Crypto-asset rules diverge sharply. The EU's MiCA requires crypto-asset service providers to be EU-incorporated and authorised, with an EU-wide passport, and limits e-money token issuance to banks and e-money institutions. The UAE licenses payment token services federally and lets merchants accept only dirham stablecoins as payment, while other virtual asset activities are licensed by the SCA or emirate authorities such as Dubai's VARA. Saudi Arabia prohibits virtual asset service providers. Singapore licenses digital payment token services.
European Union
MiCA, Regulation (EU) 2023/1114, entered into force on 29 June 2023. Crypto-asset services may be provided only by legal persons with a registered office in a Member State, and an authorisation from that state's authority is valid across the EU. E-money tokens may be issued only by credit institutions or e-money institutions. Firms already operating under national law had an 18-month transitional period, so groups relying on national registrations should confirm that their MiCA authorisation is in place.1234
Gulf and Singapore
The UAE Central Bank's Payment Token Services Regulation, effective 31 August 2024, requires a licence or registration for issuing dirham payment tokens, custody and transfer, and conversion. Merchants may accept a virtual asset as payment only if it is a licensed dirham payment token; foreign stablecoins may be used only to buy virtual assets. Other virtual asset activities are licensed by the SCA or an emirate authority such as VARA in Dubai. Saudi Arabia does not permit virtual asset service providers.
Singapore defines a digital payment token as one not denominated in or pegged to a currency, and providing a digital payment token service is a licensable payment service. The FATF has applied anti-money-laundering standards to virtual asset service providers since 2018 and 2019.5678910
| Market | Regime | Key rule | Source |
|---|---|---|---|
| EU (DE, FR) | MiCA | EU-incorporated, authorised CASPs; EU-wide passport | EUR-Lex; European Commission |
| UAE (federal) | CBUAE Payment Token Services Regulation | Only dirham payment tokens accepted as payment | CBUAE Rulebook |
| UAE (emirates) | SCA or emirate authority, e.g. VARA | Licensing of other virtual asset activities | US State Department |
| Saudi Arabia | Prohibition | Virtual asset service providers not permitted | US State Department |
| Singapore | Payment Services Act | Digital payment token service is licensable | SSO |
Decisions to make
- Does the business want to accept stablecoins as payment in the UAE?6Only licensed dirham payment tokens may be accepted as payment for goods and services.
- Is the crypto service provided into the EU from outside it?2MiCA requires a registered office and authorisation in a Member State.
- Is a stablecoin an e-money token under MiCA?3Only banks and e-money institutions may issue e-money tokens.
- Which UAE authority licenses the activity?57Payment tokens fall to the Central Bank; other virtual asset activities to the SCA or an emirate authority.
Documents usually needed
- Token classification analysis (payment token, e-money token, other crypto-asset)
- Licence or authorisation application with business plan and AML/CFT framework
- White paper where MiCA requires one
- Custody and reserve asset arrangements
Common mistakes
- Accepting US dollar stablecoins as payment for goods in the UAE
- Serving EU customers on a national registration after the MiCA transition ended
- Assuming a Dubai VARA licence covers payment token services regulated by the Central Bank
- Offering virtual asset services into Saudi Arabia
Questions businesses ask
Can a UAE shop accept USDT or USDC?
Not as payment for goods or services. Only licensed dirham payment tokens can be accepted; foreign payment tokens may be used only to buy virtual assets.6
Does a MiCA licence work across the EU?
Yes. An authorisation granted by the home Member State's competent authority is valid throughout the Union.2
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- MiCA's application dates (Article 149) and the end of the transitional period (Article 143(3)) could not yet be checked in the EUR-Lex text; ESMA's site was not reachable.
- Dubai VARA's rulebooks, Singapore's digital token service provider regime from June 2025 and MAS stablecoin framework, the UK's planned cryptoasset regime and the US GENIUS Act could not yet be checked.
- India's crypto tax and FIU registration rules were not researched.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
The EU Markets in Crypto-assets Regulation (MiCA), Regulation (EU) 2023/1114, was published in the Official Journal on 9 June 2023 and entered into force on 29 June 2023. EU. It covers crypto-assets and related services not covered by other EU financial services legislation. Application dates of its titles were not confirmed on the pages read.
Under MiCA, crypto-asset services may only be provided by legal persons with a registered office in an EU Member State, and an authorisation granted by that Member State's competent authority is valid throughout the Union. EU. Recitals 74 and 76; operative provisions in Title V.
Only the recitals of the EUR-Lex text could be read in full; the operative article should be confirmed.
MiCA requires e-money tokens to be issued by a credit institution or an electronic money institution. EU. Recital 19.
Only the recitals of the EUR-Lex text could be read in full; the operative article should be confirmed.
MiCA allowed crypto-asset service providers operating under national law an 18-month transitional period. EU. Recital 114. The end date in Article 143(3) could not yet be checked.
Only the recitals of the EUR-Lex text could be read in full; the operative article should be confirmed.
In the UAE no person may perform payment token services, such as issuing dirham payment tokens, custody and transfer or conversion, without a Central Bank licence or registration, under the Payment Token Services Regulation effective 31 August 2024. Federal. Articles 2(1) and 5(1). A payment token is a virtual asset that maintains a stable value by reference to a single fiat currency (Article 1(51)).
Issued under the former Central Bank law; Federal Decree-Law No. 6 of 2025 replaced that law from 16 September 2025. The rulebook lists the regulation as in force; confirm any transitional changes under the 2025 law.
A merchant in the UAE may accept a virtual asset as payment for goods or services only if it is a dirham payment token from a licensed issuer; foreign payment tokens may be used only to buy virtual assets or their derivatives. Federal. Article 2(7); a licensed issuer may issue dirham payment tokens only to UAE residents (Article 2(6)).
Issued under the former Central Bank law; Federal Decree-Law No. 6 of 2025 replaced that law from 16 September 2025. The rulebook lists the regulation as in force; confirm any transitional changes under the 2025 law.
Licences for virtual asset activities in the UAE come from the Securities and Commodities Authority or an emirate-level authority, such as the Virtual Assets Regulatory Authority in Dubai. UAE. Not confirmed on the regulators' own pages.
Secondary (foreign government) source: US Department of State 2025 Investment Climate Statement. Central bank pages for this country could not yet be checked.
Virtual asset service providers remain prohibited in the Kingdom and virtual currency may not be exchanged for Saudi riyals. Position as described by the source; check SAMA and Capital Market Authority announcements for any change.
Secondary (foreign government) source; the official Saudi text could not yet be checked run. Reused from market guide claim sa-risk-007.
Singapore's Payment Services Act defines a digital payment token as a digital representation of value that, among other conditions, is not denominated in any currency and is not pegged by its issuer to any currency, and providing a digital payment token service is a licensable payment service. Singapore. Section 2(1). Single-currency stablecoins fall outside this definition; MAS treats them separately.
The statement that single-currency stablecoins are treated separately follows from the definition; the MAS stablecoin framework could not yet be checked.
The FATF revised Recommendation 15 in October 2018 to add definitions of virtual asset and virtual asset service provider, and added an interpretive note in June 2019 applying anti-money-laundering standards to them. International standard; the Recommendations were last updated in June 2026.
Questions on this topic
10 statements on crypto-asset rules
