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UAE — Dubai (VARA)

A dedicated virtual-asset regulator with seven activity-based licence categories and a mandatory two-stage approval.

Middle East·Comprehensive·Reviewed 2026-08-28

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.