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| Dimension |
Pinned 🇧🇭 Bahrain partly open Verified 2026-08-15
|
🇦🇪 United Arab Emirates (Dubai - VARA)
partly open
Verified 2026-08-15
|
|---|---|---|
| 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 included in the £349 pass. | United Arab Emirates (Dubai - VARA) capital requirement is included in the £349 pass. |
| Timeline to authorisation | Bahrain 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 | Bahrain local substance is included in the £349 pass. | United Arab Emirates (Dubai - VARA) local substance is included in the £349 pass. |
| Application cost | Bahrain application cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) application cost is included in the £349 pass. |
| Ongoing cost | Bahrain ongoing cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) ongoing cost is included in the £349 pass. |
| Passporting | Bahrain passporting is included in the £349 pass. | United Arab Emirates (Dubai - VARA) passporting is included in the £349 pass. |
| MiCA CASPs approved | Bahrain 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 | Bahrain key restrictions is included in the £349 pass. | United Arab Emirates (Dubai - VARA) key restrictions is included in the £349 pass. |
| Recent changes | 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). On 3 June 2026 AX Coin Bahrain B.S.C. (c), a subsidiary of Nasdaq-listed Solowin Holdings, announced it had been granted the first licence under this framework, for stablecoin issuer activities (per the issuer's announcement; a CBB press release confirming the grant is pending direct confirmation). Separately, CBB granted a new Category 3 crypto-asset licence to Fasset Financial Services W.L.L. in January 2025. In May 2026 the CBB restructured the approved-persons section (CRA-1.7) of the Crypto-Asset Module, regrouping its fit-and-proper, prior-approval and notification rules under relocated headings (Rulebook revision of 6 May 2026). | '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 | Bahrain 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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