In Dubai's financial free zone the capital behind a crypto permission is set by the financial service you are authorised for, not by the fact that it is crypto.
the spread of base capital across the DFSA categories a crypto firm applies in
the crypto token regime has been in force since 1 November 2022, amended 12 January 2026
what a crypto trading venue pays to apply, against USD 15,000 for advising and arranging
A crypto licence in DIFC is a Financial Services Permission granted by the Dubai Financial Services Authority (DFSA) under its Crypto Token Regime, in force since 1 November 2022. The DFSA licenses financial services rather than crypto as such, so base capital follows the services applied for: USD 30,000 for advising and arranging (Category 4), USD 200,000 for dealing as agent or operating a trading venue (Category 3A), USD 1,000,000 for custody of crypto assets (Category 3B) and USD 2,000,000 for dealing on the firm's own book (Category 2). Application fees run from USD 15,000 for advising and arranging to USD 150,000 for a crypto trading venue. Applicants report six to nine months from first contact to permission; the Rulebook sets no processing time. The Senior Executive Officer, Compliance Officer and MLRO must be resident in the UAE. The regime fits institutional businesses whose counterparties need English common law and a DFSA-registered firm. Protegra's work on a DIFC application is EUR 70,000 to 75,000.
| Item | Figure | Rule |
|---|---|---|
| Regulator | Dubai Financial Services Authority (DFSA), DIFC free zone only | Crypto Token Regime, since 1 Nov 2022, amended 12 Jan 2026 |
| Category 4 — advising, arranging | USD 30,000 base capital | PIB 3.6.2 |
| Category 3A — dealing as agent, trading venue (ATS) | USD 200,000 base capital | PIB 3.6.2 |
| Category 3B — custody of crypto assets | USD 1,000,000 base capital | PIB 3.6.2 |
| Category 2 — dealing as principal | USD 2,000,000 base capital (USD 500,000 as matched principal) | PIB 3.6.2 |
| Application fee | USD 15,000 advising or arranging; USD 25,000 dealing as agent, custody or managing assets; USD 150,000 crypto ATS | FER VER35/04-26, FER 2.1 |
| Realistic timeline | 6–9 months in practice; no processing time in the Rulebook | Applicants' reports, not a DFSA standard |
Sources: DFSA Rulebook — PIB 3.6.2 (base capital), FER VER35/04-26 (fees), GEN 7.5.1 and 7.5.2 (residency), COB Chapter 15 (crypto tokens); DFSA public register, September 2026. Timeline figures are applicants' reports, not a DFSA standard.
UNITED ARAB EMIRATESA financial free zone inside the emirate of Dubai, running on English common law, with its own courts and its own regulator.
The Dubai International Financial Centre is a place rather than a licence category. Inside it English common law applies and the DIFC Courts hear the disputes, in English. The regulator is the Dubai Financial Services Authority, the free zone's own independent financial regulator, and it supervises what happens inside the centre and nothing beyond it.
Crypto is not bolted onto that structure. The DFSA's Crypto Token Regime came into force on 1 November 2022, out of Consultation Paper 143 and the rulebook amendments that went with it, and it has been revised since. A crypto firm is then governed by the ordinary DFSA modules rather than by a separate crypto rulebook: GEN for authorisation and approved individuals, COB Chapter 15 for the conduct of crypto business — custody, trading, suitability, client money — PIB for capital and liquidity, FER for fees, and the AML module for financial crime.
What the DFSA grants at the end of it is a Financial Services Permission, and which financial services sit inside that permission is what decides everything downstream. The public register of authorised firms is published on the DFSA's own site, and the names on it describe the centre better than any brochure does: Nomura Laser Digital, Nine Blocks Capital, Brevan Howard.
This is the thing most readers arrive with wrong. The line between the two Dubai regimes is territorial, not activity-based: it runs along the boundary of the free zone, and the emirate next door adds a third regulator on the other side of it. Before anything else is decided, the address the entity sits at decides who authorises you.
Two categories are permitted. Crypto Tokens — Bitcoin, Ether, Litecoin, XRP and TON among them, together with any token that passes the DFSA's liquidity and transparency tests — and Fiat-Referenced Tokens, the stablecoins referenced to a fiat currency. Both are handled under COB Chapter 15, which is where the conduct rules for crypto business sit.
Two are prohibited outright: privacy tokens, Monero and Zcash among them, and algorithmic stablecoins. No permission makes either of them workable inside the DIFC, so a business model resting on one changes or goes somewhere else.
How a token gets assessed changed on 12 January 2026. Before that date the DFSA charged USD 5,000 to recognise a token and carried out the assessment itself. Since then the fee is gone and the firm performs the assessment, against those liquidity and transparency tests. The cost falls and the judgement moves: it is now yours to make, document and defend when the regulator comes to look at it.
The DFSA grants a Financial Services Permission over named financial services, and the prudential category follows from the bundle of services on that permission rather than from whether crypto tokens are involved. The figures below are the base capital requirements in PIB 3.6.2; the categories themselves are defined in PIB 1.3.1 to 1.3.7.
| Category | Base capital (USD) | What sits in it |
|---|---|---|
| Category 1 | 10,000,000 | Accepting Deposits. This is a bank. |
| Category 2 | 2,000,000 | Dealing in Investments as Principal — trading on the firm's own book |
| Category 3A | 200,000 | Dealing in Investments as Agent, and Operating an Alternative Trading System — a trading venue sits here |
| Category 3B | 1,000,000 | Providing Custody of Crypto Assets |
| Category 3C | 500,000 | Managing assets and managing funds |
| Category 3D | 200,000 | — |
| Category 4 | 30,000 | Arranging Deals in Investments, Advising on Financial Products, Arranging Custody, Fund Administration, Trust Services, Money Transmission, Arranging Credit, Crowdfunding |
| Category 5 | 10,000,000 | An Islamic financial institution |
Several categories carry sub-cases, and a sub-case moves the figure further than the choice of category does. Category 2 falls to USD 500,000 where the firm deals in investments as principal only as a matched principal. Inside Category 3B, custody of a fund with no crypto tokens in it is USD 500,000, a Trustee of a Fund is USD 2,000,000, and an Employee Money Purchase Scheme is USD 500,000 for the operator and USD 1,000,000 for the administrator; where a firm holds several of these services, the highest of the figures applies. Inside Category 3C, Managing a Collective Investment Fund is USD 140,000 for a Public Fund or a Credit Fund and USD 40,000 otherwise, while Managing Assets or a PSIAr is USD 140,000. Category 4 rises to USD 140,000 for Operating a Crowdfunding Platform or Providing Money Transmission.
The USD 1,000,000 in the Category 3B row is the figure for a firm whose only service is Providing Custody of Crypto Assets. Add a second service and the rule is the same as everywhere else in this table: the highest applicable figure wins.
Guidance that puts a crypto exchange in Category 1 is reading the wrong row, and the error is expensive: Category 1 carries USD 10,000,000 of base capital against USD 200,000 for the category a trading venue actually needs. Category 1 is the permission for Accepting Deposits, which is what a bank does. Operating an Alternative Trading System is a Category 3A activity, alongside Dealing in Investments as Agent. If you have been quoted ten million dollars of capital to run a trading platform in the DIFC, the quote is not describing the DFSA rulebook.
The figure in the table is the least the firm may ever hold, not the amount it will end up holding. A DFSA firm holds the higher of its base capital requirement and whichever calculated minimum applies to it: the Expenditure Based Capital Minimum in PIB 3.7, the Risk Capital Requirement in PIB 3.8, or the Activity Based Capital Requirement in PIB 3.8C.
For a small firm the base figure is the one that binds. For a firm with a real cost base or a real book, one of the calculated minima overtakes it and the base figure stops being the number that matters. Read the table as the entry price of a category, and build the capital plan from the calculation that applies to you.
The same rules read from the other end. Start from the economic activity, and the category and the base figure follow from it. This is what the DFSA's category definitions produce; it is not a promise of the letter that will appear on your permission, which is settled with the regulator once it knows what you do with client money and client assets.
| What the business does | DFSA category | Base capital (USD) |
|---|---|---|
| Advising on crypto assets | 4 | 30,000 |
| Receiving and transmitting orders — arranging | 4 | 30,000 |
| Managing client portfolios | 3C | 140,000 |
| Executing orders as agent | 3A | 200,000 |
| Running a trading platform — an Alternative Trading System | 3A | 200,000 |
| Dealing as a matched principal | 2 | 500,000 |
| Dealing on the firm's own book | 2 | 2,000,000 |
| Holding client crypto assets in custody | 3B | 1,000,000 |
Sixty-six times separates the two ends of that column — USD 30,000 to advise, USD 2,000,000 to deal on your own book — and both ends are the same regulator, the same rulebook and the same free zone. What the permission costs to carry is decided by the activity, not by the jurisdiction. Choosing to arrange rather than to deal, or to place client assets with somebody else's custodian rather than hold them yourself, is the single decision on this page that moves the most money.
Portfolio management appears here at USD 140,000 rather than at the USD 500,000 printed against Category 3C above, because Managing Assets is one of the sub-cases that category carries. It is the same rule reaching a different figure, not a second rule.
Category 4 — advising or arranging, with nothing of the client's in your hands
Category 3A — Operating an Alternative Trading System, which is where a trading venue actually sits
Category 3B — Providing Custody of Crypto Assets as the firm's only service
Category 2 — Dealing in Investments as Principal, on the firm's own book
The figures come from the DFSA's own fee module, FER VER35/04-26. The first is paid when the application goes in, the second every year the permission stays open.
The Category 4 services. With crypto tokens in the permission the annual fee is USD 20,000 rather than USD 15,000.
Category 3D. The fee table carries no crypto line against this service.
One fee line covers both services. Dealing as agent is Category 3A; dealing as a matched principal is prudentially Category 2, and the fee follows the service rather than the category. USD 35,000 a year once crypto tokens are in the permission.
Category 3B. USD 35,000 a year with crypto tokens.
Category 3C. USD 35,000 a year with crypto tokens.
Category 2. The crypto line of the annual fee is USD 70,000; the application fee does not move.
The one service where crypto changes the application fee as well. A crypto ATS pays USD 150,000 to apply, and its annual fee is set on the scale at FER 3.2.4 — from USD 150,000 to USD 800,000.
Category 1, which is a bank. It is not the category an exchange applies in, whatever comparison tables print.
The DFSA charges by financial service rather than by prudential category, and a firm pays on the highest service its licence carries (FER 2.1.1, FER 3.2.1). A permission covering both arranging and custody is charged once, at the custody figure, not at both.
One line that circulates widely does not exist here. There is no Crypto Token Activity Supplement of USD 10,000 at the DFSA — no charge of that name appears anywhere in FER. What is being described is an Abu Dhabi charge: the ADGM FSRA does levy a crypto supplement, USD 20,000 on application and USD 15,000 a year, under its FEES 3.17.1 and 3.17.2. A different regulator in a different emirate, copied into DIFC guidance and left there.
The ten thousand itself comes from the table above. For dealing as agent, dealing as matched principal, managing assets and providing custody, the crypto line of the annual fee sits exactly USD 10,000 above the ordinary one. That is a second row in the same table, not a separate charge, and calling it a supplement payable on application gets both the amount and the frequency wrong.
A genuine USD 10,000 one-off does exist, and it is narrow. FER 2.1.2(3) and FER 2.1.5(2) charge it on an application from an exchange or an alternative trading system that trades tokens and has Direct Access Members. Outside that case it is not payable at all.
Two costs people expect to find on this list sit outside the module. Registering the company with the DIFC Registrar of Companies and taking the office are DIFC charges rather than DFSA ones, and the DFSA publishes no figure for either. Whatever is quoted for them comes from practice, and is worth reading as practice.
GEN 7.5.1(1) names four Authorised Individuals the DFSA has to approve. Three of the four must be resident in the United Arab Emirates. The fourth is the one published guidance most often gets wrong.
GEN 7.5.1(1)(a). Subparagraph (a) is one of the three the residency rule refers to, so this officer is resident in the UAE.
GEN 7.5.1(1)(c), and again one of the three named in GEN 7.5.2. Resident in the UAE.
GEN 7.5.1(1)(d), the third subparagraph GEN 7.5.2 refers to, so the money laundering reporting officer is resident in the UAE.
GEN 7.5.1(1)(b) — and subparagraph (b) is the one GEN 7.5.2 leaves out. The omission is deliberate: the Finance Officer is not required to be resident in the UAE.
One rule decides all four lines, and it decides them by naming three letters out of four.
| Role | Resident in the UAE | Rule |
|---|---|---|
| Senior Executive Officer | Yes | GEN 7.5.1(1)(a), listed in GEN 7.5.2 |
| Compliance Officer | Yes | GEN 7.5.1(1)(c), listed in GEN 7.5.2 |
| Money Laundering Reporting Officer | Yes | GEN 7.5.1(1)(d), listed in GEN 7.5.2 |
| Finance Officer | No | GEN 7.5.1(1)(b), absent from GEN 7.5.2 |
GEN 7.5.2 reads, in full: "The Authorised Individuals referred to in Rule 7.5.1(1)(a), (c) and (d) must be resident in the U.A.E." Set that against GEN 7.5.1(1), where (a) is the Senior Executive Officer, (b) the Finance Officer, (c) the Compliance Officer and (d) the MLRO. The rule names (a), (c) and (d). It does not name (b).
So the Finance Officer may sit outside the United Arab Emirates. Guidance that puts all four officers in the UAE has read a name into a list that does not contain it, and on a first hiring plan that is one resident seat fewer than you may have budgeted for.
Advisory material routinely lists an independent external audit of smart contracts and custody technology as something the DFSA requires before it issues the Financial Services Permission. That requirement is not confirmed in the rulebook, and this page will not present it as one. Applicants report commissioning such reviews; budget one as practice rather than as a condition the permission is withheld for.
Six to nine months end to end. None of that sits in the Rulebook, and we have found no published DFSA processing statistics, so every figure below is what applicants report rather than a standard the regulator has committed to.
Which regulated financial services the permission will carry is settled before anything is filed, because the DFSA reads everything else off that list. The prudential category comes from the set of services applied for rather than from the fact that the business is in crypto (PIB 1.3), the base capital follows from the category (PIB 3.6.2), and that base figure is a floor rather than an estimate — a firm holds the higher of it and the applicable calculated minimum under PIB 3.7, 3.8 and 3.8C. This stage runs at your own speed, and it is the one where a decision is still cheap to change.
The application is built against the DFSA's own Rulebook: GEN for authorisation and the approved individuals, COB Chapter 15 for how crypto business is conducted, PIB for capital, the AML module for financial crime controls. The application fee falls due here. The DFSA charges by financial service rather than by prudential category, and a firm pays on the highest service its licence carries (FER 2.1.1 and FER 3.2.1). Crypto moves the application figure in one case: an ATS that trades tokens pays USD 150,000 rather than USD 65,000, and an application from an exchange or an ATS that trades tokens and has Direct Access Members carries a one-off USD 10,000 as well (FER 2.1.2(3) and FER 2.1.5(2)). Since 12 January 2026 a firm assesses for itself whether a token meets the DFSA's liquidity and transparency tests, and the USD 5,000 the DFSA once charged to recognise one has gone — that assessment is now the firm's own to make and to evidence.
This is the DFSA's own review and the longest part of the route. Applicants, and the firms that file for them, report three to five months from submission to In-Principle Approval. There is no published service standard behind that range: it describes what a cohort of applications did, which is a different thing from what yours will do.
In-Principle Approval is granted subject to conditions, and every one of them is yours to close: registering the company with the DIFC Registrar of Companies, paying the capital in, signing the office lease, and hiring the Senior Executive Officer and the MLRO. Those two must be resident in the UAE, as must the Compliance Officer — GEN 7.5.1(1)(a), (c) and (d), listed in GEN 7.5.2. The Finance Officer is the approved individual that list leaves out: sub-paragraph (b) is absent from GEN 7.5.2, and a Finance Officer who lives elsewhere is not a defect in the file. In practice this stage runs two to three months.
With the conditions evidenced, the DFSA issues the permission itself. Applicants report two to four weeks for this last step. Three to five months with the regulator, two to three with you, two to four weeks of issuing at the end — and six to nine months is the figure applicants quote for the route as a whole. That last number is a reported range, not a total computed from the stages above.
None of those timings is in the Rulebook. We have found no published DFSA target for authorisation and no published statistics against which to measure one, so the six to nine months above is read off what applicants and their advisers report. It is quoted here as practice rather than as a rule.
It is worth knowing which half of the clock is yours. The three to five months to In-Principle Approval and the two to four weeks to the permission belong to the DFSA, and no amount of preparation buys them back. The two to three months of conditions between them is largely yours to set — company registration, capital, lease, hires — and it is the one stage where being ready in advance changes the date. Even there the DIFC Registrar of Companies and the visa process keep their own pace.
Three of the costs in the conditions stage are not the DFSA's at all. Registration with the DIFC Registrar of Companies, the office lease and the residence visas are charged by the DIFC itself, and none of the three appears in the DFSA Rulebook. We have not confirmed a figure for any of them against a published schedule, so this page prints none rather than repeat one from somebody else's table.
One more item belongs in the same column. An independent external audit of smart contracts and custodial arrangements, carried out before the permission is granted, is described by several advisers as a requirement. We have not found it in the Rulebook. Treat it as something a DFSA applicant may well end up doing, not as a rule you can plan a date around.
Most of this is arithmetic rather than judgement. The DFSA charges by service and sets capital by prudential category, and the services a consumer-facing business needs are the expensive ones.
This is the readership the prudential table is kindest to. Category 3C carries a base of USD 500,000, but the exceptions are where fund and asset management actually sit: USD 140,000 for Managing Assets and for a Public or Credit Fund, and USD 40,000 for managing other collective investment funds (PIB 3.6.2).
Providing Custody of Crypto Assets as the sole service is Category 3B at a base of USD 1,000,000, against USD 500,000 for fund custody without crypto. Counterparties that make you hold that much are usually the same banks and funds that will only deal with a firm holding it.
The DIFC runs on English common law with its own courts, which hear disputes in English. That is the single thing no amount of onshore structuring reproduces, and it is the reason most institutional clients are here at all.
The DFSA maintains a public register of authorised firms at dfsa.ae/public-register, and the crypto names on it are institutional — Nomura Laser Digital, Nine Blocks Capital and Brevan Howard among them. Being listed beside those firms is part of what the fee buys.
The annual supervisory fee lives as long as the permission does: USD 20,000 for arranging or advising with crypto in the licence, USD 35,000 for custody, dealing as agent or managing assets. A business that can absorb those in a quiet year is the business this regime is sized for.
A venue where third parties trade with each other is an Alternative Trading System, Category 3A. The application fee for a crypto ATS is USD 150,000 against USD 65,000 for an ordinary one, and annual supervision runs from USD 150,000 to USD 800,000 on the scale at FER 3.2.4. The DFSA charges on the highest-charging service in the licence rather than on an average (FER 2.1.1), so adding a venue to an otherwise modest permission sets the whole bill.
Then the arithmetic settles it before the merits do. The lightest crypto permission — arranging or advising, Category 4 — is USD 15,000 to apply, USD 20,000 a year in supervision, and USD 30,000 of base capital that stays on the balance sheet rather than being spent. Our own work on a DIFC application is EUR 70,000 to EUR 75,000. Nothing in that list is the office, the DIFC Registrar of Companies, or the people you have to hire.
Neither is available here. Privacy tokens, Monero and Zcash among them, and algorithmic stablecoins are excluded from the crypto token regime under COB Chapter 15, so there is no version of this application that succeeds.
Three approved individuals must be resident in the UAE: the Senior Executive Officer, the Compliance Officer and the MLRO (GEN 7.5.1 and 7.5.2). The Finance Officer is the role that list deliberately leaves out — anyone budgeting a fourth relocation on the strength of a summary is paying for a rule that is not there.
It does not. VARA regulates mainland Dubai and the commercial free zones under UAE civil law; the DFSA regulates the DIFC and nothing outside it. Neither permission is valid in the other's territory, and holding one is not a step towards the other.
If your business sits in the second column, the useful answer is not a cheaper structure inside the DIFC — it is a different regulator. A retail exchange, a P2P platform or a first licence on a budget under USD 150,000 belongs where the fee schedule was not written for institutions, and El Salvador and Canada are the two routes we would put in front of you first. If the business has to be in Dubai, VARA regulates mainland Dubai and the commercial free zones, and that is a separate application rather than a downgrade of this one.
We would rather say this in the first conversation than in the fourth. Money in a DFSA application goes out at the front and does not come back: the application fee is paid to file, the base capital is a floor the firm holds continuously and not a deposit — a firm holds the higher of it and the expenditure, risk and activity-based minima at PIB 3.7, 3.8 and 3.8C — and the supervisory fee recurs whether the volume arrives or not. Applicants and the firms advising them report six to nine months to a Financial Services Permission: three to five for in-principle approval, two to three to meet its conditions, and two to four weeks for the permission itself. The DFSA Rulebook sets no processing time, so that figure is practice and should be read as practice.
The reason to pay for this anyway is narrow, and it is real. If your counterparties are banks, funds and their risk committees, the answer to who regulates you and under what law is part of the product rather than a compliance overhead. English common law, the DIFC Courts and a name on the DFSA's public register are what the price buys. If that sentence does not describe a conversation you are already having, you are buying the expensive version of something that costs less elsewhere.
Two regulators, two legal systems, two territories inside the same emirate. VARA regulates crypto in mainland Dubai and in the commercial free zones — DMCC, DWTC, IFZA and the rest — under the civil law of the United Arab Emirates. The DFSA regulates the DIFC and nothing outside it, under English common law, with the DIFC Courts hearing disputes in English. Being in Dubai is most of what the two have in common.
No, and a DFSA permission is no use outside the DIFC either. The two regimes do not recognise one another: the DFSA's writ runs to the territory of the DIFC, VARA's runs to mainland Dubai and the commercial free zones, and a firm that wants both sides of the city applies twice.
Category 3A. A trading venue is Operating an Alternative Trading System, which sits in 3A alongside Dealing in Investments as Agent, and the base capital is USD 200,000. Category 1 — the answer a good deal of published guidance gives — is Accepting Deposits at USD 10,000,000 of base capital, which is a bank rather than an exchange. Anyone who puts a venue in Category 1 has confused the DIFC with a different regulator's table.
It depends on the services in the permission, and the spread inside this one regulator is wide: from USD 30,000 for advising or arranging in Category 4 to USD 2,000,000 for dealing on your own book in Category 2. Executing orders as agent or running a trading system is USD 200,000; managing client portfolios is USD 140,000; dealing as matched principal is USD 500,000. Those are base figures from PIB 3.6.2, and a base figure is a floor rather than a budget — the firm holds the higher of the base capital and whichever calculated minimum applies: the expenditure-based minimum in PIB 3.7, the risk capital requirement in PIB 3.8, or the activity-based requirement in PIB 3.8C.
USD 1,000,000, where Providing Custody of Crypto Assets is the only service in the permission. That is Category 3B, which also carries USD 500,000 for fund custody without crypto and USD 2,000,000 for acting as Trustee of a Fund. Where a firm holds several of these services the highest figure applies rather than the sum. And as everywhere else in PIB, the base figure is the floor: if the calculated minimum comes out higher, the calculated minimum is what the firm holds.
Fees follow the financial service rather than the prudential category, and a firm pays at the rate of the highest service in its permission (FER 2.1.1 and FER 3.2.1). Arranging or advising is USD 15,000 to apply and USD 15,000 a year, rising to USD 20,000 a year with crypto. Providing custody, managing assets and dealing as agent are each USD 25,000 to apply and USD 25,000 a year, or USD 35,000 with crypto. Dealing as principal is USD 40,000 to apply and USD 50,000 a year, or USD 70,000 with crypto. Operating an alternative trading system is USD 65,000 to apply, and a crypto ATS is USD 150,000 to apply with an annual fee scaled under FER 3.2.4 from USD 150,000 to USD 800,000.
There is no Crypto Token Activity Supplement in the DFSA's fee module, at any figure. The supplement people have in mind belongs to the FSRA in Abu Dhabi — USD 20,000 on application and USD 15,000 a year under FEES 3.17.1 and 3.17.2 — and that is a different regulator in a different emirate. At the DFSA crypto costs more through a higher line inside the annual fee table, not through a separate charge. The gap between the ordinary and the crypto rate is exactly USD 10,000 a year for dealing as agent, matched principal, managing assets and providing custody, which is where the story about a USD 10,000 supplement started; it is annual, not a one-off, and it is not payable on application. The one genuine one-off of USD 10,000 sits in FER 2.1.2(3) and FER 2.1.5(2), and it is charged only on an application for an exchange or an ATS that trades tokens and has Direct Access Members.
Not since 12 January 2026. The amendments that took effect that day removed the USD 5,000 fee for recognition of a crypto token and moved the assessment to the firms themselves. A licensee now self-assesses a token against the DFSA's liquidity and transparency tests instead of paying to have it recognised.
Crypto Tokens and Fiat-Referenced Tokens, under COB Chapter 15. Bitcoin, Ether, Litecoin, XRP and TON are in, along with any token that passes self-assessment against the DFSA's liquidity and transparency tests. Privacy tokens such as Monero and Zcash are prohibited, and so are algorithmic stablecoins — no category of permission makes either of them workable inside the DIFC.
Three of the approved individuals: the Senior Executive Officer, the Compliance Officer and the MLRO. GEN 7.5.2 sets the residency requirement by naming three subparagraphs of GEN 7.5.1(1) — (a), (c) and (d) — and those three are the SEO, the Compliance Officer and the MLRO.
No. The Finance Officer is GEN 7.5.1(1)(b), and (b) is the one subparagraph GEN 7.5.2 leaves out of its residency list: the rule names (a), (c) and (d) and stops there. The omission is deliberate rather than a drafting slip, so advice that treats a UAE residence visa for the Finance Officer as a condition of the permission is adding a requirement the rule does not contain.
Not as a rule we can point to. An independent external audit of smart contracts and custodial arrangements before the Financial Services Permission is issued appears in advisory material and in applicants' accounts of their own files, but the requirement is not confirmed in the Rulebook. Treat it as practice worth budgeting for, not as a condition of authorisation.
Applicants and law firms report six to nine months, and nobody can turn that into a date. The DFSA publishes no timetable for this, so the figure comes from practice rather than from the Rulebook: in the accounts we have, roughly three to five months to in-principle approval, two to three months to close the conditions — the DIFC ROC registration, the capital, the office lease, the hiring of the SEO and the MLRO — and two to four weeks for the permission itself. Almost everything after the in-principle approval depends on parties the regulator does not control, which is exactly why a promised date is worth nothing.
Nowhere. A Financial Services Permission is good inside the DIFC and nowhere outside it — not in mainland Dubai and not in the commercial free zones, where VARA is the regulator, and not inside ADGM in Abu Dhabi, which is a separate common-law zone with a regulator and a rulebook of its own. There is no mutual recognition in either direction, and a firm that needs two territories makes two applications.
Reference: Virtual asset service provider (non-MiCA) licences compared in the Licensing Atlas.
Tell us what the business actually does and roughly what it costs to run a year. You get back the DFSA category that follows from it, the base capital that category carries, the fee line from FER, and what the file has to prove.