CRYPTO ALERT: Inside Federal Decree-Law No. 6 of 2025 — CBUAE Takes Charge of Virtual Asset Payments
- Marco Beffa
- Dec 8, 2025
- 4 min read
The new federal decree modernizes the legal framework for the Central Bank of the UAE (CBUAE), explicitly bringing virtual-asset-related payment services under federal licensing and oversight while preserving CBUAE’s authority over monetary policy, payment systems, FMIs, and settlement finality. Effective 8 Sept 2025.
Purpose of the Decree
The new Federal Decree-Law No. (6) of 2025 modernises the statutory framework of the Central Bank of the UAE (CBUAE). It expands CBUAE’s supervisory mandate, consolidates national control over payment systems, and explicitly regulates payment services using virtual assets.Effective date: 8 September 2025.
Key Definitions Relevant to Virtual Assets
Virtual Assets (VAs) are defined as digital representations of value/rights recorded on DLT, excluding digital currency issued by the Central Bank.
VAs are not considered “Currency” under the law.
The decree applies outside financial free zones (e.g., ADGM, DIFC are excluded).
Activities That Now Require CBUAE Licensing (Critical for VASPs)
Under Article 61, the following are now licensed financial activities requiring CBUAE approval:
“Providing payment services using Virtual Assets.”
Stored value services, retail payment services, digital money services.
Article 62 further clarifies that these requirements apply regardless of the technology, medium or form used — explicitly capturing DLT, VA payment tokens, smart contracts, and dApps.
Practical meaning:Any VASP offering merchant payments, remittances, e-money/stored-value wallets, or VA-based payment tokens falls under CBUAE jurisdiction, even if also licensed by VARA or operating technical infrastructure.
Distinction Between “Payment” and “Investment” Uses of VAs
Article 187 states that VAs are not covered by the decree when used for investment or trading purposes. However, once VAs function “as a means of payment or exchange,” CBUAE rules apply.
Implication:VARA retains lead authority for investment/trading VA activities;CBUAE holds authority for payment-related VA activities.
Financial Market Infrastructures (FMIs) & Settlement Finality
The decree grants CBUAE strong national powers over FMIs, including:
Designation of FMIs (clearing, settlement, payment systems).
Finality and netting protections, including rules binding even in insolvency.
Implication:If a VA-based settlement or tokenised payment rail becomes systemically important, CBUAE can designate it and impose operational resilience, default management, and reporting requirements.
Data, Oversight, and AML
CBUAE may request any data from any juridical person for macroeconomic and supervisory purposes. VASPs operating in payment flows should expect dual reporting obligations (CBUAE + VARA) across AML, sanctions, and payment data.
Implications for VARA-regulated VASPs:
Overlap: Payment functions (merchant acceptance, stored value, remittances) fall under CBUAE, even for VARA-licensed firms. Investment/trading uses remain under VARA/DIFC/SCA, for the moment.
Supervision & Compliance: Dual reporting likely (VARA + CBUAE); AML/KYC/sanctions controls must meet both regulators’ expectations.
FMI Designation: Settlement layers or payment rails may be designated FMIs, triggering resilience, default, and operational requirements.
Recommended Actions:
VARA: Formalize MoU with CBUAE; issue guidance clarifying jurisdiction split; coordinate inspections and licensing for dual-activity firms.
CBUAE: Publish licensing guidance, streamline NoC/joint approvals with VARA, designate FMIs where appropriate.
VASPs: Map all products by function (Payment / Stored Value / Investment / Exchange); seek CBUAE coordination/licence for payment activities; upgrade AML/CTF reporting; prepare FMI readiness where applicable.
Critical Articles to Reference:
Art. 61: Payment services using VAs are licensed.
Art. 62: Broad jurisdiction over VA payment tokens, dApps, and DeFi delivering licensed activities.
Art. 187: Clarifies VAs ≠ currency; separates payment vs investment uses.
FMI Finality & Netting: Strong CBUAE powers over systemically important infrastructures.
Bottom Line:CBUAE is now the national regulator for payment functions, including VA-based payments, while VARA retains Dubai-specific authority for investment and trading. Firms should plan for dual-regulatory engagement, coordinated licensing/NoC processes, enhanced AML controls, and potential FMI obligations for settlement infrastructure.
Practical Implications for Businesses
If any product includes a payment function, we will need CBUAE licensing and/or a No-Objection Certificate (NOC).
VARA licensing alone is not sufficient for VA-based payment services.
Expect joint regulatory oversight for multi-function platforms (exchange + wallet + payments).
Settlement-related infrastructure may face FMI-level obligations.
Product and engineering must map user flows to determine where VA is used as payment vs as investment.
About the Author
Marco Beffa
CEO at cryptocompliance.ai
Author of the Book “What The Hell are Cryptocurrencies?”
Lecturer on Digital Assets
Radio Broadcaster, Crypto and Blockchain Insights
LEGAL DISCLAIMER
The information provided in this blog is for general informational purposes only and should not be construed as financial or legal advice. We are not a licensed financial advisor, nor are we regulated by FCA, VARA or any other regulatory body. We do not offer, endorse, or provide any recommendations regarding virtual assets, nor do we provide services governed by any regulatory body. All opinions expressed are our own and are not intended as professional advice, endorsements, or recommendations. Any mention of specific cryptocurrencies, digital assets, third party companies, Exchanges, platforms or investment strategies is not an endorsement or recommendation of those entities or practices. We does not receive any compensation or incentive for mentioning or discussing any particular assets or services. Cryptocurrencies and digital assets are highly volatile and involve substantial risks, including the potential loss of your entire investment. Before making any financial decisions, always seek advice from a qualified, licensed financial professional. We expressly disclaim all liability for any reliance placed on the information provided in this blog, which is presented without any guarantees of accuracy or completeness. Any code included in our blogs is for informational purposes only and should not be used as functional code. Anyone wishing to implement code must develop their own structure. We disclaim all responsibility for any unauthorized use of all or parts of the code published on our blogs or website. Copying, reproduction, or use of this code is strictly prohibited. No claims for damages can be made regarding its use. For further details, please refer to our Terms of Service at https://www.cryptocompliance.ai/terms-of-service.
Comments