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Dubai skyline — VARA license jurisdiction
VARA · Dubai VASP Licensing ·

VARA License Dubai

Eight regulated virtual asset activities, one regulator. Application fees from AED 40,000, paid-up capital from a flat AED 100,000. We manage the file end to end.

8licensed activities
AED 40Kapplication fee, from
AED 100Kcapital, from
4–7months to licence
Quick reference

VARA licensing at a glance.

Activities, fees, capital, timeline and scope of a Dubai VARA license — every figure taken from VARA’s own published framework.

A VARA license authorises virtual asset activity in or from Dubai — mainland and all free zones except the DIFC. VARA licenses eight discrete activities, and each must be applied for explicitly. Application fees are AED 40,000 or AED 100,000 depending on activity; annual supervision is AED 80,000 or AED 200,000. Paid-up capital runs from a flat AED 100,000 for Advisory Services up to the higher of AED 1,500,000 or 25% of overheads for an Exchange without a licensed custody provider. You will need a Dubai LLC or free zone company, two VARA-approved Responsible Individuals, and — for seven of the eight activities — a private office. Realistic timeline is four to seven months.
Key facts · VARA License Dubai 2026
Regulator
Virtual Assets Regulatory Authority (VARA), Dubai
Legal basis
Dubai Law No. 4 of 2022; Virtual Assets and Related Activities Regulations 2023
Licensable activities
8 discrete VA activities — each applied for explicitly
Application fee
AED 40,000 (Advisory, Transfer & Settlement) · AED 100,000 (other six)
Annual supervision fee
AED 80,000 · AED 200,000 — per activity, payable in advance
Paid-up capital
From AED 100,000 flat (Advisory) to AED 1,500,000 (Exchange)
Entity type
LLC or Free Zone company — sole proprietorships not accepted
Responsible Individuals
2 minimum, full-time, UAE resident or UAE passport holder
Timeline
4–7 months, IDQ to full VASP Licence
Geographic scope
Dubai mainland and all free zones except DIFC
The regulator

What a VARA license actually is.

VARA is the Virtual Assets Regulatory Authority, established by Dubai Law No. 4 of 2022 as the world’s first regulator built specifically for virtual assets rather than adapted from banking rules. It is the sole authority regulating virtual assets across Dubai’s mainland and free zones, with one exception: the DIFC.

I.

Activity-specific, not a blanket permit

A VARA licence authorises a legal entity to carry out specified virtual asset activities. An entity licensed for Broker-Dealer Services may not run an exchange. Adding an activity means a separate application, a separate fee and a separate capital requirement. Getting classification wrong is the most expensive mistake in a VARA application, because fees, capital, office requirements and applicable rulebooks all follow from it.

II.

Who needs one

Exchanges, broker-dealers and OTC desks, custodians, lending and borrowing platforms, virtual asset managers and funds, transfer and settlement providers, stablecoin issuers, and advisory firms. It also catches businesses that do not consider themselves crypto firms — an NFT marketplace, a payments platform settling in virtual assets, or a technology provider whose product feature is functionally a custody or exchange service.

III.

Who does not

Proprietary traders using only their own funds with no clients do not currently require a Licence — though they do need a No Objection Certificate, and registration above VARA’s volume threshold. Metaverse operators sit outside the perimeter unless conducting regulated VA activity. DLT providers not offering VA activities may register voluntarily. DIFC entities are regulated by the DFSA, not VARA.

IV.

No activity is exempt

The framework leaves no gap. Every virtual asset service or activity in or from Dubai requires a licence, a registration, or a No Objection Certificate. VARA supervises the market through both on-chain and off-chain methods, and enforcement runs from cease-and-desist orders through fines and licence suspension to potential entity closure.

Regulated activities

The eight VARA license categories.

VARA does not issue a single “crypto license”. It licenses eight discrete Virtual Asset activities, each of which must be applied for explicitly. Application fee shown first; paid-up capital second. Both are payable to VARA and are separate from professional fees.

Dubai skyline — VA Advisory Services under VARA
I.

VA Advisory Services

Advice on virtual assets without holding client assets or executing trades. The lowest-barrier activity in the framework — the only one with a flat capital requirement and the only one that does not require a private office. Research houses, token advisory firms, treasury consultants.

Application feeAED 40,000
Paid-up capitalAED 100,000
Trading desk — VA Broker-Dealer Services in Dubai
II.

VA Broker-Dealer Services

Dealing in virtual assets for clients, or arranging deals. Capital drops materially if you use a VARA-licensed custody provider rather than self-custodying. OTC desks, brokerages, introducing brokers.

Application feeAED 100,000
Paid-up capitalAED 400K–600K
Institutional custody vault — VA Custody Services under VARA
III.

VA Custody Services

Safeguarding virtual assets for or on behalf of another entity, acting only on verified instructions. Catches more businesses than founders expect — an exchange holding client assets is carrying out custody.

Application feeAED 100,000
Paid-up capitalAED 600,000
Exchange order book — VA Exchange Services under VARA
IV.

VA Exchange Services

Operating a virtual asset trading venue. The heaviest activity on every axis: highest capital, highest supervision fee, deepest scrutiny.

Application feeAED 100,000
Paid-up capitalAED 800K–1.5M
Lending and yield analytics — VA Lending and Borrowing
V.

VA Lending & Borrowing

Lending or borrowing virtual assets, including margin and yield products.

Application feeAED 100,000
Paid-up capitalAED 500,000
Portfolio management — VA Management and Investment Services
VI.

VA Management & Investment

Managing virtual assets or portfolios on a discretionary or advisory-plus basis. Fund and asset managers.

Application feeAED 100,000
Paid-up capitalAED 280K–500K
Payments and settlement rails — VA Transfer and Settlement
VII.

VA Transfer & Settlement

Transfer, payment and settlement of virtual assets. Sits in the low fee band alongside Advisory — a detail most published guidance gets wrong.

Application feeAED 40,000
Paid-up capitalAED 500,000
Stablecoin issuance — VA Issuance Category 1 under VARA
VIII.

VA Issuance — Category 1

Issuance of Fiat-Referenced Virtual Assets (stablecoins). Governed by the VA Issuance Rulebook and its Annexes, including the FRVA Issuance Rules.

Application feeAED 100,000
Paid-up capitalPer Issuance Rulebook

Category 2 issuance is different. Issuing a Category 2 virtual asset — a new token release, or minting NFTs — requires prior approval from VARA under the VA Issuance Rulebook, not a licence. Entities submit a VARA Issuance Approval Form with a whitepaper and full issuer details, evidence AML/CFT compliance, and meet technical, information-security, data-privacy and cryptographic controls. Anonymity-enhanced tokens are prohibited. Material changes to an approved virtual asset require whitepaper re-submission, VARA re-approval and a modification fee.

Transparent pricing

See your full VARA cost
before you commit.

Regulator fees, capital, Responsible Individuals, office and professional fees — itemised, with the honest first-year total.

Authorisation routes

VARA license, registration or NOC?

Most guidance treats VARA as licence-only. It is a three-tier authorisation framework, and no virtual asset activity is exempt from supervision. Any VA service or activity requires a licence, a registration, or a No Objection Certificate.

RouteWho it applies toWhat it involves
LicenceAny entity carrying out one or more of the eight regulated VA Activities in or from DubaiFull two-stage application, capital, Responsible Individuals, rulebook compliance
RegistrationLarge proprietary traders above VARA’s volume thresholdRegistration with VARA and subject to regulatory oversight
NOCProprietary traders generally; DLT providers may register voluntarilyNo Objection Certificate held at all times — annual fee AED 1,000
I.

Proprietary traders

If you trade only your own funds with no clients — and not as a service to friends, family or a third-party mass market — you are not required to hold a VARA Licence at this time. You do still need a No Objection Certificate at all times. Above a volume threshold, registration becomes mandatory regardless of whether the trading is undertaken as a business.

II.

A note on the threshold, stated honestly

VARA’s own FAQ expresses this two ways in two different answers: a cumulative 30-day rolling volume above USD 250 million in one, and above AED 1 billion monthly rolling volume in another. The two are broadly equivalent in magnitude but not identical, and VARA has not reconciled the wording publicly.

If your volumes are anywhere near either figure, treat registration as likely and confirm your position with VARA through your commercial licensor rather than relying on a published summary — including this one.

III.

DLT service providers

A DLT provider carrying out any of the eight regulated activities needs a Licence. A DLT provider not currently offering VA activities may register with VARA voluntarily, preserving the option to add VA activities later.

IV.

Metaverse and NFT businesses

Metaverse operators are generally not required to hold a VARA licence at present, unless they conduct regulated VA activities. NFT marketplaces are treated differently: entities holding an NFT Marketplace commercial licence from a free zone must obtain a VA Exchange licence and/or a VA Broker-Dealer licence from VARA, depending on what the marketplace actually does.

Official fee schedule

VARA license fees — the official schedule.

These are the fees payable to VARA, set by regulation in Schedule 2 of the Virtual Assets and Related Activities Regulations 2023. They are separate from professional fees, paid-up capital, office costs and any fees charged by your commercial licensor.

There are two fee bands, not one. Published guidance frequently presents the AED 40,000 / AED 80,000 figures as though they applied universally. They apply to two of the eight activities — Advisory Services and Transfer and Settlement Services. The other six sit in the AED 100,000 / AED 200,000 band.

VA ActivityLicence Application FeeAnnual Supervision Fee
VA Advisory ServicesAED 40,000AED 80,000
VA Transfer and Settlement ServicesAED 40,000AED 80,000
VA Broker-Dealer ServicesAED 100,000AED 200,000
VA Custody ServicesAED 100,000AED 200,000
VA Exchange ServicesAED 100,000AED 200,000
VA Lending and Borrowing ServicesAED 100,000AED 200,000
VA Management and Investment ServicesAED 100,000AED 200,000
VA Issuance — Category 1AED 100,000AED 200,000
I.

Adding activities: the extension fee

Applying for more than one activity attracts a Licence Extension Fee of 50% of the lower Licence Application Fee(s) for each additional activity — not a flat second fee.

Worked example: apply for Broker-Dealer Services (AED 100,000) and add Advisory Services. The extension fee is 50% of AED 40,000 — the lower of the two — so AED 20,000. Not AED 50,000, and not AED 100,000.

II.

When fees fall due

Application and extension fees are payable at the point of submission, and VARA will not process the application until payment is received. In practice the initial payment to commence review is typically 50% of the licence application fee, with the balance falling due at the full licence stage.

Annual supervision fees are payable per licensed activity, in advance of conducting that activity. A VASP licensed for three activities pays three supervision fees.

III.

Variable fees: what the table does not show

VARA may, at its sole and absolute discretion, impose additional supervision fees or modify fees based on a VASP’s risk profile. The published factors are market share; target market and client base; complexity of business model and products; compliance and regulatory history; and circumstances where VARA considers additional oversight resource necessary, including in response to complaints.

A retail-facing exchange with significant Dubai volume should not budget the table figure as a ceiling. An institutional advisory firm with a handful of clients reasonably can.

IV.

Other published VARA fees

Proprietary trading annual NOCAED 1,000
Licence update (per request)AED 500
Licence withdrawal and wind-downAED 10,000
Whitepaper submission (Category 1 issuers)AED 5,000
Capital & prudential

VARA capital requirements by activity.

Capital sits in the Company Rulebook, Part VI — Rule VI.B, separately from the fee schedule. Most activities use a “higher of (i) a fixed AED amount or (ii) a percentage of fixed annual overheads” formula, so the requirement scales with your cost base. Figures below are read directly from the Rulebook, current version 19 May 2025.

VA ActivityPaid-Up Capital Requirement
VA Advisory ServicesAED 100,000 — flat, no overhead formula
VA Broker-Dealer ServicesUsing a VARA-licensed custody provider (or otherwise approved during licensing): higher of AED 400,000 or 15% of fixed annual overheads. Otherwise: higher of AED 600,000 or 25%
VA Custody ServicesHigher of AED 600,000 or 25% of fixed annual overheads
VA Exchange ServicesWith a VARA-licensed custody provider (or approved): higher of AED 800,000 or 15%. Otherwise: higher of AED 1,500,000 or 25%
VA Lending and Borrowing ServicesHigher of AED 500,000 or 25% of fixed annual overheads
VA Management and Investment ServicesWith a VARA-licensed custody provider (or approved): higher of AED 280,000 or 15%. Otherwise: higher of AED 500,000 or 25%
VA Transfer and Settlement ServicesHigher of AED 500,000 or 25% of fixed annual overheads
VA Issuance — Category 1As specified in the VA Issuance Rulebook or its Annexes
I.

The custody decision is a capital decision

Three activities carry a materially lower requirement if you use a VARA-licensed custody provider instead of self-custodying. For Exchange Services the difference is AED 800,000 versus AED 1,500,000, and a 15% versus 25% overhead multiplier. That is a structuring choice worth taking before you file, not after.

II.

How capital stacks across activities

A VASP licensed for more than one activity must hold the specified capital for each activity, each calculated using the fixed annual overheads for that activity only. In combination all paid-up capital must be mutually exclusive and collectively exhaustive — total overheads fully accounted for, no double-counting, no gaps. Paid-up capital is reconciled monthly.

III.

Where the capital has to sit

Held and maintained at all times in one of: a trust account with a UAE-licensed bank naming VARA as beneficiary; a surety bond from a UAE-authorised surety company with no end date, naming VARA as beneficiary; or any other manner VARA specifies on granting the licence.

This is not a balance-sheet figure you demonstrate once. It is locked, controlled and continuously maintained, with real treasury consequences.

IV.

The three further prudential layers

Net Liquid Assets — current liquid assets less current liabilities must be at least 1.2× monthly operating expenses.

Insurance — professional indemnity, directors’ and officers’, and crime cover including hot-wallet exposure, plus any lines VARA stipulates.

Reserve Assets — where applicable, 100% of client liabilities held 1:1 in the same virtual asset.

Cost analysis

Which VARA license is cheapest?

Answering this properly requires reading three separate VARA sources together — the fee schedule, the capital rulebook and the physical-presence rules. Do that, and one activity is clearly the lowest-barrier entry point.

 VA Advisory ServicesVA Exchange Services
Licence Application FeeAED 40,000AED 100,000
Annual Supervision FeeAED 80,000AED 200,000
Paid-up capitalAED 100,000 flatHigher of AED 1,500,000 or 25% of overheads
Private office requiredNo — the only exempt activityYes
I.

A 15× difference in capital

VA Advisory Services is the cheapest VARA licence on every dimension simultaneously, and it is the only one of the eight activities that does not require a private office. VARA requires a physical presence in Dubai for all VASPs, but the private-office requirement attaches to the other seven: Broker-Dealer, Custody, Exchange, Lending and Borrowing, Management and Investment, Transfer and Settlement, and Category 1 Issuance.

II.

The trade-off — stated plainly

Advisory Services does not permit you to hold client assets, execute trades or operate a venue. If your model needs any of those, Advisory is not a cheaper route to the same outcome — it is a different licence for a different business. Applying for Advisory and then operating outside its scope is an enforcement matter, not a cost saving.

Where Advisory genuinely fits — research, token advisory, treasury consulting — it offers a regulated Dubai footprint at a fraction of the capital lock-up, and it can be extended later at 50% of the lower application fee.

Eligibility

VARA license requirements.

What VARA expects in place before it will grant a full VASP Licence — entity, presence, people and paperwork.

I.

Entity

A Limited Liability Company or a Free Zone company. Sole proprietorships are not accepted. The entity must be established with the Department of Economy and Tourism (mainland) or a Dubai free zone other than DIFC — commonly DMCC or DWTC. There are no nationality restrictions and 100% foreign ownership is available.

II.

Physical presence

All VASPs must have a physical presence in Dubai. A private office is required for seven of the eight activities: Broker-Dealer, Custody, Exchange, Lending and Borrowing, Management and Investment, Transfer and Settlement, and Category 1 Issuance. VA Advisory Services is the only exception. VARA sets no minimum size — your commercial licensor sets space requirements based on headcount.

III.

Responsible Individuals

Senior management must comprise suitably qualified individuals, and the VASP must appoint two Responsible Individuals. Each must be a full-time employee of the VASP, a Fit and Proper Person approved by VARA, and a UAE resident or a holder of a UAE passport.

This is the most commonly underestimated line in a VARA budget. Because RIs must be full-time and UAE-resident, they cannot be shared across entities or engaged part-time.

IV.

Documentation

At minimum: a regulatory business plan with financial projections; governance and organisational structure; AML/CFT and KYC policies and procedures; risk assessment and management framework; technology, cybersecurity and operational resilience documentation; Fit and Proper evidence for key personnel; and evidence of paid-up capital in an approved form. VARA states its document list is non-exhaustive.

How it works

How to get a VARA license — the two-stage process

VARA’s licensing pathway runs in two stages: an Initial Disclosure Questionnaire leading to an Approval to Incorporate, then a full VASP Licence application. Submissions are made through your commercial licensor — DET for mainland entities or the relevant Dubai free zone — not directly to VARA.

I
Stage 1 · Step 1

Submit the Initial Disclosure Questionnaire

Submit the IDQ to Dubai Economy & Tourism or the relevant free zone, disclosing your proposed VA activities, business model, ownership and control structure, ultimate beneficial owners, and senior management. Submissions are made through your commercial licensor — never directly to VARA.

TypicalWeeks 1–3
II
Stage 1 · Step 2

Supporting documentation & initial fee

Provide a business plan and details of beneficial owners and senior management. Pay the initial fee to commence review — typically 50% of the licence application fee. The application is not processed until payment is received.

TypicalWeeks 2–4
III
Stage 1 · Step 3

VARA initial assessment

The commercial licensor screens the submission and transfers it to VARA. VARA may request clarification, or decline to proceed where the activity falls outside its regulatory perimeter or the firm does not meet the standards to be regulated.

TypicalWeeks 4–8
IV
Stage 1 · Step 4

Receive Approval to Incorporate

ATI allows you to finalise legal incorporation and begin operational setup — office lease, employee onboarding, infrastructure. ATI is not a licence. At this stage you are not permitted to carry on any virtual asset activity.

TypicalMonth 2–3
V
Stage 2 · Step 5

Submit the full VASP application

Regulatory business plan, AML/CFT framework, KYC procedures, governance, cybersecurity and technology documentation, and evidence of paid-up capital in an approved form.

TypicalMonth 3–4
VI
Stage 2 · Step 6

Regulator engagement

Expect meetings, interviews with Responsible Individuals, and requests for further documentation. Pay the remaining balance of the application fee. This is where most timeline slippage happens.

TypicalMonth 4–6
VII
Stage 2 · Step 7

Satisfy conditions & go live

Office lease executed, paid-up capital in place in an approved form, operational readiness demonstrated. VARA issues the full VASP Licence; the annual supervision fee is paid in advance of commencing activity.

TypicalMonth 5–7

Critical: ATI is not a licence. At the ATI stage you are not permitted to carry on any virtual asset activity. ATI approves you to incorporate and build; it does not approve you to operate. Confusing the two is a compliance failure, not a technicality.

Timeline reality

VARA license timeline — what stalls applications.

Four to seven months from IDQ to full VASP Licence for a well-prepared applicant, with Stage 2 typically running three to five months after initial approval. Poorly prepared files run considerably longer. The variance is almost entirely on the applicant’s side — VARA’s process has defined stages; what extends it is incomplete submissions and unresolved queries.

I.

Misclassifying the activity

The single most expensive error. Fees, capital, office requirements and applicable rulebooks all follow from activity classification. Discovering mid-application that your “product feature” is regulated custody means restarting the cost model.

II.

Applying for one activity when the model needs two

Extension fees are modest — 50% of the lower application fee — but a scope change mid-file means new documentation and a new regulatory conversation.

III.

Treating capital as a balance-sheet figure

It must sit in a UAE bank trust account with VARA as beneficiary, or an open-ended surety bond. Sourcing that structure takes time founders rarely budget.

IV.

Underestimating Responsible Individuals

Two full-time, UAE-resident, VARA-approved individuals. Recruiting them after ATI rather than lining them up before is a common multi-month delay.

V.

A business plan that does not match the licence

VARA reads the two together. Inconsistency triggers query rounds.

VI.

Assuming ATI permits operations

It does not — and acting as though it does is an enforcement risk rather than a delay.

VII.

A generic AML/CFT framework

Templated policies that do not reflect the actual business model, customer base and virtual asset exposure generate the deepest query rounds. This is the single most common cause of Stage 2 slippage.

VIII.

Leaving banking to the end

Paid-up capital must sit in a UAE trust account naming VARA as beneficiary, or an open-ended surety bond. Bank onboarding for a virtual asset business is not quick, and it cannot start until the entity exists. Firms that treat it as a final formality routinely lose four to eight weeks at the last conditions stage.

Jurisdictional scope

VARA, DIFC and the Dubai regulatory map.

VARA is the sole authority regulating virtual assets across Dubai’s free zones and mainland, with one carve-out: the Dubai International Financial Centre, which sits outside VARA’s jurisdiction entirely and is regulated by the Dubai Financial Services Authority under its own digital assets regime.

I.

The most frequently muddled point in Dubai crypto licensing

A DIFC entity does not need a VARA licence, and cannot obtain one for DIFC activity. A mainland or non-DIFC free zone entity cannot rely on a DFSA authorisation. Free zones including DMCC and DWTC sit inside VARA’s perimeter — a DMCC company conducting VA activity needs a VARA licence.

II.

It is a regulator choice, not a location preference

If you are weighing DIFC against VARA, you are choosing between two different regulators, two different rulebooks and two different capital regimes — not two addresses. See our DIFC crypto license page for the DFSA route.

2026 update

VARA and the new federal CMA framework.

On 1 January 2026 the UAE replaced its federal securities regulator and issued an entirely new federal VASP framework. Most published VARA guidance predates this and describes a regulatory map that no longer exists.

I.

What changed on 1 January 2026

Federal Decree-Law No. 32 of 2025 established the Capital Market Authority (CMA) as an independent federal regulator. Federal Decree-Law No. 33 of 2025 codified capital markets regulation and expanded financial products to include virtual assets.

Together they repealed Federal Law No. 4 of 2000, which established the Securities and Commodities Authority. The CMA is the SCA’s legal successor; every reference to the SCA in existing UAE legislation is now read as a reference to the CMA. This was not a rebrand — penalties for unauthorised activity rose to AED 250 million, with enforcement reaching any person targeting clients in the UAE from anywhere in the world.

II.

CMA Decision No. 4/R.M/2026

Following FDL 33, the CMA issued Decision No. 4/R.M/2026, a comprehensive framework for virtual asset activities. It does not amend the previous SCA regime — it replaces it in full.

The decision introduces a modular, activity-based model with eight licensed virtual asset activities, materially higher capital, governance and compliance thresholds, and transitional arrangements for existing SCA-licensed VASPs. In-scope entities must regularise within one year from 1 January 2026, extendable at the CMA’s discretion.

III.

Does this change anything for a VARA applicant?

For a business establishing in Dubai outside the DIFC: no. VARA remains the competent authority.

The CMA framework is not designed to displace emirate-level regimes. It establishes a federal baseline for onshore virtual asset activity that operates alongside them, and it expressly excludes the financial free zones — the DIFC and ADGM.

Where it does matter: activity beyond Dubai or onshore outside the emirate sits in CMA territory; existing SCA-licensed VASPs face migration within the transition window; and multi-jurisdiction structures now need scope mapped deliberately across four regimes.

IV.

Ongoing obligations once licensed

The VA licence runs 12 months, with renewal notification 90 days in advance and the annual supervision fee due at renewal, per activity, in advance.

Prudentially: paid-up capital held continuously in an approved form and reconciled monthly; Net Liquid Assets at 1.2× monthly operating expenses; insurance in place; Reserve Assets at 100% of client liabilities where applicable.

VASPs also sit within the UAE federal AML/CFT regime — Federal Decree-Law No. 10 of 2025 (in force 14 October 2025) with executive regulations under Cabinet Resolution No. 134 of 2025 (effective 14 December 2025). Obligations include customer due diligence, UBO identification against the 25% test under Cabinet Decision 109/2023, targeted financial sanctions screening under Cabinet Decision 74/2020, suspicious transaction reporting to the FIU via goAML, and appointment of a compliance officer. Penalties run to AED 100 million for legal persons and up to ten years’ imprisonment for individuals.

Regulator comparison

VARA vs CMA vs DIFC vs ADGM — the 2026 UAE map.

As of 2026 there are four distinct virtual asset regimes in the UAE, and choosing between them is the first real decision a founder makes.

RegimeScopeLegal basis & systemLicensed activitiesTypical fit
VARAPurpose-built VA regulatorDubai mainland + all Dubai free zones, except DIFCDubai Law No. 4 of 2022; VA Regulations 2023UAE / Dubai civil law8 discrete activitiesDubai-based platforms, exchanges, Web3-native, retail-facing
CMA federalCapital markets regulatorUAE onshore — excludes DIFC and ADGMFDL 32 & 33 of 2025; Decision 4/R.M/2026UAE federal civil law8 licensed activitiesUAE-wide onshore activity; firms migrating from SCA
DIFC DFSAFinancial services regimeDIFC onlyDFSA digital assets regimeEnglish common lawEndorsement on a financial services licenceToken issuance needing common-law certainty; institutional
ADGM FSRAFinancial services regimeADGM, Abu DhabiFSRA virtual assets frameworkEnglish common lawFSRA permissionsInstitutional, funds, asset managers

How to choose. Three questions settle most cases. Where will you operate — Dubai only points to VARA; UAE-wide onshore brings the CMA into scope. Who are your clients — retail leans VARA, institutional leans DIFC or ADGM. Does your product look like a security — common-law centres handle that more comfortably. Larger virtual asset businesses frequently hold more than one authorisation. That is a structuring decision with real capital consequences, worth taking before you file rather than after.

Our engagement

VARA license application support from Sovera Global.

Application management and coordination of UAE-licensed specialist counsel. No consultancy submits directly to VARA — every application routes through your commercial licensor, DET or a free zone. What determines outcomes is the quality and sequencing of the file. That is what we manage.

I.

Entry tier

VA Advisory Services · VA Transfer and Settlement Services

Sovera fee from$12,500
VARA fees payable separately: AED 40,000 application · AED 80,000 annual · capital from AED 100,000
II.

Standard tier

VA Broker-Dealer · VA Lending and Borrowing · VA Management and Investment

Sovera fee from$22,500
VARA fees payable separately: AED 100,000 application · AED 200,000 annual · capital from AED 280,000
III.

Complex tier

VA Exchange · VA Custody · VA Issuance Category 1

Sovera fee from$38,000
VARA fees payable separately: AED 100,000 application · AED 200,000 annual · capital from AED 600,000
I.

What the engagement covers

Activity classification and scope strategy — mapping your business model to the right activity before you file, and modelling the fee, capital and office consequences of each option.

Entity formation — Dubai mainland via DET, or a free zone inside VARA’s perimeter. Quoted separately: DMCC from $6,500, DIFC from $15,000.

Cost and capital modelling — a full first-year budget: application and extension fees, annual supervision, paid-up capital in an approved form, Net Liquid Assets, Responsible Individuals, office, insurance, audit.

Application assembly and file management across both stages, plus banking introductions for the capital trust account.

II.

Why the AML piece matters most

VARA applications stall most often on generic, templated AML frameworks that do not reflect the actual business. This is the part we build ourselves rather than outsource.

Sovera Global operates as Sovera Global L.L.C-FZ, a licensed UAE DNFBP and trust and company service provider regulated for AML/CFT purposes. We build AML programmes to UAE federal standard as core business, not as an adjacent service — policies, business and customer risk assessments, CDD and UBO procedures, targeted financial sanctions screening, transaction monitoring, training and record-keeping.

Every VARA mandate begins with a scoping call. We will tell you what your realistic first-year budget is before you commit to anything — including when the honest answer is that a different jurisdiction fits better.

Questions we receive

VARA licensing, answered frankly.

How much does a VARA license cost in Dubai?
VARA’s own fees fall into two bands. Advisory Services and Transfer and Settlement Services cost AED 40,000 to apply and AED 80,000 in annual supervision. The other six activities cost AED 100,000 to apply and AED 200,000 annually. Those are regulator fees only — total first-year cost also includes paid-up capital from AED 100,000, two Responsible Individuals, office, audit and professional fees. Sovera’s application-management fee starts from $12,500.
What is the minimum capital for a VARA licence?
AED 100,000, flat, for VA Advisory Services — the lowest in the framework. Other activities use a “higher of a fixed amount or a percentage of fixed annual overheads” formula, ranging from AED 280,000 for Management and Investment with an approved custody arrangement up to AED 1,500,000 for Exchange Services without one.
How long does it take to get a VARA license?
In Dubai, realistically four to seven months from Initial Disclosure Questionnaire to full VASP Licence for a well-prepared applicant, with Stage 2 typically running three to five months after initial approval. Incomplete applications and unresolved regulator queries are what extend it.
How many VARA license categories are there?
In Dubai, eight regulated VA Activities: Advisory, Broker-Dealer, Custody, Exchange, Lending and Borrowing, Management and Investment, Transfer and Settlement, and Category 1 Issuance. Each is discrete and must be applied for explicitly.
Do I need a VARA licence for an NFT marketplace?
In Dubai, yes, in most cases. Entities holding an NFT Marketplace commercial licence from a free zone must obtain a VA Exchange licence and/or a VA Broker-Dealer licence from VARA, depending on the marketplace’s actual activities.
Does a DIFC company need a VARA licence?
No. VARA is the sole regulator for virtual assets across Dubai’s mainland and free zones except the DIFC, which is regulated separately by the Dubai Financial Services Authority under its own digital assets regime.
What is the difference between a VARA licence, registration and an NOC?
A Dubai Licence is required to carry out any of the eight regulated VA Activities. Registration applies to large proprietary traders above VARA’s volume threshold. A No Objection Certificate applies to proprietary trading generally, at an annual fee of AED 1,000. No virtual asset activity is exempt from supervision.
Do proprietary traders need a VARA licence?
In Dubai, not if you trade only your own funds with no clients. You do need a No Objection Certificate at all times. Above VARA’s volume threshold, registration is mandatory regardless of whether the trading is a business. VARA’s FAQ states that threshold two ways — a 30-day rolling volume above USD 250 million, and above AED 1 billion monthly rolling — so confirm your position directly if you are near either figure.
Can a foreigner own 100% of a VARA-licensed company?
Yes. There are no nationality restrictions on VARA licence applicants and 100% foreign ownership is available. The application must be made on behalf of a legal entity established with DET or a Dubai free zone other than DIFC.
How many Responsible Individuals does VARA require?
Two, as a minimum. Each must be a full-time employee of the Dubai VASP, a Fit and Proper Person approved by VARA, and either a UAE resident or a UAE passport holder.
Do I need a physical office for a VARA licence?
All VASPs need a physical presence in Dubai. A private office is required for seven of the eight activities. VA Advisory Services is the only exception. VARA sets no minimum size — your commercial licensor does, based on headcount.
Can I apply to VARA directly?
No. Applications are submitted through your commercial licensor — the Department of Economy and Tourism for mainland entities, or a Dubai free zone authority such as DWTC or DMCC. VARA assesses the file but does not receive it directly.
Is a VARA licence renewed annually?
Yes. The Dubai licence runs for 12 months, VARA issues renewal notification 90 days in advance, and the annual supervision fee falls due at renewal.
What entity type do I need for a VARA licence?
A Limited Liability Company or a Free Zone company. Sole proprietorships are not accepted.
What happens if I operate without a VARA licence?
VARA supervises the Dubai market through both on-chain and off-chain methods. Enforcement includes cease-and-desist orders, reprimands, warnings, fines, licence suspension, restrictions on scope of service, and potential entity closure — coordinated with commercial licensing bodies.
Do I need a VARA licence or a CMA licence?
If your business is established in Dubai outside the DIFC, VARA is your regulator. The Capital Market Authority’s Decision No. 4/R.M/2026 sets a federal baseline for onshore virtual asset activity across the UAE, operating alongside emirate-level regimes rather than replacing them, and expressly excluding the DIFC and ADGM. Firms operating beyond Dubai, or holding legacy SCA authorisations, need to map both.
What is CMA Decision No. 4/R.M/2026?
The UAE’s federal virtual asset framework, issued by the Capital Market Authority following Federal Decree-Law No. 33 of 2025. It replaces the previous SCA regime in full, introduces a modular activity-based model with eight licensed virtual asset activities, and applies materially higher capital, governance and compliance thresholds. In-scope entities must regularise within one year of 1 January 2026.
Does the SCA still regulate crypto in the UAE?
No. In Dubai, the Securities and Commodities Authority was replaced by the Capital Market Authority on 1 January 2026 under Federal Decree-Laws No. 32 and 33 of 2025. The CMA is the SCA’s legal successor, and all references to the SCA in existing legislation are now read as references to the CMA. Guidance still describing the SCA as the federal regulator is out of date.
What are the penalties for unlicensed virtual asset activity in the UAE?
In Dubai, under VARA, enforcement includes cease-and-desist orders, fines, licence suspension, scope restrictions and potential entity closure. At federal level, the 2025 capital markets laws raised penalties for unauthorised activity to AED 250 million, with enforcement reaching any person targeting clients in the UAE from anywhere in the world. Separately, UAE AML penalties under Federal Decree-Law No. 10 of 2025 run to AED 100 million for legal persons and up to ten years’ imprisonment for individuals.
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Tell us the activity you need and we will come back with a realistic first-year budget — VARA fees, capital, Responsible Individuals and our fee, itemised.

We reply within one business day. No obligation, and we will say so if a different jurisdiction fits you better.

Primary sources

Everything on this page, sourced.

Every fee, capital and procedural figure above is taken from VARA’s published framework rather than secondary summaries. Where VARA’s own guidance is internally inconsistent, we say so rather than picking a number.

Federal framework: Federal Decree-Law No. 32 of 2025 (Capital Market Authority); Federal Decree-Law No. 33 of 2025 (Regulation of the Capital Market); CMA Decision No. 4/R.M/2026. AML/CFT: Federal Decree-Law No. 10 of 2025; Cabinet Resolution No. 134 of 2025; Cabinet Decision 109/2023; Cabinet Decision 74/2020.

Written and maintained by Azim Shamuhammedov, CEO of Sovera Global L.L.C-FZ, a UAE-licensed DNFBP and trust and company service provider. This page is general information, not legal advice. Fees and requirements change — confirm with VARA or your commercial licensor before relying on any figure for a final budget.

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A scoping call first — activity classification, realistic first-year budget, and an honest view on whether Dubai is the right venue for your model. Then a dated proposal with the full pathway, timeline and fee schedule.

Operators serving African and Asian markets alongside the Gulf frequently pair VARA with a Mauritius VASP licence, which carries five distinct classes and an effective rate near 3% on virtual asset income.