UAE — Dubai (VARA)
A dedicated virtual-asset regulator with seven activity-based licence categories and a mandatory two-stage approval.
Who regulates this
Virtual Assets Regulatory AuthorityVARA
All virtual-asset activity in the Emirate of Dubai except the DIFC financial free zone, which is DFSA territory.
Licences and permissions
VASP Licence (activity-based)
Advisory, Broker-Dealer, Custody, Exchange, Lending & Borrowing, Management & Investment, Transfer & Settlement.
You name the specific activities you intend to carry on. Each carries its own rulebook and its own capital floor.
Initial Approval → Full Licence
The two-stage path every applicant runs.
Initial Approval permits set-up work only. Operating before the Full Licence is issued is unlicensed activity.
What it takes
Capital
Set per activity in VARA's rulebooks, and generally the higher of a fixed floor or a proportion of annual operating expenditure. Confirm the current figure for your specific activity set with VARA directly — the rulebooks are amended.
Timeline
Roughly four to seven months across both stages in current practice, assuming a complete file. Incomplete AML documentation is the usual cause of delay.
Substance
Physical presence in Dubai is required — a leased or owned office, not a flexi-desk. Senior appointees, including a Compliance Officer and MLRO, must be resident and approved.
Where a software vendor sits
VARA regulates the activity, not the software. A vendor that never holds customer assets, never onboards end-users and never executes trades is not itself carrying on a licensable activity — but that has to be true architecturally, not just contractually. Where a vendor also hosts and operates infrastructure, the analysis is fact-specific and worth counsel.
What catches people out
A VARA licence does not passport. It authorises activity in Dubai (excluding DIFC) and nowhere else — not ADGM, not onshore UAE under the SCA, and certainly not abroad.
Verify this yourself
We would rather you checked. These are the primary and authoritative secondary sources behind the summary above.