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| Dimension |
Pinned 🇦🇪 ADGM (Abu Dhabi) partly open Verified 2026-08-15
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🇦🇪 United Arab Emirates (Dubai - VARA)
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | Financial Services Permission (FSP) from the FSRA to carry on one or more 'Regulated Activities' in relation to Virtual Assets under the ADGM Financial Services and Markets Regulations (FSMR), e.g. Operating a Multilateral Trading Facility (exchange), Providing Custody, Dealing in Investments as Principal/Agent (broker-dealer), Managing Assets, or Advising on Investments, each 'in relation to Virtual Assets.' The framework was originally branded 'Operating a Crypto Asset Business' (2018 Guidance) and has since been folded into the broader Virtual Asset regulated-activities regime under the 'Guidance - Regulation of Virtual Asset Activities in ADGM' (most recent version 10 June 2025). A related but separate activity/licence covers issuing Fiat-Referenced Tokens (FRTs, i.e. stablecoins). | 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 | Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM) | 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 | ADGM (Abu Dhabi) capital requirement is included in the £349 pass. | United Arab Emirates (Dubai - VARA) capital requirement is included in the £349 pass. |
| Timeline to authorisation | ADGM (Abu Dhabi) timeline to authorisation is included in the £349 pass. | United Arab Emirates (Dubai - VARA) timeline to authorisation is included in the £349 pass. |
| Local substance | ADGM (Abu Dhabi) local substance is included in the £349 pass. | United Arab Emirates (Dubai - VARA) local substance is included in the £349 pass. |
| Application cost | ADGM (Abu Dhabi) application cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) application cost is included in the £349 pass. |
| Ongoing cost | ADGM (Abu Dhabi) ongoing cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) ongoing cost is included in the £349 pass. |
| Passporting | ADGM (Abu Dhabi) passporting is included in the £349 pass. | United Arab Emirates (Dubai - VARA) passporting is included in the £349 pass. |
| MiCA CASPs approved | ADGM (Abu Dhabi) mica casps approved is included in the £349 pass. | United Arab Emirates (Dubai - VARA) mica casps approved is included in the £349 pass. |
| Key restrictions | ADGM (Abu Dhabi) key restrictions is included in the £349 pass. | United Arab Emirates (Dubai - VARA) key restrictions is included in the £349 pass. |
| Recent changes | June 10, 2025: FSRA implemented major amendments, shifted from FSRA pre-approval for Virtual Assets to a notification-based process built on applicant self-assessment; introduced express prohibition on privacy tokens and algorithmic stablecoins; revised capital requirements and fees for VA firms; added product-intervention power for virtual assets. September 2025 (Abu Dhabi Finance Week): FSRA published Consultation Paper No. 10 of 2025 proposing a staking framework. Finalised Fiat-Referenced Token (FRT) framework followed, with FEES Rulebook amendments effective 1 January 2026 (published 31 October 2025). April 29, 2026: FSRA finalised the Virtual Asset staking regulatory framework after consultation. December 2025/January 2026: Binance received FSRA approval (announced 7 December 2025) to operate its global Binance.com platform in ADGM via three regulated entities, described as the first global platform-level licence of this kind under the ADGM framework, operations beginning 5 January 2026. On 7 Jul 2026 the FSRA granted a Financial Services Permission to BTCS (Middle East), the Abu Dhabi subsidiary of Bitcoin Suisse, covering spot trading in accepted virtual assets, institutional custody and derivatives for institutional and professional clients. On 23 July 2026 the FSRA recognised Tether Gold (XAUT) as an Accepted Spot Commodity in ADGM, a spot-commodities recognition distinct from the virtual-asset regulated activities, allowing appropriately permissioned firms to offer the token. | 'Rulebook 2.0' reissued all twelve rulebooks effective 19 Jun 2025 (mandatory Travel Rule, wind-down plans, TLPT, a new VA Issuance rulebook). VARA issued a circular implementing UAE federal anti-money laundering, counter-terrorism financing and proliferation financing requirements for VASPs (4 March 2026), an updated Travel Rule circular (24 February 2026), and an AML/CFT Business Risk Assessment Guidance (12 June 2026). VARA's rulebook site separately hosts a non-binding Guidance on the Virtual Asset Issuance Rulebook, covering two issuance pathways (Category 1: fiat- and asset-referenced tokens needing a VARA licence and reserve assets, except direct-ownership tokens; Category 2: other tokens, distributed only via VARA-licensed distributors or broker-dealers); this document carries no visible date on VARA's own rulebook page, but contemporaneous legal reporting consistently dates its publication to 9 April 2026. VARA has previously stated it penalised around 19 unlicensed firms. Legal-press reporting records VARA's 50th VASP licence (Tribe Tokenisation FZE) in early July 2026. No VARA news items have been published since 12 June 2026 as of 15 July 2026. VARA's own public register listed 52 licensed VASPs as of 1 August 2026, the most recent being Flipster FZE (exchange services, 14 July 2026); the register dates Tribe Tokenisation FZE, earlier reported by legal press as the 50th licensee, to 22 June 2026. No new VARA circular has been published since the 12 June 2026 AML/CFT Business Risk Assessment Guidance. |
| Difficulty rating | ADGM (Abu Dhabi) difficulty rating is included in the £349 pass. | United Arab Emirates (Dubai - VARA) difficulty rating is included in the £349 pass. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.
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