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| Dimension |
Pinned 🇭🇰 Hong Kong partly open Verified 2026-08-15
|
🇦🇪 United Arab Emirates (Dubai - VARA)
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | SFC Virtual Asset Trading Platform (VATP) licence on a dual basis: under the AMLO and, for tokens that are securities, under the SFO (Type 1 dealing + Type 7 automated trading). Stablecoin issuance is separately licensed by the HKMA under the Stablecoins Ordinance (Cap. 656). | 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 | SFC regulates VATPs and security-token activity; HKMA regulates stablecoin issuers and banks' VA activities. Staking and intermediary VA activity are covered by joint SFC-HKMA circulars. | 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 | Hong Kong capital requirement is included in the £349 pass. | United Arab Emirates (Dubai - VARA) capital requirement is included in the £349 pass. |
| Timeline to authorisation | Hong Kong 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 | Hong Kong local substance is included in the £349 pass. | United Arab Emirates (Dubai - VARA) local substance is included in the £349 pass. |
| Application cost | Hong Kong application cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) application cost is included in the £349 pass. |
| Ongoing cost | Hong Kong ongoing cost is included in the £349 pass. | United Arab Emirates (Dubai - VARA) ongoing cost is included in the £349 pass. |
| Passporting | Hong Kong passporting is included in the £349 pass. | United Arab Emirates (Dubai - VARA) passporting is included in the £349 pass. |
| MiCA CASPs approved | Hong Kong 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 | Hong Kong key restrictions is included in the £349 pass. | United Arab Emirates (Dubai - VARA) key restrictions is included in the £349 pass. |
| Recent changes | SFC ASPIRe roadmap (19 Feb 2025); VATP staking guidance (7 Apr 2025); HKMA Stablecoins Ordinance in force 1 August 2025, with the first two issuer licences (HSBC, Anchorpoint) granted 10 April 2026; the HKMA register lists only these two issuers as of 23 April 2026. FSTB and SFC published consultation conclusions on virtual asset dealing and custodian licensing on 24 December 2025, then published consultation conclusions on virtual asset advisory and management service provider licensing on 26 May 2026. All four new licensing regimes, dealing, custodian, advisory and management, have now completed consultation; FSTB and SFC are finalising the legislative proposals, with a single bill covering all four regimes still targeted for introduction into the Legislative Council within 2026 (not yet introduced). 13 VATPs are licensed by the SFC, unchanged since the last review (most recently NewBX, licensed 18 May 2026). A June 2026 Legislative Council reply confirmed the HKMA received 36 stablecoin-licence applications in the first window and expects the overall number of licences to remain very limited. | '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 | Hong Kong 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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