Dubai mainland · Virtual assets

VARA — Dubai's virtual-asset regulator.

The Government of Dubai's standalone virtual-asset regulator. The only regulator for crypto businesses operating from Dubai mainland with UAE consumers. Activities, costs, and when VARA is the right answer.

What VARA is

The Virtual Assets Regulatory Authority (VARA) is the Government of Dubai's standalone regulator for virtual-asset activity carried out from the Emirate of Dubai, excluding the financial free zones (DIFC and ADGM, which have their own regulators DFSA and FSRA respectively). VARA was established under Dubai Law No. 4 of 2022 and is the world's first dedicated, jurisdiction-level virtual-assets regulator. It licenses every business carrying out a Virtual Asset Service in or from Dubai mainland.

VARA is appropriate for businesses physically operating from Dubai (typically a Dubai DED licence or a Dubai non-financial Free Zone like DMCC) and providing virtual-asset services. It is not the right regulator for purely offshore token issuance (use BVI or Cayman), pure DAO governance vehicles (use Marshall Islands or Wyoming), or for institutional capital-markets activity (use ADGM FSRA or DIFC DFSA).

VARA-licensed activities

VA Advisory Services — providing advice on virtual-asset investments. Lowest barrier.
VA Broker-Dealer Services — agency or principal trading of virtual assets.
VA Custody Services — holding virtual assets for clients. High capital, technology-segregation rules.
VA Exchange Services — operating a venue for virtual-asset trading.
VA Lending and Borrowing Services — credit activity in virtual assets.
VA Management and Investment Services — discretionary VA portfolio management.
VA Issuance — issuing virtual assets directly to the public. Includes stablecoin issuance under VARA's stablecoin framework.

Each licensable activity has its own rulebook, capital requirements, technology-control rules, and ongoing supervisory regime.

Indicative cost (USD)

Item	Year 1	Year 2
Initial Disclosure Questionnaire (IDQ) fee	USD 1,400	—
Initial Approval Application fee	USD 26,500	—
VA Licence application (per activity)	USD 27,250 – 109,000	—
Annual VARA supervision fee	—	USD 27,250 – 218,000
Minimum paid-up capital (varies by activity)	USD 27,250 – 1,500,000	—
ArxSetup advisory + filing fees	USD 65,000 – 185,000	USD 24,000+

Total all-in launch cost for a VARA-licensed business ranges from USD 150,000 (lowest, for VA Advisory) to USD 2,500,000 (for a full VA Exchange). VARA licensing is not appropriate for sub-USD 5m capitalisation businesses.

Process and timeline

Initial Disclosure Questionnaire (IDQ). Pre-application gating; 2–3 weeks.
Initial Approval. VARA approves you in principle to apply for the full licence. 6–10 weeks. At this stage you can incorporate the licensed entity and begin building.
VA Licence application. Full operational application — policies, technology controls, key persons, capital. 12–24 weeks.
Operational permission. VARA confirms you may go live. Typically conditional on independent technology audit.

End-to-end: 9–14 months for a well-prepared application. Founders often underestimate; VARA is rigorous.

When VARA wins

Dubai-mainland operating presence with UAE retail customers — only VARA can authorise this.
Stablecoin issuance with Dubai consumers — VARA stablecoin rulebook is purpose-built.
VA Exchange targeting MENA flow.
Custody or VASP services to GCC family offices.

When VARA is the wrong answer

Pure token issuance with no UAE retail nexus — use BVI or Cayman, far cheaper.
Institutional crypto fund (Master / Private / Mutual) — use Cayman CIMA.
Capital-markets-grade Investment Tokens — use ADGM FSRA or DIFC DFSA, with deeper financial-services frameworks.
DAO governance vehicle — use Marshall Islands or Wyoming DAO LLC.
Sub-USD 5m capitalisation business — VARA's cost base is prohibitive.

Common VARA questions

Do I need a VARA licence if I am only issuing tokens to non-UAE users?

VARA's jurisdictional scope is activity carried out "in or from" Dubai. A Dubai-incorporated issuer marketing to non-UAE users may still be in scope depending on the marketing channels, the location of decision-making, and the location of the team. We assess case by case; in practice, most non-UAE issuance teams choose to incorporate offshore (BVI, Cayman) and keep their UAE presence to a non-issuance role.

Can I get a VARA licence as a foreign-incorporated entity?

No. The VARA-licensed entity must be incorporated in the Emirate of Dubai (Dubai DED LLC or a Dubai non-financial Free Zone). Foreign entities can passport into a licensed UAE subsidiary.

How does VARA interact with ADGM FSRA and DIFC DFSA?

The three regulators have non-overlapping jurisdictional perimeters. VARA covers Dubai outside the DIFC. DFSA covers DIFC. FSRA covers ADGM. A business operating across all three needs three separate licences. Federal AML rules apply across all three jurisdictions.

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Reviewed by the ArxSetup editorial team

Prepared and reviewed by qualified counsel within ArxSetup and our affiliated practices, Neo Legal (UAE) and Cornwalls (Australia). Figures verified against primary regulator sources. Last reviewed: May 2026. How we review →

Est. 2021 · DDA Licence 107229

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Frequently asked about VARA

Common questions on VARA.

These are the questions UAE-resident founders most often ask before signing an engagement letter. Each answer is current as of 2026 and reviewed by our incorporation team.

How much does a VARA licence cost in 2026?

Application fees from USD 17,400/year (AED 63,800) for Advisory, Broker-Dealer, Lending and VA Issuance; USD 21,350/year (AED 78,300) for Custody, Exchange and Management/Investment. Annual supervision fees start at AED 80,000 (Advisory) and reach AED 200,000 (Exchange). Realistic all-in year-one is USD 500,000 to USD 2 million.

How long does VARA licensing take?

4 months minimum for single-activity, well-prepared applications. 6–12 months typical for multi-activity or novel business models, across the two-stage IDQ → ATI → VASP full-licence pathway.

What are the VARA licence categories?

Eight categories — Advisory, Broker-Dealer, Custody, Exchange, Lending and Borrowing, Management and Investment, Transfer and Settlement, and Virtual Asset Issuance.

What is the minimum capital for a VARA licence?

Activity-dependent — Broker-Dealer approximately AED 400,000–600,000; Exchange and Custody requirements are materially higher (AED 4 million+). Capital is cumulative if you apply for multiple activities and must be held in a UAE-based segregated trust account.

Does a VARA licence require a physical office in Dubai?

Yes — all Virtual Asset Service Providers (VASPs) must lease or own a physical office in Dubai. Virtual offices are not accepted.

VARA vs ADGM — which crypto licence should I get?

VARA covers the whole Emirate of Dubai (excluding DIFC) and is purpose-built for crypto-native firms (exchanges, NFT platforms, Web3). ADGM/FSRA covers only ADGM and tends to attract institutional finance players and tokenised-asset platforms. Many firms hold both to cover both emirates.

Can a free-zone company in DMCC or IFZA get a VARA licence?

Yes — VARA requires a Dubai commercial entity, which can be a DMCC, DWTC, DAFZA or mainland company. You cannot use a DIFC entity — DIFC has its own DFSA crypto regime.

How do I apply for a VARA licence?

Submit an Initial Disclosure Questionnaire (IDQ) and pay 50% of fees; receive Approval to Incorporate (ATI); set up the legal entity and Dubai office; submit the full VASP application with AML/KYC, governance, capital and cybersecurity documentation; receive In-Principle Approval; meet preconditions; obtain operational licence.

What is the total cost of getting a VARA crypto licence?

Year-one all-in typically AED 500,000 to AED 2 million for a fully operational VASP, including company formation, VARA fees, office, two Responsible Individuals, compliance hires, regulatory capital and audits.

Does VARA regulate NFTs and stablecoins?

Yes — VARA's framework covers issuance, custody, brokerage and exchange of virtual assets including NFTs (where used as financial instruments) and fiat-referenced tokens. Privacy tokens such as Monero and Zcash are explicitly prohibited.

Who are the VARA Responsible Individuals?

Two mandatory full-time, UAE-resident or UAE-passport-holding senior executives who pass VARA's Fit and Proper test — typically the CEO and the Money-Laundering Reporting Officer/Compliance Officer.

Can I get a VARA licence as a non-UAE founder?

Yes — 100% foreign ownership is permitted. Founders do not need to be UAE residents, but the two Responsible Individuals (typically CEO/CCO) must be UAE-resident or UAE-passport holders.

Does VARA require insurance?

Yes — VASPs must maintain insurance covering operational risks, cyber threats and client-asset losses, with coverage levels proportionate to activity scale.

Can a VARA-licensed company serve retail customers?

Yes — VARA's framework explicitly supports retail-facing crypto offerings (exchanges, broker-dealers, advisory) subject to consumer-protection, marketing and AML obligations.

How does VARA differ from the SCA (Securities and Commodities Authority)?

VARA regulates virtual assets within the Emirate of Dubai (excluding DIFC). The SCA regulates securities, commodities and certain virtual-asset activities federally outside Dubai. Cross-emirate operations may require both.

Quick answers on VARA.

How much is a VARA crypto licence in Dubai?

All-in USD 500,000 to USD 2 million for year one — fees, capital, office, Responsible Individuals, compliance, legal.

VARA vs SCA?

VARA regulates virtual assets in Dubai (excluding DIFC); SCA regulates federally and elsewhere in the UAE. Some firms hold both for cross-emirate operations.

What activities require a VARA licence?

Advisory, Broker-Dealer, Custody, Exchange, Lending/Borrowing, Management/Investment, Transfer/Settlement, Virtual Asset Issuance — eight categories total.

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