MLRO).
  • Having paid-up capital that is readily available in a bank account. There is a combination of base capital, risk-based capital, and expense-based capital required. This is typically from $200,000 to $700,000. The Capital Plan must be captured in Internal Capital Adequacy Assessment Process Report. Note that additional capital requirements may be imposed by DFSA on the review of the application.

When applying for a license, an EMI will face a rigorous regulatory due diligence process. The EMI must have at least a manager residing in the UAE. They must prove their professional qualifications to manage the EMI.

An EMI must demonstrate it has high-quality software and strong technology infrastructure. They must establish internal controls, safety measures, a plan to manage operational risks to ensure payment security and prevent fraud. The EMI must also have several pieces of information and documentation when applying for a license. This information includes:

  • A business plan and financial projections
  • A description of the EMI’s organizational structure
  • Procedures for monitoring, handling, and following up on security breaches and customer complaints
  • Internal protocols for combating money laundering and terrorist financing

These are just some requirements an EMI must meet to obtain a license. Every EMI has unique challenges in obtaining a license. It takes on average 6-12 months for an EMI to obtain a license and it is time and cost saving to choose a professional and expert service provider to assist in the process.


  • Introduction to the Regulator
  • Draft of Regulatory Business Plan (RBP) (Application Forms, Business flow processes & charts)
  • Preparation of Financial model for 3 years and draft of ICAAP and IRAP report.
  • Preparation of policies and manuals (Compliance, AML, Risk Management, Remuneration, Governance, Conflicts of Interests, Business Continuity Plan etc.)

AUT – CORE: this form must be submitted by all applicants applying for a license to carry out one or more financial services in or from ADGM. It covers information on the applicant, its activities, prospective clients and controllers;

AUT – IND: this form must be submitted by the individuals holding a mandatory function including directors, senior executive officer, finance officer, compliance officer and money laundering reporting officer; and

  • Draft of regulatory application for the company and individuals
  • Submission of Regulatory Application (with Policies and appointment of SEO, FO, MLRO, RO, CO)
  • Provision of full-time functions

SEO – Senior Executive Officer

FO – Finance Officer

RO – Risk Officer

MLRO – Money Laundering Reporting Officer

CO – Compliance Officer Initiation of the entity incorporation process

  • Office lease
  • Introduction to the UAE Bank for opening an Account
  • Issuance of Regulator’s financial services license


Wincore Advisory Group helps businesses to articulate their objectives and aspirations to obtain an  Electronic Money Institution License. Contact us at [email protected] OR +971 4 221 2602.



Mohammed Rahali

Managing Partner

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