DFSA public register checked 31 Oct 2026 · 44 money-services firm records

Who holds a DFSA Category 3D licence, and what they actually sell.

Every DIFC firm licensed to provide money services, sorted into its prudential category, with its products, customers and corridors. Then the gaps a new Dubai cross-border payments firm could fill, and what a 3D licence takes.

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The numbers

Strictly 21 firms are 3D. 36 compete for the same customers.

The register lists permissions but not categories. We applied PIB 1.3.5A: 3D means a payment account, payment instrument or payment execution permission, and nothing that puts the firm in a higher category. Issuing Stored Value moves a firm to 3C, crypto custody to 3B, dealing as principal to Cat 2, and money transmission on its own to Cat 4. That leaves 15 more firms holding 3D-type payment permissions under another category.

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Category 3D firms (strict PIB 1.3.5A test). Two of them, PhotonPay and Sokin, confirm 3D themselves.

0

Active firms authorised to Provide Money Services (3D + 15 in 3C / 3B / 2 / 4)

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3D firms licensed in 2025–26, so the field is young and still growing (7 in 2025, 7 so far in 2026)

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US$200k base capital for 3D (PIB 3.6.2). In practice the expenditure- or volume-based requirement usually sets the figure.

44 · all money-services records
Includes 8 withdrawn: Rapyd, Ziina, Argentex, Ebury UK, Ebury Mass Payments, Tipr, SilkSoft, DC Ventures
36 · active Providing Money Services
The competitive set for a Dubai payments entrant
21 · Category 3D
Payment accounts / instruments / execution, with no higher-category trigger
15 · other category
10 are 3C (9 stored value + IFX for custody), plus Ripple 3B, Apricot / Sigma / Velocity Cat 2, dLocal Cat 4
4 · adjacent / pipeline
3 arranging-only (Interpolitan, MENA Card Systems, Sav) + Munify (in-principle approval only)
Interactive comparison

Compare every licensed firm, feature by feature

Filter by category or offering, search, and sort any column. Click a row or card to see the firm's register details, products and sources. Ticks come from each firm's own website or press release, read this week. A missing tick means we found no evidence, not that the firm lacks the feature.

Category 3D (21) Other category (15) Arranging only (3) Pipeline (1) Withdrawn (8)
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TableCards
Offering coverage

Accounts, payouts and FX are table stakes. Invoicing, escrow and stablecoins are almost empty.

Share of the 36 active money-services firms offering each capability, then a firm-by-capability heatmap for the 21 Category 3D firms.

Capability penetration

Active money-services firms (n=36), from public evidence

Licences granted per year

Gold = Category 3D · violet = other categories (active firms only)

White space · our analysis

Where the Dubai market is under-served

These gaps come from the coverage data above. Each counts the 21 Category 3D firms unless it says otherwise.

High
3 / 21

Invoicing & AR/AP built in

Only Finmo, Verto and PhotonPay pair accounts with invoices or AR/AP. UAE SMEs still reconcile cross-border receivables by hand.

High
1 / 21

Trade escrow / conditional release

Only 3-Shepherd, on a restricted Innovation Testing Licence. Procure Hub hints at it for construction. Nobody serves B2B trade escrow with document checks for UAE traders.

High
1 / 36

South Asia SME corridor

Remitly, Jingle Pay, Aspora and Taptap serve consumer remittance. Only MultiPass lists PKR for businesses. No one targets UAE–Pakistan/India/Bangladesh trade and services SMEs first.

Medium
3 / 21

Stablecoin settlement

PhotonPay, Wind (Innovation Testing Licence) and Lorum (fiat rails for crypto platforms). DFSA recognises USDC, EURC and RLUSD, but few 3D firms use a stablecoin settlement leg.

Medium
5 / 21

Local AED / UAE IBAN details

Most firms sell UK/EU IBANs. Few show AE IBANs or AED clearing: 3S Money, VFX Financial, Lorum, Sokin (through Ruya Bank) and Breinrock (Aani rail).

Medium
8 / 21

Cards on balances

Cards are offered by fewer than half. Under 3D a card has to be a payment instrument on a payment account; prepaid stored value would push the firm into 3C.

The licence

What a Category 3D licence requires

Summary of DFSA rules — not legal advice; verify against current rulebook (PIB VER54/10-26)
  • Scope (PIB 1.3.5A)Provides or operates a Payment Account, executes Payment Transactions on another person's account, or issues Payment Instruments, without meeting the tests for Categories 1, 2, 3A, 3B, 3C or 5.
  • Stays out of 3DIssuing Stored Value goes to 3C (US$500k base). Money Transmission only goes to Cat 4 (US$140k). Crypto custody goes to 3B. Dealing as principal goes to Cat 2.
  • Base capital (PIB 3.6.2)US$200,000. Capital Resources = CET1 + AT1 + T2 (PIB 3.11); hold mainly CET1.
  • Capital requirement (PIB 3.5.2)Highest of: base capital · Expenditure-Based Capital Minimum · Activity-Based (3.8C) · Transaction-Based Capital Requirement (payment services). Stored-value capital applies only to 3C issuers.
  • EBCM ratio (PIB 3.7.2)18/52 of annual audited expenditure if you hold client money; 9/52 if you do not.
  • TBCR (PIB 3.8B.2)Monthly payment volume (annual ÷ 12) tiered: 4% of first $5m, 2.5% of next $5m, 1% of next $90m, 0.5% of next $150m, 0.25% above; scaling factor 1.
  • Early warning (PIB 3.2.6)Notify the DFSA immediately if capital resources fall below 120% of the requirement. Liquid assets must exceed the higher of base capital and EBCM (PIB 3.5.3).
  • People (GEN 7.5)Senior Executive Officer, Finance Officer, Compliance Officer and MLRO. The SEO, CO and MLRO must live in the UAE.
  • Conduct (COB 13)Money services rules: execute in the agreed currency, disclosure, safeguarding of client money. Retail clients may hold payment accounts for business purposes only.
  • PerimeterCovers services in or from the DIFC. Serving onshore UAE retail customers normally needs CBUAE authorisation.
  • Fees & timingAbout US$15k application fee + US$15k annual fee. Review is commonly quoted at 4–8+ months. Route: RBP → application → in-principle approval → capital, premises, insurance → licence. (Secondary sources)
  • Sandbox routeThe Innovation Testing Licence lets you test with capped clients. 4 of the 21 3D firms hold one today: 3-Shepherd, CoGoLinks, Procure Hub and Wind.

Capital requirement estimator

Illustrative arithmetic on the rules shown. Not a DFSA calculation.

Capital requirement = highest line

Example: US$240m a year is US$20m a month. 4%×5m + 2.5%×5m + 1%×10m = US$425k, more than double the US$200k base.

Recommendation
RECOMMENDATION — our analysis, not fact

Build a UAE–South Asia corridor business account under 3D

Working name "[Your product]". A DIFC Category 3D payment-account and payment-instrument firm for UAE-based SMEs and trading houses that buy from or sell to Pakistan, India and Bangladesh, and for South Asian exporters with GCC clients. The product puts accounts, invoicing, conditional release and stablecoin-assisted settlement in one flow. The data above shows no 3D firm combining these.

01

AED / USD / EUR payment accounts

Named or virtual accounts through a UAE partner bank, plus EU/UK details through partners. Stay a payment account (no stored value) so the firm remains in 3D.

Fills the AED-local-details gap (5/21)
02

Invoice → pay → reconcile

Invoices and payment links, AR/AP status, Xero / QuickBooks / Zoho sync, and VAT-ready UAE statements.

Invoicing gap (3/21)
03

Milestone release ("trade-safe")

Funds stay in the buyer's payment account and are released on shipping or inspection documents. The legal structure and safeguarding must be agreed with the DFSA before launch.

Escrow gap (1/21, ITL only)
04

PKR / INR / BDT payouts

Same-day local payouts through licensed partners in each country (e.g. SBP-regulated banks or EMIs), with the documentation exporters need for proceeds.

South Asia SME corridor gap (1/36)
05

Stablecoin settlement leg (phase 2)

USDC or RLUSD treasury and settlement through a DFSA-licensed crypto partner, or a later Crypto Token endorsement. Not offered at launch.

Stablecoin gap (3/21)
06

Debit cards + API

Virtual and physical cards drawing on the payment-account balance (a payment instrument, not prepaid), plus an API so platforms and marketplaces can embed payouts.

Cards gap (8/21) · platforms

Beachhead

Pakistani- and Indian-owned general trading, textiles and IT-services firms in Dubai's free zones and the DIFC, and their suppliers back home.

Channels

Corporate service providers and free-zone setup agents, chartered accountants, business councils (e.g. Pakistan Business Council Dubai), DIFC Innovation Hub, trade associations.

Pricing

Free account tier, a transparent FX margin, flat fees per payout, and a small percentage fee on milestone release. Lead with price on the PKR and INR corridors.

Moat

Licences on both ends of the corridor (DFSA plus partners in each country), document-driven trade workflows, and corridor liquidity.

0
Months 0–3

Prepare

  • Regulatory Business Plan; DFSA pre-application meeting
  • Recruit SEO, FO, CO and MLRO (UAE-resident)
  • Capital model: plan ≥ US$0.5–1m (TBCR + EBCM + buffer)
1
Months 3–9

Apply

  • Full 3D application, or an Innovation Testing Licence first
  • Sign UAE partner bank and safeguarding account
  • Sign PK / IN payout partners
2
Months 9–15

Launch

  • Accounts, invoicing and payouts to PK / IN
  • Beta with 50–100 trading SMEs
  • Accounting integrations
3
Months 15–24

Scale

  • Milestone release and cards
  • Stablecoin settlement through a licensed partner
  • API for platforms; add the BD corridor

Risks: partner-bank de-risking on South Asia corridors · FX liquidity in PKR · DFSA view on escrow-style release · onshore UAE retail perimeter (CBUAE) · well-funded entrants (Sokin, Verto, Ebury, PhotonPay, LianLian).

Sources & method

Sources

Register data comes from the DFSA public register (queried with the "Providing Money Services" filter, 44 records) and each firm's register page, read 31 Oct 2026 (PKT). Categories are our inference from PIB 1.3.5A and are not shown on the register. Product ticks come from firm websites and press releases. Every row in the table links its sources, and the full CSV is dfsa_3d_firms_full.csv.