Virtual Asset Management and Investment Services Licence (Dubai (VARA))
The Virtual Asset Management and Investment Services Licence covers managing, administering or disposing of another person's virtual assets as agent or fiduciary, including investment management and staking, in Dubai outside the DIFC. Paid-up capital is the higher of AED 500,000 or 25% of fixed annual overheads, or AED 280,000 / 15% with a VARA-licensed custodian or an approved custody arrangement. The application fee is AED 100,000 and annual supervision AED 200,000. VARA's register listed twelve holders on 29 September 2026.
At a glance
| Official name | Virtual Asset Management and Investment Services Licence1 |
|---|---|
| Also known as | VARA asset management licence · Dubai crypto investment management licence · VA Management and Investment 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 | 129 |
What it lets you do
| Portfolio management of crypto-assets | Managing portfolios that include crypto-assets on a discretionary, client-by-client basis under a mandate. |
|---|
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 | |
| 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 | |
| Capital | The reduced AED 280,000 / 15%-of-overheads capital tier applies only where the VASP uses a VARA-licensed Custody Services provider or a custody arrangement otherwise approved during the licensing process; without either, the AED 500,000 / 25% tier applies.6 | |
| Management and people | Where an Entity applies for a Licence for more than one regulated VA Activity, a Licence Extension Fee is payable for each additional activity; for VA Management and Investment Services it is AED 200,000 (the 50%-of-lower-application-fee formula applies only to Advisory Services). The annual supervision fee (AED 200,000 for this activity) accrues for each regulated VA 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 (Company Rulebook Part VIII.C, prior written approval, 30 Working Days from a complete application) and, separately, any merger or acquisition of all or a substantial part of a VASP's assets (Part VIII.D, also requiring VARA's prior written approval). No provision was found permitting the licence itself to be assigned to a different legal entity. VARA may also 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 crypto asset manager need?
The higher of AED 500,000 or 25% of fixed annual overheads under Company Rulebook Rule VI.B.1. That drops to the higher of AED 280,000 or 15% of overheads if the manager uses a VARA-licensed Custody Services provider for client virtual assets, rewarding managers who do not self-custody.
Why is the capital requirement lower for some Management and Investment licensees?
VARA lowers the fixed floor from AED 500,000 to AED 280,000 and the overheads percentage from 25% to 15% when the manager uses a VASP licensed by VARA for Custody Services, or a custody arrangement otherwise approved during licensing (Company Rulebook Rule VI.B.1).
How long does VARA take to approve this licence?
There is no fixed statutory deadline; Regulations 2023 give VARA sole discretion over the timing of a decision based on how complete the application is. VARA publishes no typical processing time for this licence.
What are the ongoing costs after getting the licence?
AED 200,000 in annual supervision fees (Schedule 2, Regulations 2023), plus maintaining Net Liquid Assets of at least 1.2 times monthly operating expenses, reconciled daily and reported to VARA monthly, on top of the underlying paid-up capital held in a UAE bank trust account or surety bond.
Who does VARA vet for fitness and propriety at a licensed asset manager?
The Board (collectively and individually), the two mandatory Responsible Individuals, and the Compliance Officer/MLRO, assessed on qualifications, experience, solvency and integrity. Anyone acquiring 25% or more of voting control, or power to appoint the Board majority, is separately vetted under the change-of-control regime.
How many firms currently hold this licence?
Twelve, per VARA's public register as of 29 September 2026 - the third-largest activity category after Broker-Dealer (41) and Exchange (15), ahead of Custody (6), Lending (5), Advisory (3) and Category 1 Issuance (2).
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 2026-09-29
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