🇧🇭 Bahrain vs 🇦🇪 United Arab Emirates (Dubai - VARA): crypto licensing compared
On paper, Bahrain's Crypto-Asset Service Licence under CBB Rulebook Volume 6 (Capital Markets), Crypto-Asset Module (CRA), issued under Decree Law No. 64 of 2006 (CBB Law). Four categories: Category 1 (reception/transmission of orders, investment advice), Category 2 (Cat-1 activities plus trading as agent, portfolio management, custody), Category 3 (Cat-2 activities plus trading as principal/dealing on own account), Category 4 (operating a licensed crypto-asset exchange plus custody). A separate Stablecoin Issuance and Offering (SIO) Module (also Volume 6) now licenses stablecoin issuers. and United Arab Emirates (Dubai - VARA)'s VARA VASP licence under the Virtual Assets and Related Activities Regulations 2023 - licensed PER ACTIVITY (Advisory, Broker-Dealer, Custody, Exchange, Lending & Borrowing, Management & Investment, Transfer & Settlement, plus VA Issuance). A DET/free-zone commercial licence is also required. answer the same question; in practice the detail decides it. The two regimes differ on 7 of 9 tracked decision dimensions, including capital requirement and timeline to authorisation. This page compares the two side by side: the identity columns are free, the decision figures are one pass away, and every cell shows when it was last checked.
Bahrain: verified 2026-07-02 · United Arab Emirates (Dubai - VARA): verified 2026-07-03
| Dimension |
🇧🇭 Bahrain
partly open
Verified 2026-07-02
|
🇦🇪 United Arab Emirates (Dubai - VARA)
partly open
Verified 2026-07-03
|
|---|---|---|
| Licence type | Crypto-Asset Service Licence under CBB Rulebook Volume 6 (Capital Markets), Crypto-Asset Module (CRA), issued under Decree Law No. 64 of 2006 (CBB Law). Four categories: Category 1 (reception/transmission of orders, investment advice), Category 2 (Cat-1 activities plus trading as agent, portfolio management, custody), Category 3 (Cat-2 activities plus trading as principal/dealing on own account), Category 4 (operating a licensed crypto-asset exchange plus custody). A separate Stablecoin Issuance and Offering (SIO) Module (also Volume 6) now licenses stablecoin issuers. | VARA VASP licence under the Virtual Assets and Related Activities Regulations 2023 - licensed PER ACTIVITY (Advisory, Broker-Dealer, Custody, Exchange, Lending & Borrowing, Management & Investment, Transfer & Settlement, plus VA Issuance). A DET/free-zone commercial licence is also required. |
| Regulator | Central Bank of Bahrain (CBB) | VARA (Virtual Assets Regulatory Authority) - sole authority across the Emirate of Dubai except the DIFC. Parallel UAE regimes exist: ADGM/FSRA (Abu Dhabi), DFSA (DIFC), and federal SCA/Central Bank. |
| Capital requirement | Bahrain capital requirement is locked. Unlock with the £349 pass. | United Arab Emirates (Dubai - VARA) capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Bahrain timeline to authorisation is locked. Unlock with the £349 pass. | United Arab Emirates (Dubai - VARA) timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Bahrain local substance is locked. Unlock with the £349 pass. | United Arab Emirates (Dubai - VARA) local substance is locked. Unlock with the £349 pass. |
| Application cost | Bahrain application cost is locked. Unlock with the £349 pass. | United Arab Emirates (Dubai - VARA) application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Bahrain ongoing cost is locked. Unlock with the £349 pass. | United Arab Emirates (Dubai - VARA) ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Bahrain passporting is locked. Unlock with the £349 pass. | United Arab Emirates (Dubai - VARA) passporting is locked. Unlock with the £349 pass. |
| MiCA CASPs approved | Bahrain mica casps approved is locked. Unlock with the £349 pass. | United Arab Emirates (Dubai - VARA) mica casps approved is locked. Unlock with the £349 pass. |
| Key restrictions | Bahrain key restrictions is locked. Unlock with the £349 pass. | United Arab Emirates (Dubai - VARA) key restrictions is locked. Unlock with the £349 pass. |
| Recent changes | CONFIRMED: In July 2025 the CBB issued a new Stablecoin Issuance and Offering (SIO) Module, added to Rulebook Volume 6, creating Bahrain's first dedicated stablecoin licensing framework. It covers issuance, minting, burning, and reserve management of single-currency stablecoins backed by BHD, USD, or other CBB-accepted fiat currencies; requires issuers to incorporate as a Bahraini B.S.C.; mandates perpetual redemption rights for holders; and explicitly permits yield-bearing stablecoins (subject to CBB-set limits), a more permissive stance than many other jurisdictions. This confirms the '2025 stablecoin module' claim. Separately, CBB granted a new Category 3 crypto-asset licence to Fasset Financial Services W.L.L. in January 2025. | 'Rulebook 2.0' reissued all twelve rulebooks effective 19 Jun 2025 (mandatory Travel Rule, wind-down plans, TLPT, a new VA Issuance rulebook). AML circular (Mar 2026) and token-issuance guidance (Apr 2026). VARA penalised ~19 unlicensed firms. |
| Difficulty rating | Bahrain difficulty rating is locked. Unlock with the £349 pass. | United Arab Emirates (Dubai - VARA) difficulty rating is locked. Unlock with the £349 pass. |
The two regimes differ on 7 of 9 tracked decision dimensions, including capital requirement and timeline to authorisation. Unlock the pass to see each figure with its source and verification date.
What changed recently
🇧🇭 Bahrain (verified 2026-07-02): CONFIRMED: In July 2025 the CBB issued a new Stablecoin Issuance and Offering (SIO) Module, added to Rulebook Volume 6, creating Bahrain's first dedicated stablecoin licensing framework. It covers issuance, minting, burning, and reserve management of single-currency stablecoins backed by BHD, USD, or other CBB-accepted fiat currencies; requires issuers to incorporate as a Bahraini B.S.C.; mandates perpetual redemption rights for holders; and explicitly permits yield-bearing stablecoins (subject to CBB-set limits), a more permissive stance than many other jurisdictions. This confirms the '2025 stablecoin module' claim. Separately, CBB granted a new Category 3 crypto-asset licence to Fasset Financial Services W.L.L. in January 2025.
🇦🇪 United Arab Emirates (Dubai - VARA) (verified 2026-07-03): 'Rulebook 2.0' reissued all twelve rulebooks effective 19 Jun 2025 (mandatory Travel Rule, wind-down plans, TLPT, a new VA Issuance rulebook). AML circular (Mar 2026) and token-issuance guidance (Apr 2026). VARA penalised ~19 unlicensed firms.
Quick answers
Who regulates crypto licensing in Bahrain and United Arab Emirates (Dubai - VARA)?
Bahrain: Central Bank of Bahrain (CBB). United Arab Emirates (Dubai - VARA): VARA (Virtual Assets Regulatory Authority) - sole authority across the Emirate of Dubai except the DIFC. Parallel UAE regimes exist: ADGM/FSRA (Abu Dhabi), DFSA (DIFC), and federal SCA/Central Bank..
What licence do you need in Bahrain compared with United Arab Emirates (Dubai - VARA)?
In Bahrain the authorisation route is Crypto-Asset Service Licence under CBB Rulebook Volume 6 (Capital Markets), Crypto-Asset Module (CRA), issued under Decree Law No. 64 of 2006 (CBB Law). Four categories: Category 1 (reception/transmission of orders, investment advice), Category 2 (Cat-1 activities plus trading as agent, portfolio management, custody), Category 3 (Cat-2 activities plus trading as principal/dealing on own account), Category 4 (operating a licensed crypto-asset exchange plus custody). A separate Stablecoin Issuance and Offering (SIO) Module (also Volume 6) now licenses stablecoin issuers.; in United Arab Emirates (Dubai - VARA) it is VARA VASP licence under the Virtual Assets and Related Activities Regulations 2023 - licensed PER ACTIVITY (Advisory, Broker-Dealer, Custody, Exchange, Lending & Borrowing, Management & Investment, Transfer & Settlement, plus VA Issuance). A DET/free-zone commercial licence is also required.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Bahrain vs United Arab Emirates (Dubai - VARA) comparison?
The interactive benchmark lets you pin either jurisdiction and add up to five peers; a Founder Pass or Pro subscription unlocks every gated figure with its source and verification date. This page stays free at /crypto/compare/bahrain-vs-uae-vara.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.