Virtual asset licensing in the UAE

Q: Which regulator licenses a crypto exchange in Dubai?

VARA, if the exchange operates in Dubai outside the DIFC. (Rule, VA Regulations 2023 Schedule 1) In the DIFC it is the DFSA. (Rule, DFSA GEN 3A)

Rules as at 3 November 2026. Each statement carries its label and the section it comes from. The rules engine works out which route applies to your business; Clara, Candovio's AI assistant, gathers the facts.

Which regulator applies, and when

Dubai, outside the DIFC. VARA. Rule VA Regulations 2023 Schedule 1 A VARA-licensed firm is registered with the UAE Capital Market Authority (UAE CMA) by default to serve the wider UAE, at AED 3,000 a year. Rule UAE CMA and VARA agreement, 5 September 2024; Cabinet Resolution 83/2025
In or from the DIFC. The DFSA, which requires the firm to assess each crypto token itself. Rule DFSA GEN 3A.2.1(3)
In or from ADGM. The FSRA, for Accepted Virtual Assets only. Rule FSRA COBS 17
Onshore outside Dubai. The UAE CMA, under the VASP General Module. Rule UAE CMA VASP General Module Art 2(1)
Tokens referenced to the dirham. The Central Bank only. Rule PTSR Art 2(8); VARA FRVA Rules I.B.4

Licence categories and base capital

VARA

Category	Activities	Base capital	Source
Advisory Services	Advice on virtual assets	AED 100,000	Rule VARA Company Rulebook VI.B.1
Broker-Dealer Services	With a VARA-licensed custodian; with own custody	Higher of AED 400,000 or 15% of fixed annual overheads; higher of AED 600,000 or 25%	Rule VARA Company Rulebook VI.B.1
Custody Services	Holding virtual assets for clients	Higher of AED 600,000 or 25% of fixed annual overheads	Rule VARA Company Rulebook VI.B.1
Exchange Services	With a VARA-licensed custodian; with own custody	Higher of AED 800,000 or 15%; higher of AED 1,500,000 or 25%	Rule VARA Company Rulebook VI.B.1
VA Management and Investment Services	With a VARA-licensed custodian; with own custody	Higher of AED 280,000 or 15%; higher of AED 500,000 or 25%	Rule VARA Company Rulebook VI.B.1
Lending and Borrowing; Transfer and Settlement	Each a separate activity	Higher of AED 500,000 or 25% of fixed annual overheads	Rule VARA Company Rulebook VI.B.1

UAE CMA

Category	Activities	Base capital	Source
Category One	Dealing in virtual assets as principal	AED 4m or 25% of annual expenses, whichever is higher	Rule UAE CMA VASP General Module Art 21(1)
Category Two	Dealing as agent or matched principal	AED 1m or 25% of annual expenses	Rule VASP General Module Art 21(1)
Category Three	Custody	AED 3m or 25% of annual expenses	Rule VASP General Module Art 21(1)
Categories Four and Five	Arranging and advice; portfolio management	AED 1m or 25% of annual expenses	Rule VASP General Module Art 21(1)
Category Six	Multilateral trading facility	AED 500,000 or 35% of annual expenses	Rule VASP General Module Art 21(1); ATS Module

DFSA and FSRA

Category	Activities	Base capital	Source
DFSA Category 3B, crypto custody	Providing custody of crypto tokens	USD 1m	Rule DFSA PIB 3.6.2
FSRA virtual-asset activities	Dealing, managing, custody or a trading facility in Accepted Virtual Assets	The capital of the underlying category	Rule FSRA COBS 17; PRU 3.3.2

Key requirements

VARA custody must be run as a separate legal entity with its own licence. Guidance VARA: Licensed activities
A VARA firm needs two full-time Responsible Individuals, a resident Compliance Officer with five years' experience, an MLRO, a Chief Information Security Officer, a Company Secretary and a fit-and-proper board. Rule VARA Company Rulebook I.B to I.E; CRM Rulebook I.C.1, I.D.2, III.A
VARA fees: AED 100,000 to apply and AED 200,000 a year per activity, or AED 40,000 and AED 80,000 for Advisory and Transfer and Settlement Services. Rule VARA Regulations Schedule 2
A UAE CMA virtual-asset firm's Senior Manager, chief executive, Compliance Officer and MLRO must be resident, and it needs a physical head office in the State. Rule UAE CMA VASP General Module Art 54 to 57
The FSRA adds USD 20,000 per virtual-asset activity to the application fee, or USD 125,000 for a trading facility. Rule FSRA FEES 3.17, 3.18

Application stages

Assessment. The assessment gives a provisional result in about ten minutes, reviewed by a person before it is released to you, and Candovio confirms the route with you on a call.
Application pack. The AI assistant drafts the business plan, policies and forms; Candovio checks every line; you approve it.
Submission and questions. We file the application and answer the regulator's questions from the same record.
Decision and conditions. The regulator decides, usually first in principle with conditions, and the licence follows once the conditions are met.

VARA: an Approval to Incorporate first, then the VASP Licence, with no published decision period. Guidance VARA: Licence applications UAE CMA: an in-principle decision within 45 working days of a complete application and a licence decision within 60 working days. Rule UAE CMA VASP General Module Art 26, 74 We do not promise timelines.

Questions

Which regulator licenses a crypto exchange in Dubai?

VARA, if the exchange operates in Dubai outside the DIFC. Rule VA Regulations 2023 Schedule 1 In the DIFC it is the DFSA. Rule DFSA GEN 3A

Does a VARA custodian need its own company?

Yes. Custody must be run as a separate legal entity with its own licence. Guidance VARA: Licensed activities

How long does the UAE CMA take to decide a virtual-asset application?

An in-principle decision within 45 working days of a complete application, and a licence decision within 60 working days. Rule UAE CMA VASP General Module Art 26, 74