What a payments licence requires in Saudi and the UAE
Licence categories and capital floors in the SAMA and CBUAE payment regulations, and where the two regimes do not line up.
“Get a payments licence” is not one application in the Gulf. Saudi Arabia and the UAE both require a licence before a non-bank provides payment services, and they classify those services differently, capitalise them differently, and run the application in a different number of steps.
The figures below are from the instruments, not from a comparison table someone else compiled. They are initial capital floors. They are not a budget for the licence, and they are not legal advice. Open banking licensing is a related but narrower topic; the Saudi step-change in March 2026 is covered in Saudi open banking is now a licensed activity.
Saudi Arabia
SAMA’s guidelines for applying for a payment service provider licence sit on top of the Implementing Regulation of the Law of Payments and Payment Services. The guidelines, marked in force on the rulebook, say an applicant may apply for one of four licences defined in that regulation:
- Micro Electronic Money Institution (Micro EMI)
- Major Electronic Money Institution (Major EMI)
- Micro Payment Institution (Micro PI)
- Major Payment Institution (Major PI)
The process has two stages. In-principle approval comes first. The guidelines say that approval is what lets the applicant finish incorporation steps, including the commercial registration, which are a prerequisite for the final licence. SAMA then tells the applicant, in writing, of its decision within ninety calendar days of notifying them that the application is complete, and if it will take longer it says so.
Article 44 of the Implementing Regulation sets the initial paid-up equity the applicant has to evidence:
| Licence | Initial paid-up equity |
|---|---|
| Micro PI | at least SAR 1 million |
| Major PI | at least SAR 3 million |
| Micro EMI | at least SAR 2 million |
| Major EMI | at least SAR 10 million |
| Payment initiation, alone or with account information | at least SAR 1 million |
| Account information alone | at least SAR 500,000 |
A provider is a Major PI, under the regulation, when it performs one or more relevant payment services other than issuing electronic money and the average value of monthly payments exceeds SAR 10 million.
Ongoing capital is not the same number. A Micro PI or Micro EMI maintains the Article 44 initial amount. A Major PI maintains the higher of that initial amount or 1% of average monthly payment transaction value. A Major EMI maintains the higher of its initial amount or 2% of total average outstanding electronic money.
The guidelines also ask, at in-principle stage, for an irrevocable bank guarantee equal to 20% of the minimum capital of the activity, issued by a local bank in favour of SAMA, renewed until the capital is paid in full. That is cash tied up before you are licensed. It is easy to leave out of a spreadsheet that only copied the Article 44 column.
Applications go to NBFI-LIC@SAMA.GOV.SA. The guidelines give the applicant 30 calendar days to answer a request for more documents, unless SAMA sets a different period, and say SAMA may reject the application if that deadline is missed.
United Arab Emirates
The Central Bank’s Retail Payment Services and Card Schemes Regulation defines nine retail payment services: payment account issuance, payment instrument issuance, merchant acquiring, payment aggregation, domestic fund transfer, cross-border fund transfer, payment token services, payment initiation, and payment account information.
A person who is not exempt needs a licence before providing any of them in the State, or promoting them. Banks licensed under the Central Bank Law are deemed licensed, with a split: they still notify the Central Bank and obtain a no-objection before providing the services in Annex I points (3), (4) and (7) through (9). They do not need that no-objection for points (1), (2), (5) and (6).
Everyone else applies for a category. The category is determined by which services you want, not by a free choice of “the small one”:
| Category | Services it can cover | Initial capital |
|---|---|---|
| I | Account issuance, instrument issuance, acquiring, aggregation, domestic transfer, cross-border transfer, payment tokens | AED 3 million if average monthly payment transactions are AED 10 million or more; otherwise AED 1.5 million |
| II | The Category I list, without payment tokens | AED 2 million, or AED 1 million below the same threshold |
| III | Account issuance, instrument issuance, acquiring, aggregation, domestic transfer | AED 1 million, or AED 500,000 below the threshold |
| IV | Payment initiation and account information only | AED 100,000, regardless of volume |
The threshold is a moving average of the preceding three months, or the business plan if you have no history yet. Cross the AED 10 million average for three consecutive months and the regulation says you report it and become subject to the higher capital. Category I applicants also have to list the payment tokens they intend to issue and provide a legal opinion on them. Category IV applicants have to hold professional indemnity insurance as set out in the regulation.
Aggregate capital after licensing — paid-up capital, reserves other than revaluation reserves, and retained earnings, minus accumulated losses and goodwill — must not fall below the initial figure. The Central Bank can set a higher one.
What does not survive a side-by-side reading
The SAR 10 million and AED 10 million lines look parallel. They are not the same test. In Saudi Arabia, crossing SAR 10 million average monthly payments is what makes you a Major PI rather than a Micro PI, with a different ongoing formula. In the UAE, the AED 10 million line changes the capital inside a category you already hold; it does not rename the category.
Payment tokens sit in UAE Category I only. They are not a row in the SAMA table above. Account information is cheap, in both regimes, relative to issuing electronic money, and in the UAE it is the only thing Category IV is for. A firm that wants account information and also wants to acquire merchants is not in Category IV.
The application shape differs too. SAMA’s guidelines describe a formal in-principle approval that precedes incorporation. The CBUAE regulation points applicants at the Central Bank’s licensing procedure and encourages management to meet the licensing division before a formal application. Those are both “talk to the regulator first” only in the loosest sense.
What this does not settle
Capital is the part both instruments publish as a number. Staff, systems, safeguarding of customer funds and the local presence the application will actually demand are in the annexes and the forms, and they move. The SAMA guidelines list policies the applicant must draft — safeguarding, AML, cybersecurity, fraud, settlement — but drafting a policy is not the same statement as “SAMA requires X staff”. That second sentence is not in the pages cited here, so it is not made.
Fees, timelines beyond the ninety days SAMA states, and any informal expectation are out of scope for the same reason.
If the service you want is specifically a transfer out of the country, the UAE category table is doing more work than it first appears to. Cross-border fund transfer is not in Category III. That distinction is the subject of cross-border payouts into the Gulf.
Sources
- Guidelines to apply for a payment service provider licence, SAMA Rulebook. Four licence types, two-stage process, 90-day decision, 20% bank guarantee, document list. Checked 26 September 2026.
- Article 44, Implementing Regulation, initial paid-up equity. Checked 26 September 2026.
- Article 45, ongoing capital. Checked 26 September 2026.
- Retail Payment Services and Card Schemes Regulation, CBUAE Rulebook. Categories, services and Article 6 capital. Checked 26 September 2026.
Read the article you intend to rely on. This page is a map of where the numbers sit, not a substitute for the instrument.