Virtual Assets Regulatory Authority (VARA)

Rules as at 3 November 2026. Each statement carries its label and the section it comes from.

No person may conduct a licensable virtual-asset activity in the emirate without a permit from VARA. A business must also establish itself in the emirate and obtain VARA's approvals before starting the commercial-licensing process. Rule Law No. (4) of 2022, Article 15

New firms apply in two stages: an Approval to Incorporate, and then a VASP Licence. VARA may decline a licence where the firm's activities fall outside its perimeter or the firm does not meet its standards. Guidance VARA: Licence applications

For federal anti-money-laundering purposes, VARA is the supervisory authority for virtual-asset service providers and virtual-asset activities in the emirate. Rule VARA Rulebook, Introduction

Who it licenses

Firms carrying on the virtual-asset activities in Schedule 1 of the Regulations in Dubai outside the DIFC. Rule VA Regulations 2023 Schedule 1 Security tokens fall under the securities regimes, and tokens referenced to the UAE dirham are for the Central Bank only. Rule VA Regulations 2023 Schedule 1; VARA FRVA Rules I.B.4 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

Activities and capital

A firm may also operate as a sponsored VASP under a regulated sponsor for any activity except custody and exchange, with VARA's approval, a Dubai entity and a full-time Responsible Officer. Rule VARA CRM Rulebook Part VII

Fees

• Application fee: AED 100,000, or AED 40,000 for Advisory and for Transfer and Settlement Services. Adding an activity costs 50% of the lower application fee. Rule VARA Regulations Schedule 2
• Annual fee: AED 200,000 per activity, or AED 80,000 for Advisory and for Transfer and Settlement Services. VARA may raise it on risk. Rule VARA Regulations Schedule 2

People, insurance and reporting

A VARA firm needs two full-time Responsible Individuals, a full-time resident Compliance Officer with five years' experience, an MLRO, a Chief Information Security Officer who is not the Compliance 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; Technology and Information Rulebook Part I

It must hold professional indemnity, directors' and officers' and commercial crime cover for hot-wallet assets from a regulated insurer, in amounts set in the licence. Rule VARA Company Rulebook VI.D.1 to VI.D.4

It reports net liquid assets monthly, files annual audited accounts and has reserve assets audited every six months. Rule VARA Company Rulebook VI.C, VI.E

Documents

Every application pack, whichever the regulator, contains the same core documents. Rule VARA Company Rulebook; Compliance and Risk Management Rulebook

• Regulatory business plan: the activities applied for, clients, products, three-year financial projections, and the capital plan showing the base capital and how it is funded.
• Corporate documents: constitution or articles, an ownership chart to the ultimate beneficial owners, the group structure, and for a branch the home regulator's consent or no-objection.
• Fit-and-proper files for every controller, director and senior manager: CVs, declarations, criminal and credit checks, and the regulator's own individual forms.
• Compliance and AML framework: compliance manual, AML and CFT policy and risk assessment, and the MLRO arrangements.
• Risk management framework and internal controls, including outsourcing and IT and cyber policies.
• Financial resources: capital adequacy workings and, for existing groups, audited accounts.
• Evidence of premises and of professional indemnity insurance where the category requires it.

VARA runs two stages: an Initial Disclosure Questionnaire and provisional approval first, then the full licence file against the four mandatory rulebooks (Company; Compliance and Risk Management; Technology and Information; Market Conduct) and the rulebook for each activity. The file names two Responsible Individuals and includes custody term sheets, and a commercial licence from the Department of Economy and Tourism or a free zone comes before the VARA licence. Rule VARA Company Rulebook; Compliance and Risk Management Rulebook; Technology and Information Rulebook; Market Conduct Rulebook; Law No. (4) of 2022, Article 15

How to apply, and published timelines

1. Confirm the activities. Clara, our AI assistant, maps your business to VARA's activity list.
2. Apply for the Approval to Incorporate. Guidance VARA: Licence applications
3. Establish the Dubai entity with the commercial licensor, after VARA's approval. Rule Law No. (4) of 2022, Article 15
4. Apply for the VASP Licence. Guidance VARA: Licence applications

VARA publishes no decision period. It sends a renewal notice 90 days before a licence expires. Guidance VARA: Licence applications; FAQ We do not promise timelines.

Check a firm

The public register on vara.ae lists licensed virtual-asset service providers. Guidance VARA: Licensed activities and register

Questions