Financial Services Permission with Virtual Asset Activities Endorsement (Abu Dhabi Global Market (ADGM))
The Virtual Asset Activities Endorsement in ADGM is granted by the FSRA as an endorsement on a Financial Services Permission under FSMR 2015. It allows firms to operate crypto exchanges, custodial wallets, and brokerages. Applicants require minimum capital of USD 250,000 for custody or 6 to 12 months of operational expenses for trading facilities, local physical substance in Abu Dhabi with resident officers, and pay a USD 20,000 endorsement fee.
At a glance
| Official name | Financial Services Permission with Virtual Asset Activities Endorsement1 |
|---|---|
| Local name | إذن تقديم الخدمات المالية مع إقرار بأنشطة الأصول الافتراضية |
| Also known as | ADGM virtual asset licence · FSRA crypto licence · ADGM crypto licence · FSP permission with virtual asset activities · FSP · FSRA |
| Issued by | Financial Services Regulatory Authority |
| Jurisdiction | Abu Dhabi Global Market (ADGM) |
| Licence family | Virtual asset service provider (non-MiCA) |
| Legal basis | Financial Services and Markets Regulations 2015, Sections 5A, 16, 27, 302 FSRA Anti-Money Laundering and Sanctions Rulebook (AML)3 FSRA Guidance: Regulation of Virtual Asset Activities in ADGM (VER07.100625)4 |
| Passporting | Domestic only: The Financial Services Permission is valid exclusively within the Abu Dhabi Global Market financial free zone. There are no passporting arrangements to UAE mainland, the DIFC, or foreign jurisdictions; cross-border operations into other jurisdictions must comply with local licensing or reverse solicitation frameworks.4 |
| Minimum capital | USD 250,0004 |
| Application fee | USD 20,0001 |
| Annual fee | USD 15,0001 |
| Statutory decision time | No statutory deadline: FSMR sets no decision period for a new Financial Services Permission5 |
| Public register | official register6 |
| Current holders | 186 |
What it lets you do, and where
What does an ADGM Virtual Asset licence let you do, and where can you serve clients?
COBS Chapter 17 Rules 17.1 to 17.2 define permitted virtual-asset activities for Authorised Persons, including operating a Multilateral Trading Facility, providing custody, managing assets and brokerage. Under FSMR Section 16, no person may carry on a Regulated Activity by way of business in ADGM without authorisation; this prohibition does not limit service territory. FSRA Guidance (VER07.100625) prohibits privacy tokens and algorithmic stablecoins across all regulated activities.415
Activities it covers
| Virtual asset exchange (FATF) | Exchanging virtual assets for fiat currency or for other virtual assets as a business, as defined in the FATF glossary. |
|---|---|
| Virtual asset transfer (FATF) | Conducting transactions that move virtual assets between addresses or accounts on behalf of another person. |
| Virtual asset safekeeping (FATF) | Safekeeping or administering virtual assets, or instruments enabling control over them, for another person. |
Where it is valid
Do you need it, and is Abu Dhabi Global Market (ADGM) the right choice?
What is an ADGM Financial Services Permission with Virtual Asset Activities Endorsement and do you actually need one?
An ADGM Financial Services Permission with Virtual Asset Activities Endorsement is the authorisation needed to carry on virtual-asset activities in ADGM. FSMR s.5A empowers the Regulator to prescribe rules for Authorised Persons carrying on Regulated Activities in Virtual Assets. FSRA Guidance (VER07.100625) sets out the FSRA's approach to VA Regulated Activities and the Financial Services Permission (or Recognition Order stipulation) needed to carry them on. COBS 17 sets additional rules for virtual-asset activities; COBS 17.2.1 bars activity in non-Accepted Virtual Assets.16417
Is an ADGM Virtual Asset licence right for your model, and what are the alternatives? When is ADGM the wrong choice?
ADGM suits institutional market infrastructure such as MTFs and custody, while VARA serves retail and DIFC serves wealth management, per Ocorian comparative analysis. FSRA's digital asset framework states capital formation activities are not provided for under the Virtual Asset Framework and are not envisaged under the Market Rulebook.184
VARA, ADGM or DIFC, which UAE regulator is right for your crypto business?
ADGM (FSRA) has the widest framework for institutional products (custody, derivatives, lending, advisory), so institutional trading, custody and structured-product firms may benefit from ADGM or DIFC. VARA (mainland Dubai) targets high-volume, retail-focused platforms (retail exchanges, NFT/metaverse, consumer DeFi), and its model is still developing. DIFC (DFSA) stays cautious on established assets and is strong for private capital and family offices. Updated Crypto Token rules apply from 12 January 2026, with firms self-assessing token suitability as DFSA no longer prescribes Recognised Crypto Tokens.1819
Do you need a separate commercial licence alongside an FSRA Virtual Asset permission, and a CBUAE licence for stablecoins?
A CBUAE licence is required for Payment Token Services in the UAE under the CBUAE Payment Token Services Regulation (C 2/2024, effective 31 August 2024). It covers ordinary free zones but excludes Financial Free Zones (ADGM, DIFC). ADGM Commercial Licensing Regulations Section 1 sets the general prohibition requiring any person carrying on controlled activities to be a licensed person.2021
Do proprietary crypto traders in ADGM need an FSRA licence or is a NOC sufficient?
ADGM FSMR 2015 Schedule 1 Part 2 provides an exclusion from Dealing in Investments as Principal: no dealing as principal in Securities, Virtual Assets or Spot Commodities absent holding out, market-making or public solicitation. In Dubai, VARA fee regulations establish that proprietary traders require a No-Objection Certificate with an annual NOC fee of AED 1,000.2223
What do UAE and ADGM marketing rules prohibit for virtual assets, even for foreign firms?
COBS 3.2.1 requires communications on Specified Investments and Regulated Activities to be clear, fair and not misleading. VARA Marketing Regulations (effective 1 October 2024) apply to all firms marketing virtual assets in or targeting UAE consumers, with fines up to AED 10 million.2425
What it really takes
How much capital do you really need for an ADGM Virtual Asset licence?
For a Virtual Asset Custodian, capital is the higher of a $250,000 Base Capital Requirement or an EBCM of six months' Annual Audited Expenditure (FSRA Guidance VER07.100625, para 37). Recognised Investment Exchanges must hold 6 months' operational expenses plus up to a 6-month buffer (ADGM MIR Rule 3.2.1). Regulatory capital must be held by an Authorised Person in fiat form (FSRA Guidance, para 39).426
Who do you have to hire in ADGM, and where must they be based?
Under GEN Rule 5.5, licensees must appoint Approved Persons for four Controlled Functions: Senior Executive Officer, Finance Officer, Compliance Officer and MLRO. Under GEN Rule 5.5.2, Approved Persons for the Senior Executive Officer, Compliance Officer and MLRO roles must be resident in the UAE.1227
Requirements
| Requirement | What is needed | Legal reference |
|---|---|---|
| Capital and people assessed | ||
| Minimum capital | USD 250,0004 | |
| Ongoing own funds | Ongoing capital resources must at all times equal or exceed the calculated Capital Requirement, held in fiat form. For Virtual Asset Custodians, ongoing capital is the higher of the USD 250,000 Base Capital Requirement or the Expenditure Based Capital Minimum of 6 months' Annual Audited Expenditure. For MTF operators, capital must cover 6 to 12 months of operational expenses calculated under IFRS.4 | |
| Who is assessed | The FSRA assesses the fitness and propriety of the Board of Directors, ultimate beneficial owners (UBOs) and Controllers holding 10% or more of voting rights or capital (or exercising significant influence), and all Approved Persons performing designated Controlled Functions under GEN 5.5 (Senior Executive Officer, Licensed Directors, Finance Officer, Compliance Officer, and MLRO). Candidates must demonstrate relevant professional experience, integrity, financial soundness, and clean regulatory and criminal records.7 | GEN 5.5 |
| Substance and people | ||
| Mind and management in ADGM | An Authorised Person conducting Virtual Asset activities must maintain its registered office, physical operational presence, and place of effective management within ADGM (Al Maryah or Al Reem Island). The FSRA requires 'mind and management' to be located in ADGM with substantive resources committed across commercial, operational, compliance, IT, and HR functions.4 | |
| Mandatory resident Approved Persons (SEO and MLRO) | The licensee must appoint mandatory Approved Persons who pass fit-and-proper vetting under GEN 5.5, including a Senior Executive Officer (SEO), Compliance Officer, and Money Laundering Reporting Officer (MLRO). The SEO and MLRO must have sufficient seniority, independence, and normally reside in the UAE.4 | GEN 5.5 |
| Segregation of client virtual assets and safeguarding | Client virtual assets and fiat funds must be held in segregated client accounts and designated on-chain wallet addresses, strictly separated from proprietary assets, with 100% reserve backing. Commingling or using client assets for proprietary trading is prohibited. Custodians must conduct weekly reconciliations and send monthly statements to retail clients under COBS 17.8.4 | |
| Technology governance and cryptographic key architecture | Licensees must establish robust technology governance under GEN 3.3 and COBS 17.5, eliminating single points of failure. Systems must feature cryptographic hardware security modules (HSMs), multi-signature or MPC key management, layered firewall security, encryption at rest and in transit, and business continuity and disaster recovery plans.4 | GEN 3.3 |
| Annual third-party IT and cyber security audit | Authorised Persons operating MTFs or providing Virtual Asset custody must undergo an annual third-party verification and audit of their core technology infrastructure, wallet security, smart contracts, and proof of reserve holdings conducted by reputable cyber security specialists.4 | |
| Independent financial audit | The licensee must appoint an external registered auditor approved by the ADGM Registration Authority to conduct an annual statutory audit of its financial statements and regulatory returns, ensuring ongoing compliance with PRU capital rules.4 | |
| Conditions to keep the licence | ||
| Accepted Virtual Assets (AVA) mandate | Licensees may only conduct regulated activities in relation to Accepted Virtual Assets (AVAs) that meet FSRA assessment criteria regarding market capitalization, liquidity, governance, blockchain traceability, and security, or receive specific FSRA approval. Privacy tokens and algorithmic stablecoins are strictly prohibited.4 | |
| FATF Travel Rule compliance | Licensees must comply with Chapter 10 of the AML Rulebook, obtaining, verifying, and immediately transmitting originator and beneficiary information for all qualifying virtual asset transfers between VASPs or financial institutions.3 | |
| Strict prohibition on commingling and lending client assets | Client virtual assets must be segregated from proprietary assets at all times with 100% reserve backing. Licensees are prohibited from lending, re-hypothecating, or staking client virtual assets for their own account without explicit client consent and appropriate regulatory permissions.4 | |
| Pre-operational launch testing | Following In-Principle Approval (IPA), the applicant cannot launch commercial operations until it successfully completes operational launch testing to the FSRA's satisfaction, including stress testing wallet connectivity and third-party IT verification.4 | |
| Ongoing prudential reporting and incident notification | Licensees must submit regular prudential returns, capital calculations, client asset reports, and audited annual financials, and must immediately notify the FSRA under GEN 8.2 and COBS 17.5 of any material system outages, cyber attacks, or security breaches.4 | GEN 8.2 |
The legal framework
| Level | Document | What it does here |
|---|---|---|
| Act | Financial Services and Markets Regulations 2015 | Primary financial services legislation of ADGM establishing the general prohibition (s. 16), s. 5A virtual asset regulation powers, FSP licensing and endorsement framework (ss. 27-31, 40-41), change of control (s. 105), statutory warning and decision notices (ss. 246-249), and the Appeals Panel (ss. 224-226) |
| Act | Federal Law No. (8) of 2004 Regarding Financial Free Zones in the United Arab Emirates | Federal constitutional statute exempting financial free zones from federal civil and commercial laws while maintaining the application of federal criminal law and AML statutes |
| Regulator rules | FSRA Conduct of Business Rulebook (COBS) | Mandatory conduct rulebook: Chapter 17 prescribes dedicated virtual asset rules, Accepted Virtual Assets criteria (COBS 17.2), capital requirements (COBS 17.3), technology governance and key management (COBS 17.5), client disclosures (COBS 17.6), MTF operations (COBS 17.7), and custody/wallet segregation (COBS 17.8-17.9) |
| Regulator rules | FSRA General Rulebook (GEN) | Core prudential and operational rulebook governing core principles, systems and controls (GEN 3), Approved Persons and Controlled Functions (GEN 5.5: SEO, MLRO, Compliance Officer), and Controller approval notifications (GEN 8.8) |
| Regulator rules | FSRA Prudential: Investment, Insurance Intermediation and Banking Rulebook (PRU) | Prudential capital framework establishing base capital requirements, capital adequacy ratios, 6-12 month expenditure-based capital buffers, and the strict requirement to hold regulatory capital in fiat currencies |
| Regulator rules | FSRA Market Infrastructure Rulebook (MIR) | Prescribes market infrastructure requirements for Multilateral Trading Facility (MTF) operators, including MIR 3.2 financial resource requirements (6 to 12 months operating expenses) incorporated by COBS 17.3.1 |
| Procedure law | Application of English Law Regulations 2015 | Applies the common law of England and rules of equity directly into ADGM legal architecture, providing contract and commercial baseline for virtual asset rights and fiduciary custody obligations |
| Procedure law | ADGM Courts, Civil Evidence, Judgments, Enforcement and Judicial Appointments Regulations 2015 | Establishes jurisdiction and procedures of the ADGM Court of First Instance and Court of Appeal, including judicial review of FSRA administrative determinations and Appeals Panel decisions |
| Fee schedule | FSRA Fees Rulebook (FEES) | Binding fee schedule prescribing virtual asset endorsement application fees ($20k standard / $125k MTF), annual supervision fees ($15k standard / $60k MTF), underlying category fees, trading levies, and controller fees |
| Forms | FSRA Authorisation Forms and Supplemental Questionnaires | Official electronic and PDF application forms: Core FSP Application Form, Approved Persons Form (AUT 01), Controller Notification Form (AUT 02), and Virtual Asset Supplemental Information Questionnaire |
5 related regimes and guidance documents
| Level | Document | What it does here |
|---|---|---|
| Guidance | FSRA Guidance: Regulation of Virtual Asset Activities in ADGM | Comprehensive supervisory guidance clarifying FSRA expectations for Virtual Asset business models, Accepted Virtual Assets determination, capital calculation, custody arrangements, and migration pathways |
| Related regime | Federal Decree-Law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations (as amended by Federal Decree-Law No. 26/2021) | Federal criminal AML/CFT statute establishing VASPs and financial institutions as reporting entities, requiring suspicious transaction reporting to the UAE FIU via goAML and criminalising money laundering |
| Related regime | Federal Decree-Law No. (6) of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business | Federal banking and monetary statute setting the exclusive jurisdiction of the Central Bank of the UAE (CBUAE) over payment tokens, stablecoins, UAE-CBDC, and Dirham-backed stored value facilities |
| Related regime | FSRA Anti-Money Laundering and Sanctions Rulebook (AML) | Binding AML/CFT/sanctions rulebook for ADGM Authorised Persons: Chapter 10 sets specific electronic transfer and FATF Travel Rule obligations for virtual asset transactions and wallet verification; Chapter 12 sets MLRO duties |
| Regional rules | Abu Dhabi Law No. (4) of 2013 Concerning the Abu Dhabi Global Market | Founding emirate legislation establishing ADGM as a financial free zone, constituting the FSRA and ADGM Courts, and providing for direct application of English common law |
The procedure under the law
| Step | What the law says | Legal reference |
|---|---|---|
| How to file | None of the governing texts held for this licence (Financial Services and Markets Regulations 2015; Financial Services and Markets Regulations 2015; FSRA Anti-Money Laundering and Sanctions Rulebook; Regulatory Law 2004; Regulatory Law 2004; Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai; Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai; Virtual Assets and Related Activities Regulations 2023; Virtual Assets and Related Activities Regulations 2023; Federal Decree-Law No. (6) of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business; Federal Decree-Law No. (6) of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business; FSRA Fund Rulebook (FUNDS); FSRA Fund Rulebook (FUNDS); Prudential: Investment, Insurance Intermediation and Banking Rulebook (PRU); Prudential: Investment, Insurance Intermediation and Banking Rulebook (PRU); Cabinet Decision No. 111/2022 on the Regulation of Virtual Assets and Their Service Providers; Cabinet Decision No. 111/2022 on the Regulation of Virtual Assets and Their Service Providers; Cabinet Decision No. 112/2022 on Delegating Certain Competencies related to the Regulation of Virtual Assets; Cabinet Decision No. 112/2022 on Delegating Certain Competencies related to the Regulation of Virtual Assets; Payment Token Services Regulation; Payment Token Services Regulation; Retail Payment Services and Card Schemes Regulation; DFSA Rulebook: Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Module (AML); DFSA Rulebook: Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Module (AML); Collective Investment Law 2010; Collective Investment Law 2010; Investment Trust Law 2006; Investment Trust Law 2006; Prudential: Investment, Insurance Intermediation and Banking Module (PIB); Prudential: Investment, Insurance Intermediation and Banking Module (PIB); Markets in Crypto-Assets Act (AP.647)) contains a provision on the channel (portal, e-mail or paper) through which the application is submitted.8 | FSMR 2015 Section 40(4)(b) & Section 40(7); FSRA General Application Process Direction |
| Language | None of the governing texts held for this licence (Financial Services and Markets Regulations 2015; Financial Services and Markets Regulations 2015; FSRA Anti-Money Laundering and Sanctions Rulebook; Regulatory Law 2004; Regulatory Law 2004; Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai; Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai; Virtual Assets and Related Activities Regulations 2023; Virtual Assets and Related Activities Regulations 2023; Federal Decree-Law No. (6) of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business; Federal Decree-Law No. (6) of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business; FSRA Fund Rulebook (FUNDS); FSRA Fund Rulebook (FUNDS); Prudential: Investment, Insurance Intermediation and Banking Rulebook (PRU); Prudential: Investment, Insurance Intermediation and Banking Rulebook (PRU); Cabinet Decision No. 111/2022 on the Regulation of Virtual Assets and Their Service Providers; Cabinet Decision No. 111/2022 on the Regulation of Virtual Assets and Their Service Providers; Cabinet Decision No. 112/2022 on Delegating Certain Competencies related to the Regulation of Virtual Assets; Cabinet Decision No. 112/2022 on Delegating Certain Competencies related to the Regulation of Virtual Assets; Payment Token Services Regulation; Payment Token Services Regulation; Retail Payment Services and Card Schemes Regulation; DFSA Rulebook: Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Module (AML); DFSA Rulebook: Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Module (AML); Collective Investment Law 2010; Collective Investment Law 2010; Investment Trust Law 2006; Investment Trust Law 2006; Prudential: Investment, Insurance Intermediation and Banking Module (PIB); Prudential: Investment, Insurance Intermediation and Banking Module (PIB); Markets in Crypto-Assets Act (AP.647)) contains a provision on the language in which the application must be filed. | |
| What the application contains | Under FSMR 2015, an application for a Financial Services Permission must be made in accordance with the applicable Regulator Rules and contain any other information the Regulator reasonably requires.910 | FSMR 2015 Section 40(1)-(4); FSRA General Rulebook (GEN) Rule 5.2 and Section 8.8; FSRA Guidance - Authorisation of Financial Services Firms; COBS Chapter 17 |
| Decision clock | The review is iterative, with follow-up queries and interviews with Approved Persons, and leads to in-principle approval with pre-conditions before a Financial Services Permission is granted.8 | |
| Fees set by law | The FSRA Guidance example (para 176) shows fees in USD thousands: application: Dealing in Investments as unmatched Principal (FEES 3.4.1) 40, Arranging Deals in Investments (3.8.1(c)+3.2.1) 10, plus a single Virtual Assets add-on (3.17.1(a)) 20; supervision: 50, 10 and add-on (3.17.2(a)) 15, prorated in the first year. MTFs using Virtual Assets also pay a monthly sliding-scale trading levy (FEES 3.18). FSRA may add or waive fees (FEES 1.2.4).114 | FSRA Fees Rulebook (FEES) [VER20.010126], Rules 3.2, 3.17.1, 3.17.2, 3.18, and Chapter 6; charging power under FSMR 2015 Section 7(2)(n) and Section 8 |
| Grounds for refusal | Under the GEN Rulebook's "Consideration and assessment of applications", an applicant must satisfy the Regulator that it has adequate and appropriate resources, including financial resources (assessed under PRU, COBS and PIN), is fit and proper, is capable of being effectively supervised, and has adequate compliance arrangements. These requirements summarise the "Threshold Condition Rules" for sections 7(2) and 28 of FSMR.12 | |
| Appeal | Yes. Under the Financial Services and Markets Regulations 2015 the matter is heard by the ADGM Appeals Panel on a full merits review, decided on the balance of probabilities. Its decision may then be judicially reviewed by the ADGM Court of First Instance where it is wrong in law or exceeds the Panel's jurisdiction.1310 | FSMR 2015 Part 19, Chapter 1, Section 224 and Section 225(1)-(2); before refusing an application or imposing unagreed conditions, the FSRA must issue a Warning Notice under Section 246(1)(c) and Section 247 giving a reasonable period (not less than 14 days) to make representations. If confirmed, a Decision Notice is issued under Section 248 and Section 249(1)(e). Under Section 225(2)(a), a reference to the Appeals Panel for a full merits review must be commenced within 30 days of the date of the Decision Notice (extendable by up to 30 days under s. 225(2)(b)). The Appeals Panel may confirm, vary, or remit the decision to the FSRA. Decisions of the Appeals Panel may be challenged via judicial review before the ADGM Court of First Instance on points of law under the ADGM Court Regulations 2015. |
| Validity | None of the governing texts held for this licence (Financial Services and Markets Regulations 2015; Financial Services and Markets Regulations 2015; FSRA Anti-Money Laundering and Sanctions Rulebook; Regulatory Law 2004; Regulatory Law 2004; Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai; Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai; Virtual Assets and Related Activities Regulations 2023; Virtual Assets and Related Activities Regulations 2023; Federal Decree-Law No. (6) of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business; Federal Decree-Law No. (6) of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business; FSRA Fund Rulebook (FUNDS); FSRA Fund Rulebook (FUNDS); Prudential: Investment, Insurance Intermediation and Banking Rulebook (PRU); Prudential: Investment, Insurance Intermediation and Banking Rulebook (PRU); Cabinet Decision No. 111/2022 on the Regulation of Virtual Assets and Their Service Providers; Cabinet Decision No. 111/2022 on the Regulation of Virtual Assets and Their Service Providers; Cabinet Decision No. 112/2022 on Delegating Certain Competencies related to the Regulation of Virtual Assets; Cabinet Decision No. 112/2022 on Delegating Certain Competencies related to the Regulation of Virtual Assets; Payment Token Services Regulation; Payment Token Services Regulation; Retail Payment Services and Card Schemes Regulation; DFSA Rulebook: Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Module (AML); DFSA Rulebook: Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Module (AML); Collective Investment Law 2010; Collective Investment Law 2010; Investment Trust Law 2006; Investment Trust Law 2006; Prudential: Investment, Insurance Intermediation and Banking Module (PIB); Prudential: Investment, Insurance Intermediation and Banking Module (PIB); Markets in Crypto-Assets Act (AP.647)) contains a provision on a fixed term or expiry of the licence. | |
| Change of control | Prior approval is required for a proposed acquisition or increase in control in an Authorised Person. The Regulator must decide as soon as practicable and within 90 days of receiving a duly completed application, unless it notifies a different period in writing. An approval, including a conditional one, is valid for one year from the date of approval unless extended in writing. If objecting or imposing conditions, the Regulator must act within the same 90 days and allow 14 days for representations.1412 | |
| Reapplying after a refusal | None of the governing texts held for this licence (Financial Services and Markets Regulations 2015; Financial Services and Markets Regulations 2015; FSRA Anti-Money Laundering and Sanctions Rulebook; Regulatory Law 2004; Regulatory Law 2004; Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai; Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai; Virtual Assets and Related Activities Regulations 2023; Virtual Assets and Related Activities Regulations 2023; Federal Decree-Law No. (6) of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business; Federal Decree-Law No. (6) of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business; FSRA Fund Rulebook (FUNDS); FSRA Fund Rulebook (FUNDS); Prudential: Investment, Insurance Intermediation and Banking Rulebook (PRU); Prudential: Investment, Insurance Intermediation and Banking Rulebook (PRU); Cabinet Decision No. 111/2022 on the Regulation of Virtual Assets and Their Service Providers; Cabinet Decision No. 111/2022 on the Regulation of Virtual Assets and Their Service Providers; Cabinet Decision No. 112/2022 on Delegating Certain Competencies related to the Regulation of Virtual Assets; Cabinet Decision No. 112/2022 on Delegating Certain Competencies related to the Regulation of Virtual Assets; Payment Token Services Regulation; Payment Token Services Regulation; Retail Payment Services and Card Schemes Regulation; DFSA Rulebook: Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Module (AML); DFSA Rulebook: Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Module (AML); Collective Investment Law 2010; Collective Investment Law 2010; Investment Trust Law 2006; Investment Trust Law 2006; Prudential: Investment, Insurance Intermediation and Banking Module (PIB); Prudential: Investment, Insurance Intermediation and Banking Module (PIB); Markets in Crypto-Assets Act (AP.647)) contains a provision on a waiting period before a new application after refusal or withdrawal. |
How long it takes
How long does an ADGM Virtual Asset licence really take?
The FSRA General Application Process runs from initial Contact and Submission through In-Principle Approval (IPA), Fulfillment, and Financial Services Permission. Practitioner advisory indicates FSRA review takes 3 to 6+ months, with complex models such as exchanges and custody businesses usually taking longer.828
For change-of-control approvals, ADGM General Rulebook (GEN) Rule 8.8.6 requires the FSRA to approve as soon as practicable and within 90 days of a duly completed application, unless a different period is notified in writing. ADGM FSMR 2015 sections 40 and 41 govern determination of Financial Services Permission applications and set no time limit; the Regulator may require further information before determining the application.142
What it costs
What does an ADGM Virtual Asset licence cost in total?
FSRA FEES Rule 3.17.1(a) sets a USD 20,000 application add-on fee and Rule 3.17.2(a) a USD 15,000 annual supervision add-on fee for Virtual Asset Activities (FSRA Guidance VER07.100625). These apply on top of the application and supervision fees for the underlying Regulated Activities.4
Approval odds and who can own it
What are the real approval odds for an ADGM Virtual Asset licence, and why do applications fail?
The FSRA 2025 Annual Report records 95 Financial Services Permissions (+22% vs 2024) and 120 In-Principle Approvals (+32%). The FSRA Enforcement Notice of 14 April 2025 fined HAYVN Group USD 8.85 million and indefinitely banned its CEO for unauthorised virtual-asset activities and false records.2930
Who can own and run an ADGM Virtual Asset company?
FSMR s.105 empowers the Regulator to make Rules on Controllers and to approve or object to Controllers. ADGM GEN Rule 8.8.6 sets a 90-day determination clock for prior approval of acquisitions or increases in control crossing specified thresholds.3114
After you get the licence
What else will you need alongside an ADGM Virtual Asset licence?
ADGM Companies Regulations 2020 Section 5 governs forming and registering a company with the Registrar. ADGM Data Protection Regulations 2021 require all registered entities processing personal data to register as a Data Controller with the Office of Data Protection. The CBUAE Payment Token Services Regulation (effective August 2024) mandates separate federal licensing for Dirham payment-token issuance and conversion.323321
Will you get a bank account and payment processing with an ADGM Virtual Asset licence?
Banks apply enhanced due diligence to crypto businesses automatically, which Cryptoverse Lawyers describe as a hidden bottleneck for UAE firms. The ADGM Public Register confirms AMINA Bank AG holds an active Financial Services Permission (FSP 210043) operating as a branch in ADGM. COBS 17.9.1 modifies Client Money reconciliations for VA firms: weekly (14.11.1) and within five days (14.11.4).343536
What does it take to keep an ADGM Virtual Asset licence, and what is changing?
COBS Rule 17.8 mandates weekly reconciliations of client virtual-asset holdings and monthly client account statements. The FSRA finalised the regulatory framework for staking of Virtual Assets on 29 April 2026 following Consultation Paper No. 10 of 2025. UAE Cabinet Resolution No. 41 of 2023 expanded ADGM jurisdiction to Al Reem Island with transitional arrangements for existing businesses.37438
Yes. ADGM FSMR 2015 Section 224 and Part 19 establish the independent Appeals Panel to conduct full merits reviews of FSRA regulatory decisions. The 30-day appeal deadline (from the relevant FSRA decision, extendable by up to 30 days) is in paragraph 20(a) of the ADGM Appeals Panel Practice and Procedures, mirroring FSMR s.225(2). Appeals Panel decisions may be referred to the ADGM Court of First Instance, which may review them and correct mistakes of law (ADGM Courts Regulations 2015).10
FSMR 2015 sets no expiry for a Financial Services Permission; under Section 33 the FSRA may vary or cancel it if the firm has not carried on a Regulated Activity for at least 12 months. Prior written FSRA approval is required to become a Controller (10%+) or cross 20%, 30% or 50% (GEN Rule 8.8.4), and Controlled Functions are subject to FSRA approval (GEN Rule 5.3.1; Rule 5.5 covers mandatory appointments).212
Buying a company that already holds it
The Financial Services Permission is granted to the specific ADGM corporate entity and is non-transferable and non-assignable to any other entity. Commercial transfer of the regulated business can only be effected through a share purchase of the licensed company, subject to prior FSRA change-of-control approval under FSMR section 105 and GEN 8.8. An asset sale or business transfer requires the acquiring entity to hold its own FSP or undergo an FSMR Part 7 transfer scheme.7
Prior approval required. Under FSMR section 105 and GEN 8.8, prior written approval from the FSRA is required before a person becomes a controller or increases control across 20%, 30%, or 50% thresholds. A controller is defined as holding 10% or more of voting rights or capital, or exercising significant influence. The statutory determination period is 90 days from receipt of a complete notice, accompanied by a USD 1,000 application fee.7
Ready-made companies holding this licence: see verified positions.
VASP in other countries
| Country | Licence | Regulator | Min. capital | Application fee | Statutory time |
|---|---|---|---|---|---|
| Abu Dhabi Global Market (ADGM) | VASP licenceFinancial Services Permission with Virtual Asset Activities Endorsement | FSRA | USD 250,000 | USD 20,000 | n/a |
| Australia | VASP licenceRegistration as a virtual asset service provider (VASP) on the AUSTRAC Virtual Asset Service Provider Register (formerly the Digital Currency Exchange Register) | AUSTRAC | n/a | n/a | n/a |
| Bermuda | Digital Asset Business Class F (Full) Licence | BMA | n/a | n/a | n/a |
| Bermuda | Digital Asset Business Class M (Modified) Licence | BMA | n/a | n/a | n/a |
| Bermuda | Digital Asset Business Class T (Test) Licence | BMA | n/a | n/a | n/a |
| British Virgin Islands | Virtual Assets Service Provider Registration | BVI FSC | n/a | n/a | n/a |
| Cayman Islands | Virtual Asset Service Provider Licence | CIMA | n/a | KYD 5,000 | n/a |
| Cayman Islands | Virtual Asset Service Provider Registration | CIMA | n/a | KYD 1,000 | n/a |
| Dubai (VARA) | Virtual Asset Advisory Services Licence | VARA | AED 100,000 | AED 40,000 | n/a |
| Dubai (VARA) | Virtual Asset Broker-Dealer Services Licence | VARA | AED 600,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Custody Services Licence | VARA | AED 600,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Exchange Services Licence | VARA | AED 1,500,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Lending and Borrowing Services Licence | VARA | AED 500,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Management and Investment Services Licence | VARA | AED 500,000 | AED 100,000 | n/a |
| Dubai (VARA) | Virtual Asset Transfer and Settlement Services Licence | VARA | AED 500,000 | AED 40,000 | n/a |
| Dubai International Financial Centre (DIFC) | Financial Services Permission with Crypto Token Activities Endorsement | DFSA | USD 1,000,000 | USD 15,000 | n/a |
| El Salvador | Proveedor de Servicios de Activos Digitales (PSAD) registration | CNAD | USD 2,000 | USD 5,475 | ~0.9 mo |
| Germany | Qualified crypto custody licence | BaFin | n/a | n/a | n/a |
| Ireland | Virtual Asset Service Provider AML/CFT Registration | CBI | n/a | n/a | n/a |
| Mauritius | Virtual Asset Advisory Services (Class I) | FSC | n/a | n/a | n/a |
| Mauritius | Virtual Asset Broker-Dealer (Class M) | FSC | n/a | MUR 2,000,000 | n/a |
| Mauritius | Virtual Asset Wallet Services (Class O) | FSC | n/a | n/a | n/a |
| Mauritius | Virtual Asset Custodian (Class R) | FSC | n/a | MUR 5,000,000 | n/a |
| Mauritius | Virtual Asset Market Place (Class S) | FSC | n/a | MUR 6,500,000 | n/a |
| Seychelles | Virtual Asset Service Provider Licence / RegistrationVirtual Asset Service Provider Licence / Registration (Wallet Provider, Exchange, Broking, Investment Provider) under the Virtual Asset Service Providers Act 2024 | FSA | n/a | SCR 75,000 | n/a |
| South Africa | Crypto Asset Service Provider licenceCrypto Asset Service Provider licence (an FSP authorisation category under FAIS, not a MiCA-equivalent regime) | FSCA | n/a | n/a | n/a |
| Switzerland | Financial intermediary / VASP SRO affiliation | FINMA | CHF 10,000,000 | CHF 1,600 | n/a |
| United Kingdom | Cryptoasset Business Registration (MLRs 2017) | FCA | n/a | GBP 11,260 | ~3 mo |
Values come from each licence's page, where every figure has its source.
Laws behind it
- Financial Services and Markets Regulations 2015: Financial Services and Markets Regulations 2015
Getting this licence
Protegra handles this licence end to end: crypto licensing in ADGM: process, timeline and our fee.
Frequently asked questions
What is an ADGM Financial Services Permission with Virtual Asset Activities Endorsement and do you actually need one?
An ADGM Financial Services Permission with Virtual Asset Activities Endorsement is the authorisation needed to carry on virtual-asset activities in ADGM.
How much capital do you really need for an ADGM Virtual Asset licence?
For a Virtual Asset Custodian, capital is the higher of a $250,000 Base Capital Requirement or an EBCM of six months' Annual Audited Expenditure (FSRA Guidance VER07.100625, para 37).
How long does an ADGM Virtual Asset licence really take?
The FSRA General Application Process runs from initial Contact and Submission through In-Principle Approval (IPA), Fulfillment, and Financial Services Permission.
What does an ADGM Virtual Asset licence cost in total?
FSRA FEES Rule 3.17.1(a) sets a USD 20,000 application add-on fee and Rule 3.17.2(a) a USD 15,000 annual supervision add-on fee for Virtual Asset Activities (FSRA Guidance VER07.100625).
What are the real approval odds for an ADGM Virtual Asset licence, and why do applications fail?
The FSRA 2025 Annual Report records 95 Financial Services Permissions (+22% vs 2024) and 120 In-Principle Approvals (+32%).
What does an ADGM Virtual Asset licence let you do, and where can you serve clients?
COBS Chapter 17 Rules 17.1 to 17.2 define permitted virtual-asset activities for Authorised Persons, including operating a Multilateral Trading Facility, providing custody, managing assets and brokerage.
Will you get a bank account and payment processing with an ADGM Virtual Asset licence?
Banks apply enhanced due diligence to crypto businesses automatically, which Cryptoverse Lawyers describe as a hidden bottleneck for UAE firms.
Who do you have to hire in ADGM, and where must they be based?
Under GEN Rule 5.5, licensees must appoint Approved Persons for four Controlled Functions: Senior Executive Officer, Finance Officer, Compliance Officer and MLRO.
Is an ADGM Virtual Asset licence right for your model, and what are the alternatives? When is ADGM the wrong choice?
ADGM suits institutional market infrastructure such as MTFs and custody, while VARA serves retail and DIFC serves wealth management, per Ocorian comparative analysis.
What does it take to keep an ADGM Virtual Asset licence, and what is changing?
COBS Rule 17.8 mandates weekly reconciliations of client virtual-asset holdings and monthly client account statements.
Sources
- ADGM FSRA Rulebook: 24820 · retrieved 2026-09-24
- ADGM FSRA Rulebook: financial services and markets regulations 2015 0 · retrieved 2026-09-24
- ADGM FSRA Rulebook: anti money laundering and sanctions rulebook aml ver11210526 · retrieved 2026-09-24
- assets.adgm.com (PDF) · retrieved 2026-09-24
- ADGM FSRA Rulebook: 12521 · retrieved 2026-09-29
- adgm.com: firms · retrieved 2026-09-24
- ADGM FSRA Rulebook: 7993 · retrieved 2026-09-24
- adgm.com: fsra general application process · retrieved 2026-10-01
- adgm.com: how to apply and FSMR 2015 Section 40 · retrieved 2026-10-01
- Financial Services and Markets Regulations 2015 · retrieved 2026-10-01
- ADGM FSRA Rulebook: fees rules fees and FSMR 2015 ss. 7, 8 · retrieved 2026-10-01
- ADGM FSRA Rulebook: gen 551 · retrieved 2026-10-01
- assets.adgm.com (PDF) · retrieved 2026-10-01
- ADGM FSRA Rulebook: gen 886 · retrieved 2026-10-01
- ADGM FSRA Rulebook: cobs 1711 · retrieved 2020-02-24
- ADGM FSRA Rulebook: 5a authorised persons carrying regulated activity relation v · retrieved 2015-11-01
- ADGM FSRA Rulebook: cobs 1721 · retrieved 2020-02-24
- ocorian.com: scaling digital asset businesses uae balanced guide adgm dif · secondary · retrieved 2024-05-15
- dfsa.ae: dfsa issues updated rules regulation crypto tokens difc · secondary · retrieved
- ADGM FSRA Rulebook: 1 general prohibition 2 · retrieved 2015-11-01
- rulebook.centralbank.ae: 45 · retrieved 2024-08-31
- ADGM FSRA Rulebook: 5 absence holding out etc · retrieved 2015-11-01
- vara.ae: vara publishes clarification and further information on fees · retrieved 2023-06-22
- ADGM FSRA Rulebook: cobs 321 · retrieved 2020-02-03
- techinsights.linklaters.com · secondary · retrieved 2024-10-05
- ADGM FSRA Rulebook: mir 321 · retrieved 2015-11-01
- ADGM FSRA Rulebook: gen 552 · retrieved 2023-12-18
- cryptoverselawyers.io: the complete guide to obtaining an adgm crypto licence · secondary · retrieved 2026-07-16
- adgm.com: adgm fsra publishes its 2025 annual report · secondary · retrieved 2026-07-13
- adgm.com: adgms fsra imposes fines of USD 8 85 million on hayvn · retrieved 2025-04-14
- ADGM FSRA Rulebook: 105 provisions governing controllers · retrieved 2015-11-01
- ADGM FSRA Rulebook: 5 method forming company 0 · retrieved 2020-02-23
- adgm.com: office of data protection · retrieved 2021-02-14
- cryptoverselawyers.io: crypto bank account uae firm rejection · secondary · retrieved 2026-09-17
- adgm.com: amina bank ag 210043 · retrieved 2022-02-07
- ADGM FSRA Rulebook: cobs 1791 · retrieved 2020-02-24
- adgm.com: adgm fsra finalises regulatory framework for the staking of · retrieved 2026-04-29
- adgm.com: adgm welcomes al reem island businesses to its community · retrieved 2023-11-01
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