Dubai licenses virtual asset firms through VARA, the Virtual Assets Regulatory Authority, under the Virtual Assets and Related Activities Regulations 2023. The licence is granted per activity, spanning advisory, broker-dealer, custody, exchange, lending and borrowing, management and investment, transfer and settlement, and issuance, and a DET or free-zone commercial licence is required alongside. VARA's remit covers the Emirate of Dubai except the DIFC; Abu Dhabi's ADGM, the DFSA and the federal SCA and Central Bank operate parallel regimes, so the licence carries no passport within the UAE or beyond.
The rulebook moves quickly. Rulebook 2.0 reissued all twelve rulebooks with effect from 19 June 2025, bringing a mandatory Travel Rule, wind-down plans, threat-led penetration testing and a new issuance rulebook; an AML circular followed in March 2026 and token-issuance guidance in April 2026. VARA has penalised around nineteen unlicensed firms.
This is a full-substance regime. It expects a physical Dubai office and a locally resident, VARA-pre-approved senior team, chief executive, compliance officer and money laundering reporting officer among them, none nominal, with board governance and risk and technology functions behind them. Paid-up capital is set per activity, rising sharply from the lighter advisory permissions to a full exchange, with net-liquid-asset and reserve requirements on top. Application fees also run per activity, and the all-in cost, including the commercial licence and advisory work, climbs steeply for the heavier activities, with a full exchange build the most expensive by a wide margin. Annual supervision fees are charged per activity and payable in advance.
Privacy coins and mixers are prohibited, client assets must be segregated with full reserves and proof of reserves, and the 2024 marketing regulations bind even foreign entities targeting Dubai. The process runs in two stages, an initial approval allowing incorporation and hiring, then the full licence review; a well-prepared applicant moves through appreciably faster than an unprepared one.