E-money and stored value wallets are regulated separately from bank deposits. In the EU and the UK an electronic money institution needs at least EUR 350,000 of initial capital, must safeguard customer funds, redeem at par on demand and may not pay interest. The UAE requires a Central Bank licence, AED 15 million of paid-up capital and segregated float for stored value facilities. Singapore treats e-money issuance as a licensable payment service.
EU and UK
Under the E-Money Directive, e-money is stored monetary value represented by a claim on the issuer, and only e-money issuers may issue it. An e-money institution needs initial capital of at least EUR 350,000 and must safeguard customer funds; e-money must be issued and redeemed at par, and interest or time-related benefits are prohibited. The UK's Electronic Money Regulations 2011 keep the EUR 350,000 requirement, with ongoing own funds of 2% of average outstanding e-money under Method D, though the regulations are due to be replaced under the Financial Services and Markets Act 2023.123456
UAE and Singapore
In the UAE, issuing or operating a stored value facility without a Central Bank licence is prohibited, except for single-purpose facilities. Licensees need AED 15 million paid-up capital and capital funds of at least 5% of float, must be UAE-incorporated outside the financial free zones, and must hold float in segregated bank accounts or protect it by guarantee or insurance. The Central Bank sets no hard cap on wallet balances; each licensee sets justified limits.
Singapore's Payment Services Act lists e-money issuance among licensable payment services alongside account issuance, money transfer and digital payment token services.78910
| Market | Authority or law | Capital | Source |
|---|---|---|---|
| EU (DE, FR) | E-Money Directive 2009/110/EC | EUR 350,000 initial capital | EUR-Lex |
| United Kingdom | Electronic Money Regulations 2011 | EUR 350,000; own funds 2% of outstanding e-money | legislation.gov.uk |
| UAE | CBUAE SVF Regulation | AED 15 million paid-up; 5% of float | CBUAE Rulebook |
| Singapore | Payment Services Act 2019 | Licensable service (capital not confirmed) | SSO |
Decisions to make
- Will customers hold balances, or only pass payments through?17Holding redeemable balances is e-money or stored value, with higher capital and safeguarding duties.
- Is the wallet single-purpose?7UAE single-purpose SVFs are outside the licensing prohibition.
- Does the product plan include interest or rewards for holding a balance?4The EU prohibits time-related benefits on e-money.
- Can the business fund AED 15 million of paid-up capital in the UAE?8It is the minimum for an SVF licence.
Documents usually needed
- Safeguarding arrangements and segregated account agreements
- Capital and own funds calculations
- Redemption terms and customer terms and conditions
- Wallet limit policy (UAE operating rules)
Common mistakes
- Offering interest-like rewards on EU e-money balances
- Setting up a UAE wallet in a financial free zone and assuming the CBUAE SVF regime applies
- Treating float as available for the company's own investment returns
Questions businesses ask
Can e-money balances earn interest in the EU?
No. The E-Money Directive prohibits interest or any benefit linked to how long a holder keeps e-money.4
Is there a maximum wallet balance in the UAE?
The Central Bank does not set a hard cap; each licensee must set reasonable, justified limits in its operating rules.9
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- India's prepaid payment instrument rules, Saudi e-money institution licensing and US state money transmission laws were not researched.
- Singapore capital and safeguarding requirements for e-money issuers were not confirmed.
- The timing of replacement of the UK Electronic Money Regulations 2011 was not confirmed.
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.
Under the EU E-Money Directive, electronic money is electronically or magnetically stored monetary value represented by a claim on the issuer, and only electronic money issuers may issue it. EU. Article 2(2) and Article 10. Member States had to transpose the Directive by 30 April 2011 (Article 22).
An EU electronic money institution must hold initial capital of at least EUR 350,000 at authorisation and must safeguard funds received in exchange for e-money. EU. Articles 4 and 7.
E-money must be issued at par value on receipt of funds and redeemed at par value at any moment on the holder's request. EU. Article 11.
EU e-money issuers may not grant interest or any other benefit related to the length of time a holder keeps e-money. EU. Article 12.
An authorised electronic money institution in the UK must hold initial capital of at least EUR 350,000. UK. Electronic Money Regulations 2011, Schedule 2, paragraph 2.
Latest revised text up to date to 17 October 2026; the page notes a prospective revocation under the Financial Services and Markets Act 2023 (Schedule 1 Part 2) not yet applied, as the UK replaces retained EU financial services law.
A UK electronic money institution's own funds for e-money issuance are calculated under Method D as 2% of its average outstanding electronic money. UK. Schedule 2, paragraphs 13 and 23; Methods A to C apply to unrelated payment services.
Latest revised text up to date to 17 October 2026; the page notes a prospective revocation under the Financial Services and Markets Act 2023 (Schedule 1 Part 2) not yet applied, as the UK replaces retained EU financial services law.
In the UAE it is prohibited to issue or operate a stored value facility without prior licence from the Central Bank, under the Stored Value Facilities Regulation in force since 30 October 2020. Federal. Article 2(2); single-purpose SVFs are excepted. Licensed banks are deemed authorised but need a no-objection letter (Article 4(1)).
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 UAE stored value facility licensee needs paid-up capital of at least AED 15 million and aggregate capital funds of at least 5% of its total float, and must be a company incorporated in the UAE outside the financial free zones. Federal. Articles 3(2), 7(4.1) and 7(4.2).
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.
UAE stored value facility float must be held in segregated accounts with licensed banks or a foreign bank recognised by the Central Bank, or protected by a bank guarantee or insurance, and the Central Bank sets no hard cap on stored value, leaving licensees to set justified limits. Federal. Articles 11(4), 11(5) and 13(9).
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.
Singapore's Payment Services Act defines e-money issuance service, account issuance, domestic and cross-border money transfer, merchant acquisition, digital payment token and money-changing services as payment services. Singapore. Section 2(1) definitions, referring to the First Schedule.
Questions on this topic
10 statements on e-money and stored value
