01
UAE VIRTUAL ASSET
LEGAL AND LICENSING
UAECRYPTOLAWFIRM
Dubai cityscape

Enabling visionary founders with expert legal guidance, regulatory clarity, and strategic support to thrive in the UAE's Web3 ecosystem.

VARA · Dubai

The VARA licence, from questionnaire to operational approval

Any business offering virtual asset services from Dubai needs a licence from the Virtual Assets Regulatory Authority. The category you apply for decides the capital, the staff and the controls VARA expects. We scope the right category, prepare every submission and manage the process until the licence is operational.

Licence categories

  • Advisory servicesAdvising on virtual asset investments, token structures and VA strategy.
  • Broker-dealer servicesReceiving and transmitting client orders, matching trades and dealing as principal.
  • Custody servicesSafekeeping and controlling virtual assets on behalf of clients.
  • Exchange servicesOperating a platform where virtual assets are bought, sold and exchanged.
  • Lending and borrowingLending virtual assets or taking them as collateral.
  • VA management and investmentManaging portfolios of virtual assets for clients, including funds.
  • Transfer and settlementMoving virtual assets between accounts and settling transactions.

What to expect

Regulator
Dubai Virtual Assets Regulatory Authority, for all of Dubai outside DIFC
Minimum capital
Set per activity in the VARA rulebooks as the higher of a fixed amount and a share of annual operating costs; confirmed for your category before you apply
Typical timeline
From a few months for advisory and broker-dealer categories to longer for exchange and custody, depending on readiness
Mandatory roles
Compliance Officer and Money Laundering Reporting Officer resident in the UAE, plus named senior management
Alternatives
ADGM (FSRA) in Abu Dhabi and DMCC crypto licences for certain activities; we assess which regulator fits your model

The four stages

  1. 01

    Initial Disclosure Questionnaire

    VARA reviews who you are, what you plan to do and your ownership. We prepare the IDQ, the business plan and the ownership chart with you.

  2. 02

    Initial approval

    VARA grants an initial approval that lets you incorporate the entity, open a bank account and prepare the operating documents. You cannot serve clients yet.

  3. 03

    Licensing submission

    Compliance manual, AML/CFT policies, technology and security framework, governance, capital proof and the mandatory staff appointments (Compliance Officer, MLRO).

  4. 04

    Operational approval

    Once VARA is satisfied the controls work in practice, the licence becomes operational and you may onboard clients within the approved activities.

Not sure which category or regulator you need?

A 30-minute call with a crypto regulatory lawyer settles the category, the entity and the realistic timeline before you spend on the application.