Virtual Asset Exchange Services Licence (Dubai (VARA))
The Virtual Asset Exchange Services Licence in Dubai allows multilateral crypto-to-crypto and fiat-to-crypto order matching and trading platform operations under VARA oversight. Paid-up capital is AED 1,500,000 (or 25% of annual overheads), reduced to AED 800,000 when utilizing a VARA-licensed custodian. Decision timelines are discretionary without a statutory deadline. Operating requires two UAE-resident Responsible Individuals, an independent director, and an AED 100,000 application fee.
At a glance
| Official name | Virtual Asset Exchange Services Licence1 |
|---|---|
| Also known as | VARA exchange licence · Dubai crypto exchange licence · VA Exchange Services licence |
| Issued by | Virtual Assets Regulatory Authority |
| Jurisdiction | Dubai (VARA) |
| Licence family | Virtual asset service provider (non-MiCA) |
| Legal basis | Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai2 Cabinet Decision No. 111/2022 on the Regulation of Virtual Assets and Their Service Providers3 Cabinet Decision No. 112/2022 on Delegating Certain Competencies related to the Regulation of Virtual Assets4 |
| Passporting | Domestic only |
| Minimum capital | AED 1,500,000, or 25% of fixed annual overheads, whichever is higher; reduced to AED 800,000, or 15% of fixed annual overheads, whichever is higher, where the VASP uses a VARA-licensed custodian or a custody arrangement otherwise approved during the licensing process5 |
| Application fee | AED 100,0006 |
| Annual fee | AED 200,0006 |
| Statutory decision time | No fixed statutory determination deadline is prescribed by Law No. (4) of 2022 or Regulations 2023; VARA exercises discretionary review based on submission completeness.7 |
| Public register | official register8 |
| Current holders | 158 |
What it lets you do, and where
What does a Dubai VARA Exchange licence let you do, and where can you serve clients?
A VARA Exchange licence lets you operate a trading venue and settle trades within 24 hours under the Exchange Services Rulebook Part III. VASPs may not actively invest their own or their Group's portfolio, except for prudent management of Net Liquid Assets or treasury/balance-sheet purposes. Custody Services must be run by an independent legal entity separate from Group members doing other VA Activities (except VA Transfer and Settlement).303132
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. |
|---|---|
| Operating a crypto-asset trading platform | Managing a multilateral system that brings together buying and selling interests in crypto-assets so that contracts are concluded. |
Where it is valid
Do you need it, and is Dubai (VARA) the right choice?
Is a Dubai VARA Exchange licence right for your model, and when is Dubai the wrong choice?
VARA targets retail and consumer-facing crypto platforms, while ADGM focuses on institutional MTFs and DIFC operates under DFSA. Dubai may be the wrong choice if your model is institutional, or if you cannot fund two full-time Responsible Individuals who are UAE residents or passport holders under Company Rulebook Part I.C. Compliance Licensed MLRO (DIFC) monthly salaries range AED 56,000 to AED 69,000.331134
VARA, ADGM or DIFC, which UAE regulator is right for your crypto exchange?
VARA suits retail and Web3 crypto businesses, ADGM suits institutional and fund-focused firms, and DIFC operates as a DFSA financial services carve-out. Dubai Law No. (4) of 2022 Article 3 explicitly excludes DIFC from VARA's jurisdiction. DFSA Consultation Paper 168 proposed moving the DIFC crypto token regime from central recognition to a firm-led suitability model.333536
What are the VARA licence stages (ATI → MVP → FMP) and what can you do at each?
Coincub outlines four sequential VARA licensing phases: ATI, MVP Preparatory, MVP Operational and Full Market Product. Pinsent Masons notes that the FMP licence gives a firm footing for growth after the limited MVP stage. A VARA January 2026 circular sets Retail/Qualified/Institutional classification (Qualified: AED 3.5m net assets or AED 700k income).373839
Do you need a free-zone licence and a VARA licence, and a CBUAE licence for stablecoins?
Yes. Dubai requires licences to be stacked. You must first obtain a commercial trade licence from DET or a Dubai free zone (like DMCC, from AED 31,000) for corporate formation, and second, a VARA Exchange licence (AED 100,000 application fee) to operate the venue. Under the CBUAE Payment Token Regulation (effective August 2024), any firm issuing, converting, or facilitating AED-backed payment tokens also requires a federal Central Bank licence, even if already licensed by VARA.224041
No. VARA confirms that proprietary trading with your own funds requires an approval or No Objection Certificate (NOC), not a full VASP licence. Infinilex documents the NOC fee at AED 1,000 annually (as at 22 June 2023); no processing time is given. VARA proprietary trading rules set a mandatory registration threshold of $250,000,000 in volume over a rolling 30-day window.274224
What do VARA's marketing rules ban, even for foreign and unlicensed crypto firms?
VARA's 2024 Marketing Regulations prohibit unauthorised marketing of virtual asset services targeting the UAE and ban privacy coins. The rules apply to domestic and foreign entities; only VARA-licensed VASPs may market. Linklaters highlights their extraterritorial reach and maximum administrative fines of AED 10,000,000.294344
What it really takes
How much capital do you really need for a Dubai VARA Virtual Asset Exchange licence?
Under VARA Company Rulebook Rule VI.B.1, statutory paid-up capital is the higher of AED 1,500,000 or 25% of annual fixed overheads. This drops to AED 800,000 (or 15% overheads) if client custody is outsourced to an approved VARA custodian. Capital must be placed in a UAE bank trust account with VARA as beneficiary or backed by a surety bond. Licensees must constantly maintain Net Liquid Assets at no less than 1.2x monthly operating expenses, reconciled daily.59
Who do you have to hire for a Dubai VARA Exchange and where must they be based?
Hire two Responsible Individuals as full-time employees who are UAE residents or passport holders (VARA Company Rulebook Part I.C). The board must include at least one independent director and meet quarterly (Exchange Services Rulebook Part I). Appoint an MLRO with at least two years of AML/CFT experience (Compliance and Risk Management Rulebook). Compliance Licensed MLRO (DIFC) monthly salaries range AED 56,000 to AED 69,000.11121334
On language, the one point on record is that Dubai Law No. (4) of 2022, the law regulating virtual assets, was promulgated in the Official Gazette in Arabic, with English working translations.45
The VARA application documentation list, not the Company Rulebook, defines what an Exchange licence application must contain. It requires governance, risk and compliance documents and capital evidence at application. VARA's administrative application guidelines enumerate 18 mandatory document categories, including a business plan, UBO information, and financial projections. Regulations 2023 Part IV establishes the regulatory licensing procedure and authorisation conditions.2120
Requirements
| Requirement | What is needed | Legal reference |
|---|---|---|
| Capital and people assessed | ||
| Minimum capital | AED 1,500,000, or 25% of fixed annual overheads, whichever is higher; reduced to AED 800,000, or 15% of fixed annual overheads, whichever is higher, where the VASP uses a VARA-licensed custodian or a custody arrangement otherwise approved during the licensing process5 | |
| Ongoing own funds | Net Liquid Assets must be maintained at all times at no less than 1.2x monthly operating expenses, reconciled daily and reported to VARA monthly; eligible Net Liquid Assets are limited to cash and cash equivalents or virtual assets referencing USD or AED approved by VARA.9 | |
| Who is assessed | Every Board member is individually vetted and approved by VARA as Fit and Proper upon appointment and re-assessed at least annually; the Board of an Exchange VASP must include at least one independent director. Senior Management and two designated UAE-resident Responsible Individuals are vetted similarly. Controlling Entities and Ultimate Beneficial Owners must be identifiable in the chain of ownership and declared free of PEP or sanctions exposure; any entity holding 25% or more of voting rights or equivalent control is treated as a Controlling Entity.10 | |
| Substance and people | ||
| Management and people | The VASP must maintain two Responsible Individuals who are full-time employees, Fit and Proper, and either UAE residents or UAE passport holders, notified to and approved by VARA during licensing.11 | |
| Interest ban | The Board of an Exchange VASP must consist of executive and non-executive directors with at least one independent director meeting strict conflict-of-interest criteria, convening at least quarterly.12 | |
| Management and people | Every Board member must be individually assessed by the VASP and approved by VARA as a Fit and Proper Person, with the Board re-confirming each member's status at least annually.10 | |
| AML/CFT | A Money Laundering Reporting Officer with at least two years' AML/CFT experience must be appointed and confirmed Fit and Proper, reporting quarterly to the Board on AML/CFT compliance.13 | |
| ICT and DORA | A Chief Information Security Officer (CISO) must be appointed to lead technology governance, cybersecurity, and key storage compliance, operating as a distinct individual from the Compliance Officer.14 | |
| Client assets | Client Money and Client Virtual Assets must be held strictly segregated from the VASP's proprietary assets; fiat funds must be placed in a UAE bank Client Account within one calendar day, with no rehypothecation.15 | |
| Audit | The VASP must appoint an independent third-party auditor for annual financial audits and maintain an independent internal audit function reporting to senior management at least quarterly.16 | |
| Local presence | The licensee must maintain a legal entity incorporated in Dubai (mainland or free zone, excluding DIFC) holding a VARA Permit before commencing operations or securing a commercial licence.2 | |
| Conditions to keep the licence | ||
| Withdrawal | VARA may vary, suspend (for up to six months) or revoke the Licence for material regulatory breach, insolvency, an unpaid court judgment, or other good cause, alongside cancellation of the underlying commercial licence.2 | |
| Requirement | Final settlement of virtual asset transactions executed on the trading venue must be completed within twenty-four (24) hours.17 | |
| Reporting | Net Liquid Assets must be reconciled daily and reported to VARA monthly, maintained at no less than 1.2x monthly operating expenses at all times.9 | |
| Requirement | Licensed VASPs are strictly prohibited from proprietary trading on their own exchange; proprietary trading operations require a separate legal entity holding a VARA No Objection Certificate (NOC).1 | |
| Client assets | Client Money and Client Virtual Assets must be safeguarded in segregated accounts and cannot be used for the VASP's own balance sheet, liquidity, or capital ratios.15 | |
The legal framework
| Level | Document | What it does here |
|---|---|---|
| Act | Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai | Constitutive statute establishing VARA, creating the virtual asset permit requirement (Art. 15), specifying exchange services activities (Art. 16), prohibiting unapproved permit assignment (Art. 17), powers to suspend/revoke (Art. 18, 20), fee setting (Art. 19), and the 30-day statutory grievance procedure (Art. 22) |
| Secondary legislation | Cabinet Decision No. (111) of 2022 on the Regulation of Virtual Assets and Their Service Providers | Federal regulatory baseline establishing federal supervisory competencies of the Securities and Commodities Authority (SCA) over virtual assets and service providers, with powers to coordinate with local licensing authorities |
| Secondary legislation | Cabinet Decision No. (112) of 2022 on Delegating Certain Competencies related to the Regulation of Virtual Assets | Federal cabinet decision delegating licensing, supervisory, and enforcement competencies over virtual assets and VASPs operating within Dubai mainland and free zones from federal SCA to VARA |
| Regulator rules | Virtual Assets and Related Activities Regulations 2023 | Master regulatory rulebook setting licensing application procedures (Part IV), defining Exchange Services (Schedule 1), establishing the compulsory and activity rulebook framework (Part V), AML/CFT hooks (Part VI), supervisory powers (Part IX), and fee and fine schedules (Schedules 2 and 3) |
| Regulator rules | Company Rulebook (Virtual Assets Regulatory Authority) | Compulsory rulebook governing company ownership, board independence, two UAE-resident Responsible Individuals, fit and proper standards, outsourcing, paid-up capital (AED 1,500,000, or AED 800,000 with approved custodian), Net Liquid Assets (1.2x monthly operating expenses), wind-down, and 30-working-day change-of-control prior approval (Part VIII) |
| Regulator rules | Compliance and Risk Management Rulebook (Virtual Assets Regulatory Authority) | Compulsory rulebook mandating AML/CFT compliance function, MLRO appointment with at least two years experience, risk management framework, CDD, and ongoing fit-and-proper monitoring |
| Regulator rules | Technology and Information Rulebook (Virtual Assets Regulatory Authority) | Compulsory rulebook setting IT governance, cybersecurity controls, separate CISO appointment, wallet and cryptographic key storage architecture, business continuity, and incident reporting |
| Regulator rules | Market Conduct Rulebook (Virtual Assets Regulatory Authority) | Compulsory rulebook establishing business conduct principles, fair treatment of clients, prevention and detection of market manipulation and insider dealing, and conflict-of-interest management |
| Regulator rules | Exchange Services Rulebook (Virtual Assets Regulatory Authority) | Activity-specific rulebook for Virtual Asset Exchange Services: mandates Board independence (minimum one independent director), participant codes of conduct, market surveillance and VARA notifications, 24-hour final settlement rule, margin trading, and exchange-traded derivative (ETD) services rules |
| Regulator rules | Regulations on the Marketing of Virtual Assets and Related Activities 2024 | Binding regulatory framework governing marketing, advertising, and promotional communications relating to virtual assets and exchange services targeting Dubai residents |
| Procedure law | Law No. (13) of 2016 Concerning the Judicial Authority in the Emirate of Dubai | Governs judicial review and administrative law appeals before the Dubai Courts (Court of First Instance - Administrative Circuit) following exhaustion of the statutory grievance procedure under Law No. (4) of 2022 Article 22 |
| Fee schedule | Schedule 2: Supervision and Authorisation Fees to the Virtual Assets and Related Activities Regulations 2023 | Statutory fee schedule establishing the AED 100,000 application fee, AED 200,000 extension fee, and AED 200,000 annual supervision fee for Virtual Asset Exchange Services |
| Fee schedule | Schedule 3: Fines to the Virtual Assets and Related Activities Regulations 2023 | Prescribes administrative fines and penalties for regulatory breaches, AML violations, and market offences (up to AED 50,000,000, 15% revenue, or 300% profits gained/losses avoided for corporates) |
| Forms | Standard Initial Disclosure Questionnaire (IDQ) and VASP Application Dossier Forms | Mandatory administrative electronic questionnaire and application forms specifying the 18 documentary exhibits required for VASP licence determination |
5 related regimes and guidance documents
| Level | Document | What it does here |
|---|---|---|
| Guidance | VARA Guidelines and Process Guides on VASP Licensing (Initial Disclosure Questionnaire and Stage 2 Application Guide) | Regulator guidance detailing the two-stage licensing process (Stage 1 IDQ / ATI through DET or Free Zones; Stage 2 full VASP application dossier) and administrative evaluation criteria |
| 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; successor Federal Decree-Law No. 10/2025) | Core UAE federal AML/CFT statute establishing VASPs as reporting entities, criminalising money laundering, and mandating suspicious transaction reporting to the UAE FIU |
| Related regime | Cabinet Resolution No. (10) of 2019 Issuing the Executive Regulations of Federal Decree-Law No. (20) of 2018 (as amended / Cabinet Resolution No. (134) of 2025) | Sets federal implementing AML/CFT standards for customer due diligence (CDD), ultimate beneficial ownership identification, suspicious transaction reporting, record retention, and FATF Travel Rule compliance |
| Related regime | Cabinet Decision No. (74) of 2020 Regarding Terrorism Lists Regulation and Implementation of UN Security Council Resolutions on the Suppression and Combating of Terrorism | Mandates real-time screening and immediate asset freezing against UAE local terrorist lists and UN Security Council sanctions lists |
| 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 jurisdiction of the Central Bank of the UAE (CBUAE) over payment tokens, stablecoins, CBDC (UAE-CBDC), and stored value facilities, carved out from VARA jurisdiction under Regulation III.A.4 |
The procedure under the law
| Step | What the law says | Legal reference |
|---|---|---|
| How to file | Application submissions for a VASP Licence are made through Dubai Economy and Tourism (DET) for mainland firms, or through any Dubai Free Zone in Dubai (excluding DIFC). The process has two stages: first an Approval to Incorporate (ATI) to establish the legal entity, then the VASP Licence application. For Stage 1, an Initial Disclosure Questionnaire (IDQ) is submitted to DET or a relevant Free Zone. Part IV of the Virtual Assets and Related Activities Regulations 2023 governs licensing.192021 | Dubai Law No. (4) of 2022 Art. 15(a)-(c); Virtual Assets and Related Activities Regulations 2023, Regulation IV.A.2 (empowering VARA to prescribe the licensing process) and Regulation IV.B.1 |
| Language | None of the governing texts held for this licence (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; 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; Virtual Assets and Related Activities Regulations 2023; Virtual Assets and Related Activities Regulations 2023; Financial Services and Markets Regulations 2015; Financial Services and Markets Regulations 2015; Regulatory Law 2004; Regulatory Law 2004; 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 Anti-Money Laundering and Sanctions Rulebook; FSRA Fund Rulebook (FUNDS); FSRA Fund Rulebook (FUNDS); Prudential: Investment, Insurance Intermediation and Banking Rulebook (PRU); Prudential: Investment, Insurance Intermediation and Banking Rulebook (PRU); 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)) contains a provision on the language in which the application must be filed. | |
| What the application contains | The application runs in two stages. Stage 1: an Initial Disclosure Questionnaire is submitted to Dubai Economy & Tourism or a relevant Free Zone, with additional documentation including a business plan and details of beneficial owners and senior management. Stage 2: a VASP Licence application supported by a non-exhaustive document list of 18 categories: incorporation certificate, UBO list, fit and proper confirmations, source of funds, organisational structure, governance framework, local website, key personnel details, regulatory business plan, financial projections, financial statements, paid-up capital proof, locked-up capital, reserve account report, insurance certificates, succession plan, wind-down plan and close links analysis. VARA may require further documentation.192021 | Virtual Assets and Related Activities Regulations 2023, Regulation IV.A.2, IV.B.1 and Schedule 1 (Exchange Services), read with Company Rulebook Parts I-VII and VARA VASP Licence Application Documentation List |
| Decision clock | VARA grants or refuses a VASP licence in its sole and absolute discretion (Reg. IV.B.1.a) through a two-stage process. No start date, extension or clock-stop rule is specified.722 | |
| Fees set by law | For Exchange Services, Schedule 2: Supervision and Authorisation Fees of the Virtual Assets and Related Activities Regulations 2023 sets: Licence Application Fee AED 100,000 (one regulated VA Activity); Licence Extension Fee 50% of the lower Licence Application Fee(s) per additional activity; Annual Supervision Fee AED 200,000 per licensed activity, payable in advance of conducting the activity. Application and extension fees fall due at submission; the application is not processed until paid. VARA's fee announcement of 22 June 2023 sets separate administrative fees.232124625 | Virtual Assets and Related Activities Regulations 2023, Schedule 2 (Supervision and Authorisation Fees), issued pursuant to Article 19 of Dubai Law No. (4) of 2022; and VARA Administrative Fee Notice of 21 June 2023 |
| Grounds for refusal | Under Dubai Law No. (4) of 2022 Art. 15 and Regulations 2023 Regulation IV.B.1.a, VARA exercises sole and absolute discretion to grant or refuse a Licence. Refusal grounds include: (a) failure to satisfy fit-and-proper standards for Board members, Senior Management, Responsible Individuals, or UBOs (Company Rulebook Part III); (b) failure to meet minimum paid-up capital (AED 1,500,000, or AED 800,000 with approved custodian) or Net Liquid Assets requirement (1.2x monthly operating expenses) (Company Rulebook Part VI); (c) deficient governance, operational substance, risk management, or ICT/cybersecurity systems (Compliance and Technology Rulebooks); (d) lack of UAE-resident Responsible Individuals (Company Rulebook Part I.C); (e) non-compliance with federal AML/CFT laws or FATF standards (Regulations Part VI); (f) activities posing risk to market integrity, financial stability, or client assets; (g) failure to obtain commercial incorporation approval (ATI) from DET or Free Zone Authority; or (h) submission of false, misleading, or incomplete information. | |
| Appeal | Yes. Under Article 22 of Dubai Law No. (4) of 2022, any affected party may submit a written grievance to the Director General against any decision, action or measure taken against him under that Law, within 30 days of being notified. The grievance is determined within 15 days from referral to a committee formed by the Director General, and that committee's decision is final.26 | Dubai Law No. (4) of 2022, Article 22: an affected party may submit a written grievance to the Director General within 30 days of notification of the contested decision. The grievance is determined within 15 days from referral to the committee formed for this purpose, whose decision is final within the authority. Subsequent judicial challenge lies before the Dubai Courts under Law No. (13) of 2016 Concerning the Judicial Authority in the Emirate of Dubai within 60 days of the grievance decision. |
| Validity | The VARA VA licence is an annual licence, renewed for 12 months. VARA issues a renewal notification 90 days in advance, and an annual supervision fee must be paid at the time of renewal. For Exchange Services the annual supervision fee is AED 200,000, payable in advance of conducting the licensed activity.276 | |
| Change of control | Prior written approval from VARA is required before any action that may result in a change of Control of a VASP; the VASP and the acquiring Entity must jointly file a written application. VARA must approve or deny within thirty (30) Working Days from the filing of an application deemed complete, extendable by a reasonable period. A separate determination that an Entity does not Control another is made within thirty (30) Working Days or further period VARA prescribes. Working Day excludes weekends and public holidays in the Emirate.1828 | |
| Reapplying after a refusal | They confirm only that if an application is denied or withdrawn, no fees are refunded, and that fees apply per application. VARA grants licences in its sole and absolute discretion. Whether a new application may be filed immediately is not addressed.7 | |
| Serving other countries | VARA's remit covers only the Emirate of Dubai: mainland, Special Development Zones and free zones, excluding DIFC. No provision in these passages lets a VARA licensee serve clients in other Emirates or abroad. A commercial blog (passage 4) says Dubai-licensed VASPs are auto-registered with the SCA and may passport across the UAE (except DIFC/ADGM); no legal text here confirms this.429 |
How long it takes
How long does getting a Dubai VARA Virtual Asset Exchange licence really take?
There is no fixed timeline: VARA may grant licences in its sole and absolute discretion (Reg IV.B.1). The MVP phase typically lasts 6 to 12 months under live supervision. BitOasis received the first of Dubai's Minimum Viable Product (MVP) operational licences from VARA in 2023.73746
What it costs
What does a Dubai VARA Exchange licence cost in total, first year and ongoing?
Regulations 2023 Schedule 2 sets two fees for an Exchange Services licence: an application fee of AED 100,000 and an annual supervision fee of AED 200,000. For non-regulated activities, DMCC's Crypto Centre Package starts at AED 31,000.622
Approval odds and who can own it
Company Rulebook Schedule 1 (Definitions) defines Control as possession of power to influence management. Control is presumed where a person holds 25% or more of voting shares, or the right to appoint or dismiss a majority of the Board or Senior Management.28
After you get the licence
Alongside the VARA activity licence, you need a commercial licence. A DMCC commercial licence alone does not authorise regulated virtual asset activity, so a VARA activity licence is required in tandem. Virtual Asset Custody Services must be run through a standalone, structurally segregated legal entity with its own dedicated licence. AED (Dirham) Payment Tokens require a federal licence under the CBUAE Payment Token Services Regulation 2024, regardless of SCA or VARA status.22141
To keep the licence, pay the annual supervision fee of AED 200,000 for Exchange Services (Regulations Schedule 2). VARA Marketing Regulations, effective 1 October 2024, carry penalties up to AED 10,000,000. Federal Decree-Laws No. 32 of 2025 and No. 33 of 2025 establish the Capital Market Authority framework effective 1 January 2026. A VARA circular sets Qualified Investor criteria; a client who fails the assessment waits at least one week before reassessment.6434739
Yes. You may file a grievance against a VARA action or sanction with VARA's Grievance Committee, formed under Article 22 of Dubai Law No. (4) of 2022 to determine grievances against VARA actions and sanctions. Article 22 provides a 30-day filing window from notification. Practitioner analysis confirms grievances are determined internally by the Committee rather than by DIFC tribunals.2636
Regulations 2023 Schedule 2 requires an Annual Supervision Fee of AED 200,000 per licensed Exchange activity, paid in advance. Changes of control require prior written approval under Company Rulebook Part VIII.C, with VARA to approve or deny within a 30-working-day review period (extendable). Law No. (4) of 2022 Article 17 prohibits unauthorised transfer or assignment of a VARA permit.618
Buying a company that already holds it
The VARA Permit/Licence itself is not transferable or assignable to another party without VARA's prior approval; an unauthorised assignment is null and void (Article 17, Law No. (4) of 2022). A change of ownership is instead effected as a share or asset deal in the licensed entity, which separately requires VARA's prior written approval once 25% or more of voting rights or equivalent control passes to the acquirer (see change_of_control).2
Prior approval required. Under Company Rulebook Part VIII.C, no action may be taken that may result in a change of Control of a VASP without VARA's prior written approval. Prior to any transaction, the VASP and acquirer must submit a joint written application. Control is presumed when an entity directly or indirectly owns or controls 25% or more of voting shares, possesses power to direct management/policies, or can appoint or dismiss the majority of the Board or Senior Management. The statutory assessment period is thirty (30) Working Days from deemed receipt of a complete application, extendable by VARA. Assessments consider public interest, investment vs controlling intent, board influence, and fit-and-proper standards.18
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
- Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai: Law No. (4) of 2022
- Virtual Assets and Related Activities Regulations 2023: Virtual Assets and Related Activities Regulations 2023
Getting this licence
Protegra handles this licence end to end: crypto licensing in Dubai (VARA): process, timeline and our fee.
Frequently asked questions
How much capital do you really need for a Dubai VARA Virtual Asset Exchange licence?
Under VARA Company Rulebook Rule VI.B.1, statutory paid-up capital is the higher of AED 1,500,000 or 25% of annual fixed overheads.
How long does getting a Dubai VARA Virtual Asset Exchange licence really take?
There is no fixed timeline: VARA may grant licences in its sole and absolute discretion (Reg IV.B.1).
What does a Dubai VARA Exchange licence cost in total, first year and ongoing?
Regulations 2023 Schedule 2 sets two fees for an Exchange Services licence: an application fee of AED 100,000 and an annual supervision fee of AED 200,000.
What does a Dubai VARA Exchange licence let you do, and where can you serve clients?
A VARA Exchange licence lets you operate a trading venue and settle trades within 24 hours under the Exchange Services Rulebook Part III.
Who do you have to hire for a Dubai VARA Exchange and where must they be based?
Hire two Responsible Individuals as full-time employees who are UAE residents or passport holders (VARA Company Rulebook Part I.C).
Is a Dubai VARA Exchange licence right for your model, and when is Dubai the wrong choice?
VARA targets retail and consumer-facing crypto platforms, while ADGM focuses on institutional MTFs and DIFC operates under DFSA.
VARA, ADGM or DIFC, which UAE regulator is right for your crypto exchange?
VARA suits retail and Web3 crypto businesses, ADGM suits institutional and fund-focused firms, and DIFC operates as a DFSA financial services carve-out.
What are the VARA licence stages (ATI → MVP → FMP) and what can you do at each?
Coincub outlines four sequential VARA licensing phases: ATI, MVP Preparatory, MVP Operational and Full Market Product.
Do you need a free-zone licence and a VARA licence, and a CBUAE licence for stablecoins?
Yes. Dubai requires licences to be stacked. You must first obtain a commercial trade licence from DET or a Dubai free zone (like DMCC, from AED 31,000) for corporate formation, and second, a VARA Exchange licence (AED 100,000 application fee) to operate the venue. Under the CBUAE Payment Token Regulation (effective August 2024), any firm issuing, converting, or facilitating AED-backed payment tokens also requires a federal Central Bank licence, even if already licensed by VARA.
What do VARA's marketing rules ban, even for foreign and unlicensed crypto firms?
VARA's 2024 Marketing Regulations prohibit unauthorised marketing of virtual asset services targeting the UAE and ban privacy coins.
Sources
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