Digital gold savings apps: how they work and the rules that apply

How an app that sells gold by the gram works: allocated or unallocated metal, vault partners, the LBMA Gold Price, redemption, AML for gold dealers and VAT in the EU, UK and UAE.

· Head of IT
· 8 min read
A stack of gold bars with a gold coin struck with a wheat sheaf, an amber glass euro coin and a custody block

A digital gold savings app sells physical gold by the gram, from small amounts and on a schedule, while a bullion partner keeps the metal in a vault. When customers sell, the money goes to their bank account. The app is the smaller part of the launch: the gold, its price and the rules for precious metals dealers decide what you can offer, and where.

This guide covers metal held in a vault, not tokens or funds that track gold. It is general information, not legal or tax advice: the details depend on your services and your market, so confirm them with a lawyer, a tax adviser and the regulator before you launch.

How it works

For the customer:

  1. They sign up, pass ID and selfie checks, and are screened against sanctions and politically exposed person (PEP) lists.

  2. They enter an amount and see the price per gram, the fee and the grams they get. The price holds while they pay by card, Apple Pay, Google Pay or bank payment.

  3. They can set a weekly or monthly plan that buys at that day's price.

  4. They see their gold in grams, valued at today's sell price.

  5. They sell any amount and receive the money in their bank account.

For you, the operator:

  • Each purchase is booked in grams in your ledger at once.

  • You settle with the partner in the background.

  • Every day, you reconcile your ledger with the partner's statement.

  • You set margins and fees, and run the checks your role requires.

Allocated or unallocated gold

This decides what a customer owns. The London Bullion Market Association (LBMA), which sets standards for the London market, explains both in its guide to precious metal accounts:

  • Unallocated: the holder has a contractual claim to an amount of metal, not to specific bars, and carries the credit risk of whoever owes it, like a current account balance.

  • Allocated: specific bars are set aside and listed by serial number, weight and purity. The holder has no credit exposure to the operator, which acts as custodian, like a safe deposit box.

A customer with 2.5 grams cannot own a bar. An app can hold allocated bars for all its customers and record each share in its ledger, or hold an unallocated balance with the partner. Your contracts decide what customers own and what happens if you or the partner fail: say it plainly in your terms, and have a lawyer check it.

What you need beyond the software

A bullion dealer and a vault

The dealer sells you gold and buys it back; the vault stores it. Often they are one company.

London trades large bars under the LBMA's Good Delivery standard: each holds 350 to 430 troy ounces of gold and is at least 995 parts per thousand pure (Good Delivery List Rules, January 2026). A troy ounce, the unit gold is priced in, is 31.1035 grams (HMRC, section 15). Refiners on the Good Delivery List must follow the LBMA's Responsible Gold Guidance (About Good Delivery).

Ask a partner which bars hold your customers' gold, who audits the vault and how often, how the metal is insured, what happens to it if the partner fails, and which statements and bar lists it sends each day.

A price

The London benchmark is the LBMA Gold Price, in US dollars per troy ounce, set twice a day, at 10:30 and 15:00 UK time, in an electronic auction run by ICE Benchmark Administration (IBA). Its prices in other currencies are indicative, for settlement only (FAQs). The LBMA says anyone using it for valuation, pricing, transactions or financial products needs a usage licence from IBA.

Between auctions, your quote comes from the partner's live buy and sell prices, converted to grams and to your currency, with your margin and fees on top. The partner's spread, the gap between its buy and sell prices, is a cost your prices carry.

Payment partners, and no cash balance

Card payments need an acquirer that accepts gold purchases; sales need a payout route to customers' banks. Keep money out of the app if you can. A balance held between trades can be e-money in the EU (E-Money Directive, Articles 2 and 10) and the UK (Electronic Money Regulations 2011, regulation 63), or a stored value facility in the UAE (SVF Regulation, Article 2), and each needs an authorised issuer, yours or a partner's. The guides to EU and UK e-money licences and the UAE's SVF licence cover the routes.

The rules by market

Anti-money laundering

  • EU today. The Anti-Money Laundering Directive covers traders in goods only for cash payments of €10,000 or more (Directive (EU) 2015/849, Article 2(1)(3)(e)), but member states may go further (Article 5).

  • EU from 10 July 2027. The AML Regulation, Regulation (EU) 2024/1624, makes anyone trading in precious metals and stones as a regular or principal professional activity an obliged entity, bound to run anti-money laundering checks, with no cash condition (Articles 3(3)(e) and 90). Checks apply when a business relationship starts, and the supplier of the goods counts as a customer too (Article 19), so your bullion partner goes through them.

  • UK. Under the Money Laundering Regulations 2017, a trader in goods is a high value dealer when it makes or receives cash payments of at least £10,000 for a transaction (regulation 14), a threshold that was 10,000 euros before 30 June 2026. HMRC supervises high value dealers (regulation 7). An app that never takes or pays cash may fall outside that definition, but cash paid into a bank account still counts (regulation 14(2)), so confirm your position with a lawyer.

  • UAE. Under Federal Decree-Law No. (10) of 2025, in force since 14 October 2025, dealers in precious metals and stones are designated non-financial businesses and professions for cash transactions, single or linked, of AED 55,000 or more (Cabinet Resolution No. (134) of 2025, Article 3). The Ministry of Economy and Tourism (MoET) supervises them on the mainland and in the commercial free zones. Its March 2026 guidance calls the threshold a minimum trigger, not an exemption: risk-based checks apply at any value. Dealers report cash transactions of AED 55,000 or more with individuals, and transactions of that size with companies, in cash or by wire, keep records for at least five years, and register on goAML, the reporting system for suspicious transactions.

VAT on investment gold

  • EU. The VAT Directive's special scheme (Directive 2006/112/EC, Articles 344 to 356) exempts gold bars and wafers of weights accepted by the bullion markets, at least 995 thousandths pure, including gold held through certificates or gold accounts, allocated or unallocated (Articles 344 and 346). Coins have their own tests, and member states may exclude bars of 1 g or less. Traders keep records that identify customers for at least five years (Article 356). The scheme covers gold only.

  • UK. Under HMRC's VAT Notice 701/21, investment gold is exempt, unallocated gold included. The first time a single exempt supply exceeds £5,000, or supplies to one customer pass £10,000 in 12 months, you notify HMRC within 28 days, and records are kept for at least 6 years (sections 2, 3.1 and 7.7).

  • UAE. Supplies of investment precious metals are zero-rated (Federal Decree-Law No. 8 of 2017, Article 45(8)): gold, silver and platinum at least 99% pure, in a form tradeable in global bullion markets (Executive Regulation, Article 36).

Decisions that shape the build

  • Who sells the gold: you, reselling the dealer's gold, or the dealer, with your app selling in its name, a common way to start. The choice shapes who carries the duties above: the VAT Directive exempts agents' services in the seller's name (Article 347), while HMRC treats an agent acting in its own name as the supplier (section 7.3).

  • Allocated or unallocated, and whether customers see the bars behind their grams.

  • Settlement: trade by trade or netted, and who carries the price risk in between.

  • Price source: the partner's live price, or a benchmark for valuations or scheduled buys, under an IBA licence.

  • Redemption: sell-back only, or bars and coins too. Bars are commonly traded in set weights, from 1 gram up (HMRC's list, section 15), and delivered gold is always allocated (section 16).

  • Card rules: limits for new customers, and a wait before paying out sales of card-bought gold, so a chargeback cannot follow a payout.

What drives the cost

Components, not prices:

  • the partner's spread, and your margin on top;

  • storage, insurance and audits of the metal;

  • fabrication and insured delivery, if you offer them;

  • card acceptance and payouts;

  • identity checks, screening and fraud tools for every customer;

  • price data, and a benchmark licence if you use the LBMA Gold Price;

  • compliance staff, reporting and VAT administration;

  • the connection to your partner, and the daily reconciliation.

Common mistakes

  • Holding customers' cash without a licence or a licensed partner.

  • Calling unallocated gold "your gold in the vault". It is a claim on whoever owes the metal.

  • Waiting for July 2027 in the EU. National rules apply now.

  • Ignoring sales below AED 55,000. MoET's guidance lists red flags that fit an app: small purchases that add up, several cards from one IP address, smaller retries after a decline, and card payments followed by requests for a refund in another form.

  • Assuming silver gets gold's VAT treatment in the EU.

What this means for your platform

Our white-label gold savings app covers both sides above: passkey sign-up with ID, liveness, sanctions and PEP checks; buying by the gram at a held price; weekly or monthly plans; sales paid out by SEPA Instant where the customer's bank takes it; and a ledger that books every gram and reconciles daily against your partner's statement. Margins, fees, fraud limits and an audit trail of every check sit in the backoffice. The library has no bullion or vault connector yet, so we build the connector to your partner as part of the work and hand it over with the rest of the source code, with no licence fee and no revenue share. Delivery of bars and coins, gold sent between customers, silver and platinum, or a card that spends gold can be assembled from the same modules, as can anything else you have in mind.

Sources

Checked on 7 October 2026.

Written by

Paynoramic's Head of IT

Head of IT

Head of IT at Paynoramic, responsible for the module library every platform is built from. Has worked on payment, banking and workforce platforms for companies including American Express, Teya and Indeed Flex, and for a global card issuer-processor. Writes about what a fintech or crypto launch needs beyond the software: licensing, certification and the real cost.

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