The VARA Licence in Dubai
Dubai's dedicated virtual-asset regime — which activities need a VASP licence, how the two-stage process works, and what applicants must prepare.
Dubai was the first jurisdiction in the world to create a regulator dedicated solely to virtual assets. The Virtual Assets Regulatory Authority (VARA) was established under Law No. (4) of 2022 regulating virtual assets in the Emirate of Dubai. If you intend to carry on any virtual-asset activity in or from Dubai, a VARA VASP (Virtual Asset Service Provider) licence is mandatory — with one important exception below.
The seven regulated activities
A VASP application must identify one or more of seven regulated activity categories, each with its own activity-specific rulebook:
- Advisory services
- Broker-Dealer services
- Custody services
- Exchange services
- Lending & Borrowing services
- Management & Investment services
- Transfer & Settlement services
Each licensed firm is bound to the specific activities it is authorised for, and must comply with both VARA's general (compulsory) rulebooks and the rulebook for each activity it conducts.
The two-stage licensing process
VARA licensing runs in two stages, and applications are submitted via the Dubai Department of Economy & Tourism (DET) or a Dubai free-zone authority:
| Stage | What it covers |
|---|---|
| 1 · Initial Approval (ATI) | Approval to Incorporate / establish — lets the entity be formed and proceed toward licensing |
| 2 · Full VASP Licence | Detailed compliance, governance, technology, risk-management, AML/CFT, financial, operational and business documentation |
Capital, substance and the key restriction
Capital requirements vary by activity — higher-risk activities such as custody carry higher thresholds than, say, advisory. Applicants must establish a genuine physical presence in Dubai (leased or owned premises) and demonstrate fit-and-proper governance, robust technology and AML/CFT controls. Critically, a firm may not begin operations until the full VASP licence is granted — Initial Approval alone does not authorise live activity. There is no fixed approval timeline; a well-prepared application moves materially faster than an underprepared one.
Frequently asked questions
Who needs a VARA licence?
Any entity carrying on a regulated virtual-asset activity — exchange, custody, broker-dealer, advisory, lending/borrowing, management/investment or transfer/settlement — in or from Dubai, outside the DIFC.
Does VARA cover the DIFC?
No. The DIFC has its own virtual-asset regime under the DFSA. VARA covers the rest of Dubai, including other free zones.
Can I operate after Initial Approval?
No. Initial Approval allows you to incorporate and progress, but live operations require the full VASP licence.
How long does licensing take?
There is no fixed timeline — it depends on the activities sought and how well-prepared the compliance, governance and technical documentation is.
Official sources
- Virtual Assets Regulatory Authority (VARA) — rulebooks and licensing
- Legal basis — Law No. (4) of 2022 regulating virtual assets in the Emirate of Dubai
- Dubai Department of Economy & Tourism (DET) — submission channel
This guide is general information prepared by ARM Management and is current as at June 2026. VARA's rulebooks, capital thresholds and procedures are detailed and subject to change. Confirm requirements against the official VARA sources, or with an advisor, before applying.
Plan your VARA application properly.
ARM Management advises virtual-asset businesses on activity scoping, structuring and the VARA two-stage application, alongside wider GCC and EU regulatory strategy. Begin with a confidential conversation.