Cryptocurrency is no longer simply a technology or investment product in the UAE. It is increasingly appearing in employment contracts, commercial transactions, investment arrangements and court disputes. Yet the legal treatment of cryptocurrency depends on how it is being used. The UAE does not simply classify all cryptoassets as “money”. Instead, different legal consequences arise when crypto is used as a payment instrument, included in a contract, paid as part of remuneration or treated as an asset capable of ownership and recovery.
Crypto as Payment: Permitted, but Not the Same as Legal Tender
The fact that cryptocurrency can be legally traded in the UAE does not mean that every business can freely accept Bitcoin or other crypto assets as payment. The CBUAE Payment Token Services Regulation (Circular No. 2/2024) regulates payment-token activities and restricts merchants from accepting a virtual asset for goods or services unless it falls within the permitted categories under Article 2(7). In particular, merchants may accept a Dirham Payment Token issued by a licensed issuer, subject to the Regulation’s requirements.
This creates an important distinction between owning or trading cryptocurrency and using it as a payment mechanism. A business that merely owns crypto is in a different position from one that provides conversion, custody, transfer, settlement or other payment-token services. The latter may fall within a regulated activity requiring authorisation.
Therefore, the legal question is not simply “Is crypto legal in the UAE?” but rather “What is the crypto being used for?”
Can Your Salary Be Paid in Crypto?
One of the most interesting examples of this distinction comes from the UAE employment context.
In Dubai Court of First Instance, Labour Case No. 1739/2024, an employee’s contract provided for a salary in UAE dirhams together with 5,250 EcoWatt tokens. The employer failed to pay the cryptocurrency component for several months. The Court ordered the employer to pay the outstanding token amount in accordance with the employment contract.
The decision was particularly significant because an earlier 2023 judgment, Case No. 6947/2023, had taken a more cautious approach. Although the court recognised that cryptocurrency had been included in the employment agreement, it declined to award the crypto component because there was insufficient evidence of a clear method for calculating its value in fiat currency. The 2024 decision therefore demonstrated a more practical approach where the contractual obligation was sufficiently clear.
However, the decision should not be read as meaning that cryptocurrency has replaced the UAE dirham as legal tender or that employers can simply disregard the Wages Protection System (WPS). The case concerned the enforceability of a contractual crypto component; WPS obligations remain a separate compliance issue.
The practical lesson for employers is therefore straightforward: if cryptocurrency forms part of an employee’s remuneration or benefits, the contract should clearly specify the number of tokens, payment dates, valuation mechanism and the relationship between the crypto component and the employee’s ordinary salary.
Crypto Is Also Being Treated as Property
The UAE courts have gone further than simply recognising cryptocurrency as a contractual payment. The DIFC Courts have expressly recognised cryptocurrency as property.
In Gate Mena DMCC (formerly Huobi OTC DMCC) & Huobi Mena FZE v Tabarak Investment Capital Ltd & Christian Thurner [2024] DIFC CA 002, the DIFC Court of Appeal considered a dispute involving 300 Bitcoin. The Court confirmed that Bitcoin is property of a third kind: it is neither tangible property nor a traditional “thing in action”. The Court further recognised that cryptoassets are capable of being owned and transferred, and that “control” is an appropriate way of understanding possession in the context of cryptoassets.
This is significant because property rights bring practical legal remedies with them. If cryptocurrency is property, a person whose crypto is wrongfully transferred may potentially seek remedies directed at the asset itself, rather than being restricted to a claim for monetary damages.
The position has also been reinforced by the DIFC Digital Assets Law No. 2 of 2024, which expressly provides that a digital asset is intangible property and addresses concepts including title and control.
What Happens When Crypto Is Misappropriated?
The recognition of crypto as property has particularly important consequences in investment disputes and fraud cases.
In Dubai Court of First Instance Case No. 1872/2024, an investor had transferred 29 Bitcoin and 102 Ethereum under an investment arrangement promising a fixed return. When the defendant failed to return the assets, the claimant sought the return of the actual cryptocurrency rather than merely its historical cash value.
In May 2025, the Dubai Court ordered the defendant to return the 29 Bitcoin and 102 Ethereum. If the defendant failed to return the cryptocurrency, the alternative was payment of its market value in UAE dirhams calculated at the date of enforcement.
This is particularly important because cryptocurrency is highly volatile. If a claimant loses Bitcoin when it is worth AED 100,000 and the proceedings take years, a conventional damages award based on the value at the date of loss could leave the claimant significantly out of pocket if the asset subsequently appreciates. By allowing the actual cryptocurrency to be returned, or alternatively valuing it at enforcement, the Court recognised the distinctive nature of digital assets.
What Does This Mean in Practice?
These cases demonstrate an important evolution in the UAE’s approach to cryptocurrency. The courts are not treating crypto simply as an unregulated digital form of cash. Instead, its legal treatment follows its function and context.
As a payment mechanism, cryptocurrency is subject to specific regulatory restrictions. As contractual remuneration, it may be enforceable where the parties have clearly agreed to it. As an asset, Bitcoin and other cryptocurrencies may be capable of ownership and transfer. And where those assets are wrongfully withheld or transferred, UAE courts are increasingly prepared to consider remedies requiring the actual digital assets to be returned.
The practical takeaway for businesses and individuals is therefore that cryptocurrency should be treated as a legally significant asset rather than merely a technological product. Contracts involving crypto should clearly define the asset, the parties’ rights, valuation and payment obligations; employers should carefully structure any crypto-based remuneration; and investors should preserve transaction records, wallet addresses and contractual communications where digital assets are transferred.
The UAE’s developing case law shows that the question is no longer simply whether cryptocurrency is “legal”. The more useful legal question is what legal character does cryptocurrency assume in the particular transaction, and what rights and remedies follow from that character?
Disclaimer: This article is intended for general information only and does not constitute legal advice. The regulatory treatment of a particular digital asset or transaction will depend on its specific facts, the nature of the activity and the jurisdiction in which it is conducted.