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Crypto has officially reached cruising altitude.
Emirates has launched Crypto.com Pay across its website and app, allowing eligible UAE customers to use crypto-funded payments when booking flights.
It is an eye-catching development for the adoption of crypto payments in the UAE. But the most interesting part for us at Founders Law is not simply that customers can use crypto to buy a plane ticket. It is the legal and operational structure behind the transaction.
Flights continue to be priced and settled in Emirati dirhams (AED), while Crypto.com provides the payment infrastructure. In other words, Emirates can offer customers another way to pay without necessarily receiving or holding volatile crypto assets itself.
That distinction matters – and it could offer other businesses a useful blueprint for accepting crypto payments in the UAE responsibly.
Eligible UAE residents with a Crypto.com account can select Crypto.com Pay when booking through the Emirates website or app.
On mobile, customers are directed to the Crypto.com app to approve the transaction. Desktop users can scan a QR code and confirm the payment through their app. Once approved, the customer returns to Emirates to receive their booking confirmation and ticket.
Crucially, bookings are priced and settled in AED.
The integration is powered by Crypto.com’s Dubai entity, which Emirates says is the first Virtual Asset Service Provider to receive a Stored Value Facilities licence from the Central Bank of the UAE.
This means the customer may fund the transaction using digital assets, but Emirates is not simply accepting crypto directly into a company wallet and hoping its value remains stable.
It is a much more carefully structured – and regulated – model.
Businesses have experimented with crypto payments for years, so Emirates is not the first company – or airline globally – to enter the space.
However, the involvement of a globally recognised UAE airline is still an important step.
For crypto to become part of everyday financial infrastructure, it needs to work for ordinary transactions, not only investment, trading or highly specialist blockchain products. Buying a flight is a familiar consumer purchase, which makes the technology feel considerably less niche.
It also demonstrates that mainstream adoption does not necessarily require merchants to hold digital assets themselves. A regulated crypto payment provider in the UAE can sit between the customer and the business, handling elements such as conversion, payment processing and compliance.
This could make crypto-funded payments more attractive to businesses that want to offer greater customer choice but do not want direct exposure to price volatility, wallet management or the operational risks associated with holding cryptoassets.
While the customer experience may look relatively simple, introducing crypto payments can create several legal and regulatory questions behind the scenes.
The UAE has developed an increasingly sophisticated virtual asset and payments landscape. However, the legal requirements for crypto payments in the UAE will depend on how the service is structured, where the parties operate and what role each business plays in the transaction.
Any company considering a similar payment option should think carefully about the following areas.
The UAE does not have one single regulator responsible for every activity involving digital assets.
The relevant UAE crypto regulations can depend on where a business operates, the services being provided and the role each party plays in the transaction.
The Central Bank of the UAE regulates certain payment services. Virtual asset activities may also fall within the scope of authorities such as Dubai’s Virtual Assets Regulatory Authority (VARA), the Dubai Financial Services Authority (DFSA) in the DIFC or the Financial Services Regulatory Authority (FSRA) in the ADGM.
Under the Central Bank’s Payment Token Services Regulation, businesses providing regulated payment token services in or into the UAE must generally be appropriately licensed or registered.
A merchant using an external provider will not necessarily be carrying out the same regulated activity as that provider. However, the precise structure matters.
Businesses should establish:
For businesses looking for crypto regulatory advice in the UAE, this analysis should happen before the solution is integrated or marketed to customers.
Choosing the right provider is about considerably more than comparing transaction fees.
Before integrating a crypto payment solution, a business should verify:
Licensing should not be treated as a box-ticking exercise. The provider’s permissions must cover the services it will actually perform.
A business should also consider the provider’s financial position, security arrangements, operational resilience and ability to keep pace with changes to crypto payment regulations in the UAE.
Crypto transactions can present heightened money laundering, sanctions and fraud risks, particularly where businesses cannot clearly establish the origin or destination of funds.
A regulated payment provider may take responsibility for customer verification, wallet screening and transaction monitoring. However, outsourcing these functions does not mean the merchant can ignore them entirely.
The agreement should clearly establish which party is responsible for:
The merchant will also need sufficient information and oversight to understand whether these controls are operating effectively.
Any business seeking crypto AML compliance support in the UAE should consider both the regulatory requirements and the practical division of responsibilities between the merchant and its payment provider.
Blockchain transactions are generally irreversible, but consumer rights are not.
Businesses still need a clear process for cancellations, complaints, failed transactions and refunds. This is especially important in sectors such as travel, where bookings are regularly amended or cancelled.
The customer terms should explain:
Without clear terms, a relatively small refund could quickly become a much bigger customer dispute.
Businesses should also ensure that the payment journey does not give customers a misleading impression about the identity of the payment provider, the assets being used or the protections that apply.
The contract between the merchant and its payment provider is central to the arrangement.
A properly drafted crypto payment provider agreement should address:
It should also explain who bears losses resulting from fraud, incorrect wallet details, conversion errors, technical failures or regulatory intervention.
Businesses should pay particular attention to limits of liability. If a provider’s failure could prevent customers from completing high-value purchases or disrupt the wider checkout journey, a heavily restricted liability clause may leave the merchant carrying most of the commercial risk.
The contract should also account for regulatory change. The UAE’s virtual asset landscape continues to evolve, so both parties need a clear process for making changes if a regulator introduces new requirements or restricts part of the service.
Introducing another payment provider means customer data may move between more systems and potentially across multiple jurisdictions.
Businesses should map:
Privacy notices and data-processing agreements may also need to be updated.
Cybersecurity responsibilities should be equally clear. Crypto-related services remain an attractive target for fraudsters, and an integration can introduce new vulnerabilities even where the merchant never holds crypto directly.
Businesses should understand how authentication works, who monitors suspicious activity and which party is responsible for responding to security incidents.
The way a transaction is structured will affect how it should be recorded and treated for tax and accounting purposes.
A business receiving AED through a regulated payment provider will be in a different position from one receiving and retaining cryptoassets directly.
Companies should determine how transactions, provider fees, refunds and any conversion gains or losses will be recorded before going live.
This should involve legal, finance, tax and treasury teams from the outset – not after the first payment has already landed.
The Emirates launch is significant because it shows one way crypto payments can fit into established commercial systems.
Customers can use digital assets to fund a familiar purchase. The merchant receives settlement in a conventional currency. A regulated provider handles the crypto element of the transaction.
For many businesses, that may be a much more realistic route to adoption than receiving cryptocurrency directly.
It does not remove every legal or operational risk. It does, however, demonstrate how those risks can be allocated and managed through regulated infrastructure, clear contracts and a carefully designed customer journey.
Crypto adoption was never going to become mainstream simply because more businesses added a wallet address to their checkout page.
The more likely future looks like this: customers can choose to pay using digital assets, while the transaction itself sits within a recognisable regulatory, contractual and consumer-protection framework.
Less “send us some Bitcoin and hope for the best.” More carefully structured, regulated adoption.
For businesses considering launching or integrating crypto payments in the UAE, the question is no longer only whether the technology works. It is whether the legal and operational model works too.
Founders Law provides legal support to crypto, fintech, payments and digital asset companies operating across the UAE and internationally.
Whether you are a crypto company entering the UAE market, applying for regulatory permissions or a more established business looking to introduce crypto-funded payments, our team can help you:
If you are considering launching or integrating a crypto payment solution in the UAE, get in touch with us today.
We act as an extension of your team and handle any overflow in specialist areas.
Working across five continents, operating in multiple sectors, with over 400 clients.
Offices in London | Dubai.
