VARA License in Dubai: The Definitive Guide to Virtual Asset Licensing
A VARA license is the authorisation Dubai's Virtual Assets Regulatory Authority grants to a Virtual Asset Service Provider (VASP) to carry out specific virtual asset activities in or from Dubai, excluding the DIFC. It is issued per activity, sits on top of your ordinary trade licence, and must be in place before you onboard a single client.
- Regulator
- VARA, created by Dubai Law No. (4) of 2022
- Who needs it
- Any business offering regulated virtual asset services in or from Dubai, mainland or free zone (not DIFC)
- VARA fees
- AED 40,000–100,000 to apply, AED 80,000–200,000 a year in supervision, per activity
- Paid-up capital
- From AED 100,000 (Advisory) to AED 1.5 million or more (Exchange without a VARA-licensed custodian)
- Process
- IDQ → Approval to Incorporate (ATI) → full VASP licence
- Typical timeline
- 3 to 7 months
What is VARA?
The Virtual Assets Regulatory Authority (VARA) is Dubai's dedicated virtual asset regulator, established under Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai. It licenses and supervises VASPs operating on the Dubai mainland and in Dubai's free zones. The Dubai International Financial Centre is outside its remit and has its own regulator, the DFSA.
VARA's framework rests on the Virtual Assets and Related Activities Regulations 2023 and a set of rulebooks: four that apply to every VASP plus one rulebook for each licensed activity. The current versions were issued as Rulebook 2.0 and took effect on 19 June 2025.
The Four Compulsory Rulebooks
Company
Governance, capital, people and corporate requirements.
Compliance and Risk Management
AML/CFT, Travel Rule and risk frameworks.
Technology and Information
Systems, cybersecurity and data.
Market Conduct
Client dealings, disclosures and marketing.
Who Needs a VARA License?
Any business that carries out a regulated virtual asset activity by way of business in or from Dubai, or markets one to people in Dubai, needs a VARA licence for that activity. That includes exchanges, brokers and OTC desks, custodians and wallet providers, crypto fund managers, lenders, payment and settlement providers, token issuers and firms giving personalised crypto investment advice.
Not every crypto-related business needs a full licence. Proprietary trading with your own funds can require only a No Objection Certificate, with registration above certain volumes; some technology providers may only need to register.
Trade Licence vs VARA Licence
| Trade (commercial) licence | VARA licence | |
|---|---|---|
| Issued by | DET (mainland) or the Dubai free zone authority | VARA |
| What it does | Creates the legal entity | Authorises specific virtual asset activities |
| Enough to serve crypto clients? | No | Yes, for the licensed activities only |
| Scope | Company-wide | Activity by activity |
| Ongoing duties | Annual renewal, company filings | Rulebook compliance, reporting, annual supervision fee, renewal |
Types of VARA license (Licensed Activities)
VARA licenses seven VASP activities, plus Category 1 virtual asset issuance. You apply for each activity you will carry out.
Advisory Services
Personal recommendations to a client about virtual asset transactions, made at the client's request or on your own initiative.
Broker-Dealer Services
Arranging or matching orders, dealing on own account for clients, market-making, and placement or distribution of virtual assets.
Custody Services
Safeguarding client virtual assets and private keys, acting only on confirmed client instructions, with client assets segregated.
Exchange Services
Operating a venue that exchanges virtual assets for fiat or other virtual assets, including maintaining an order book.
Lending and Borrowing Services
Contracts under which virtual assets are lent by one party to another, with the borrower committing to return them.
VA Management and Investment Services
Managing client virtual assets as agent or fiduciary, including portfolio management and staking on clients' behalf.
VA Transfer and Settlement Services
Transferring virtual assets between parties and settling virtual asset transactions on behalf of others.
Category 1 VA Issuance
Issuing certain virtual assets, including fiat-referenced (FRVA) and asset-referenced (ARVA) tokens, requires a licence and VARA approval of the whitepaper. Category 2 issuances do not need a VARA licence but must be distributed through a licensed VASP.
One licence or several?
A single VASP can hold several activities, but it must meet the full requirements and capital of each one, with no blended standard. Custody is the exception: it must sit in a separate legal entity with its own VARA licence.
VARA License Requirements
- A Dubai legal entity on the mainland or in an eligible Dubai free zone (not DIFC), with activity wording aligned to the planned VARA activities.
- Fit and proper owners and management, with notarised and attested documents for foreign corporate shareholders.
- Responsible Individuals: at least two, full-time, meeting VARA's UAE residency requirements.
- Key officers: a Compliance Officer and an MLRO, plus technology and information security leadership.
- Paid-up capital for each activity (table below), held in a UAE bank account in favour of VARA.
- Net liquid assets of at least 1.2 times monthly operating expenses, maintained at all times.
- Insurance appropriate to the business (e.g. professional indemnity, directors and officers, crime).
- A physical office in Dubai.
- Policies and systems that meet every applicable rulebook: governance, AML/CFT and Travel Rule, technology and cybersecurity, market conduct and the activity rulebooks.
VARA License Cost: Fees And Capital
The cost of a VARA licence has three layers: VARA's own fees, paid-up capital that stays in the business, and the cost of setting up and running a compliant firm.
VARA Fees by Activity
| Activity | Application fee | Annual supervision fee |
|---|---|---|
| Advisory Services | AED 40,000 | AED 80,000 |
| VA Transfer and Settlement Services | AED 40,000 | AED 80,000 |
| Broker-Dealer Services | AED 100,000 | AED 200,000 |
| Custody Services | AED 100,000 | AED 200,000 |
| Exchange Services | AED 100,000 | AED 200,000 |
| Lending and Borrowing Services | AED 100,000 | AED 200,000 |
| VA Management and Investment Services | AED 100,000 | AED 200,000 |
Minimum Paid-Up Capital by Activity
| Activity | Paid-up capital (higher of) |
|---|---|
| Advisory Services | AED 100,000 |
| Broker-Dealer — using a VARA-licensed custodian | AED 400,000 or 15% of fixed annual overheads |
| Broker-Dealer — other cases | AED 600,000 or 25% of fixed annual overheads |
| Custody Services | AED 600,000 or 25% of fixed annual overheads |
| Exchange — using a VARA-licensed custodian | AED 800,000 or 15% of fixed annual overheads |
| Exchange — other cases | AED 1,500,000 or 25% of fixed annual overheads |
| Lending and Borrowing Services | AED 500,000 or 25% of fixed annual overheads |
| VA Management and Investment — using a VARA-licensed custodian | AED 280,000 or 15% of fixed annual overheads |
| VA Management and Investment — other cases | AED 500,000 or 25% of fixed annual overheads |
| VA Transfer and Settlement Services | AED 500,000 or 25% of fixed annual overheads |
| Category 1 VA Issuance | As set in the VA Issuance Rulebook |
Other Costs to Budget
Company formation and trade licence (DET or free zone)
Office lease in Dubai
Salaries for Responsible Individuals, Compliance Officer, MLRO and technology lead
Technology, custody, blockchain analytics and Travel Rule providers
Insurance, external audit and penetration testing
Legal and regulatory fees
Need help scoping the budget? Our VARA license consultants build it activity by activity.
How to Get a VARA License: The Process in Brief
- 1Define your activities and map your business model to VARA's licensed activities
- 2Choose your licensing authority: DET for the mainland or an eligible Dubai free zone
- 3Submit the IDQ through that authority, which passes it to VARA
- 4Apply and receive Approval to IncorporateBusiness plan, ownership, management, projections; first part of the fee
- 6Submit the full VASP licence application and answer VARA's clarification requests and gap lists
- 7Pay the remaining licence fees and first-year supervision fee
- 8Receive your VASP licencePossibly with conditions; listed on VARA's public register
Foreign founder, or want each stage broken down? Read the full VARA license process in Dubai.
How Long Does a VARA License Take?
Expect roughly 3 to 7 months from IDQ to full licence for a well-prepared applicant. The longest delays come from appointing Responsible Individuals, attesting foreign documents, generic policies that trigger extra questions, and slow responses to gap lists.
From IDQ to full VASP licence, for a well-prepared applicant.
The longest delays
- Appointing Responsible Individuals
- Attesting foreign documents
- Generic policies that trigger extra questions
- Slow responses to gap lists
Documents Required For a VARA License
The core file VARA expects across both stages. The process guide shows which documents go in at which step.
- Regulatory Business Plan and Regulatory Financial Plan (projections)
- Corporate documents: certificate of incorporation, MoA/AoA, shareholder register
- Group structure chart and Ultimate Beneficial Owner details
- Passports, CVs and fit-and-proper information for shareholders, directors and Responsible Individuals
- Source of funds and evidence of paid-up capital
- Policies: governance, compliance and risk management, AML/CFT and Travel Rule, technology and information security, market conduct, and activity-specific policies
- Outsourcing and vendor agreements
- Insurance certificates
- Business continuity, succession and wind-down plans
- Office lease
VARA vs DIFC, ADGM and Federal Regulation
| Regulator | Where it applies | Use it when |
|---|---|---|
| VARA | Dubai mainland and Dubai free zones, excluding DIFC | You operate in or serve clients from Dubai outside DIFC |
| DFSA | Dubai International Financial Centre | You want a DIFC base and its common-law, financial-centre regime |
| FSRA | Abu Dhabi Global Market (ADGM) | You want an Abu Dhabi base under ADGM's virtual asset framework |
| CMA (federal; replaced the SCA on 1 Jan 2026) | Onshore UAE outside emirate-level regimes | Your activity falls within federal virtual asset or securities rules |
What Changed in 2025–26
Rulebook 2.0
VARA reissued its rulebooks in May 2025; they took effect on 19 June 2025.
Activity rulebook updates
The Exchange Services Rulebook was updated again on 31 March 2026.
VA Issuance guidance
VARA published guidance on applying the VA Issuance Rulebook in April 2026.
Enforcement
VARA has stepped up action against unlicensed firms, including fines and cease-and-desist orders.
After You Get Your VARA License
Renew the licence every year and pay each activity's supervision fee in advance
Maintain paid-up capital and net liquid assets at all times, reconciling capital monthly
File periodic reports and notify VARA of material changes
Clear marketing with VARA's marketing rules before campaigns go live
Keep policies current with new rulebooks and circulars, and train staff
Disclose your licensed activities and licence details to clients
For post-licence support, see VARA compliance implementation and VARA Stage 2 policy drafting.
What Happens if You Operate Without a VARA License?
Carrying out a regulated virtual asset activity in Dubai without a licence exposes the business and its managers to VARA enforcement, including fines, cease-and-desist orders and public warnings. A trade licence gives no protection if the activity needed VARA authorisation. You can check whether a firm is licensed on VARA's public register.
VARA License FAQs
Have a question not covered here? Tell us what you plan to offer and we'll confirm what applies.
Ask our VARA teamGet Help With Your VARA License
Finjuris's lawyers take virtual asset businesses from structuring to full VASP licence and beyond. See how our VARA license consultants work, or book a free scoping call.
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Tell us which activities you plan to offer. We'll confirm the VARA licences, fees and capital that apply and reply within one business day.
