Virtual Asset Lending and Borrowing Services Licence (Dubai (VARA))
The Virtual Asset Lending and Borrowing Services Licence lets a VASP run collateralised and bilateral crypto lending in Dubai (mainland and free zones, excluding DIFC). VARA requires paid-up capital of the higher of AED 500,000 or 25% of fixed annual overheads, an AED 100,000 application fee, AED 200,000 annual supervision, and has no fixed statutory decision deadline. Five firms hold it today.
At a glance
| Official name | Virtual Asset Lending and Borrowing Services Licence1 |
|---|---|
| Also known as | VARA lending licence · Dubai crypto lending licence · VA Lending and Borrowing 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: Valid only for Dubai mainland and free zones; VARA's mandate explicitly excludes the Dubai International Financial Centre (DIFC), which is regulated separately by the DFSA. The licence does not extend to Abu Dhabi (ADGM) or other emirates.5 |
| Minimum capital | AED 500,0006 |
| Application fee | AED 100,0007 |
| Annual fee | AED 200,0007 |
| 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.8 |
| Public register | official register9 |
| Current holders | 59 |
What it lets you do
| Lending | Granting loans, including consumer credit, mortgage credit, factoring and financing of commercial transactions. |
|---|
Where it is valid
Requirements
| Requirement | What is needed | Legal reference |
|---|---|---|
| Capital and people assessed | ||
| Minimum capital | AED 500,0006 | |
| Ongoing own funds | On an ongoing basis the VASP must hold Net Liquid Assets (current assets less current liabilities) worth at least 1.2 times its monthly operating expenses. Net Liquid Assets must be reconciled daily and reported to VARA monthly; eligible assets are limited to cash equivalents and USD/AED-referenced virtual assets VARA approves. Paid-up capital itself must be reconciled monthly and held in a trust account with a UAE-licensed bank naming VARA as beneficiary, or an equivalent open-ended surety bond.10 | |
| Who is assessed | VARA's Fit and Proper regime assesses the Board (collectively and individually, on qualification, industry/management experience, solvency, integrity and reputation), the two Responsible Individuals, and the Compliance Officer/MLRO. On a change of control, any acquirer of 25% or more of voting shares or of the power to appoint/dismiss the majority of the Board is separately assessed.11 | |
| Substance and people | ||
| Local presence | Two Responsible Individuals of sufficient seniority, each a full-time VASP employee, resident in the UAE or a UAE-passport holder, notified to and approved by VARA during licensing and re-approved on any change.12 | |
| AML/CFT | A dedicated Compliance Officer, full-time and UAE-resident (or UAE-passport holder), reporting directly to the Board; the role may be combined with the Money Laundering Reporting Officer role provided VARA is satisfied this does not compromise fit-and-proper status.13 | |
| AML/CFT | A Money Laundering Reporting Officer with at least two years of AML/CFT experience, assessed as a Fit and Proper Person and reviewed annually.14 | |
| Management and people | The Board collectively must possess adequate knowledge, skills and experience to run the business, assessed under the Fit and Proper regime (qualification, industry and management experience, solvency, integrity and reputation).11 | |
| Capital | Paid-up capital must be held in a trust account with a UAE-licensed bank naming VARA as beneficiary, or an open-ended surety bond from a UAE-authorised surety company naming VARA as beneficiary; a commercial (DET or free-zone) trade licence and Dubai office are also required, held separately from the VARA licence itself.6 | |
| Conditions to keep the licence | ||
| Local presence | VARA may incorporate limitations and stipulations into a licence and may grant it for a specified time only.8 | |
| Withdrawal | VARA may vary, suspend or revoke the licence for material violation of any law, regulation, rule or directive, for insolvency or insolvency proceedings, for failure to pay a judgment within 30 calendar days, or for other "Good Cause".8 | |
| Reporting | Net Liquid Assets must be reconciled daily and reported to VARA monthly; paid-up capital must be reconciled monthly.10 | |
| Requirement | Adding a further regulated activity to an existing VARA licence costs a Licence Extension Fee equal to 50% of the lower of the two activities' application fees, rather than the full application fee again; annual supervision fees accrue per activity held.7 | |
Cost
Buying a company that already holds it
The licence is granted to, and attaches to, the licensed legal entity; VARA's rulebook regulates changes of ownership/control within that entity (a share deal), not assignment of the licence itself to a different entity. The Change of Control section (Company Rulebook Part VIII.C) contains no provision permitting the licence to be transferred to another legal entity, and no clause distinguishing an asset-sale acquisition from a share-sale acquisition; VARA's licensing-powers rule instead lets VARA vary, suspend or revoke a licence on material breach, insolvency or "Good Cause".15
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.15
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 does a VARA Lending and Borrowing licence need?
The higher of AED 500,000 or 25% of the VASP's fixed annual overheads for this activity, per Company Rulebook Rule VI.B.1. It must be held in a UAE bank trust account (or equivalent surety bond) naming VARA as beneficiary, reconciled monthly, and is separate from any capital required for other activities the same VASP holds.
How long does it take to get a VARA crypto lending licence?
VARA sets no fixed statutory deadline for the initial licensing decision; Regulations 2023 give VARA sole discretion to grant licences based on submission completeness. The regulator's own dossier notes observed timelines of roughly 6 to 12 months, though that figure is not stated by VARA itself.
What does the licence cost each year?
An AED 100,000 application fee and AED 200,000 in annual supervision fees, per Schedule 2 of the Regulations 2023. Adding lending as a second activity to an existing VARA licence instead costs a 50% extension fee on the lower of the two application fees.
Who at the company does VARA vet for fitness and propriety?
The Board (collectively and individually), the two mandatory Responsible Individuals, and the Compliance Officer/MLRO, all assessed on qualifications, experience, solvency and integrity. Anyone acquiring 25% or more of voting control, or the power to appoint the Board majority, is separately vetted under the change-of-control regime.
Can a VARA lending licence be sold or transferred to another company?
VARA's rules govern change of ownership within the licensed entity (prior written approval above 25% control) rather than assignment of the licence to a different legal entity; no VARA rule found in this research describes transferring the licence itself, and VARA can vary, suspend or revoke a licence for material breach, insolvency or "Good Cause".
How many firms hold this licence today?
Five, according to VARA's public register as of 24 September 2026, making it one of the smaller activity categories alongside Advisory (3) and Category 1 Issuance (2); Broker-Dealer (41) and Exchange (15) are far larger.
Sources
- vara.ae: licensed activities · retrieved 2026-09-24
- VARA Rulebooks: law no 4 2022 regulating virtual assets emirate dubai · retrieved 2026-09-24
- VARA Rulebooks: cabinet decision no 1112022 regulation virtual assets and th · retrieved 2026-09-24
- VARA Rulebooks: cabinet decision no 1122022 delegating certain competencies · retrieved 2026-09-24
- vara.ae: about vara · retrieved 2026-09-24
- VARA Rulebooks: b paid capital · retrieved 2026-09-24
- VARA Rulebooks: schedule 2 supervision and authorisation fees · retrieved 2026-09-24
- VARA Rulebooks: b varas licensing and authorisation powers · retrieved 2026-09-24
- vara.ae: public register · retrieved 2026-09-24
- VARA Rulebooks: c net liquid assets · retrieved 2026-09-24
- VARA Rulebooks: general principles 1 · retrieved 2026-09-24
- VARA Rulebooks: c responsible individuals · retrieved 2026-09-24
- VARA Rulebooks: c duties compliance officer · retrieved 2026-09-24
- VARA Rulebooks: appointment and duties money laundering reporting officer · retrieved 2026-09-24
- VARA Rulebooks: c change control · retrieved 2026-09-24
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