VARA welcomes Virtual Asset firms to be regulated in Dubai
VARA's regulatory regime is founded on establishing clear guardrails to foster proactive and responsible market participation. VARA welcomes firms from the UAE or overseas that share VARA’s principles, to apply for its Virtual Asset Service Provider Licence [VASP Licence]. Any firm seeking to carry on Virtual Asset activities in or from Dubai [excluding DIFC] has a legal obligation to be licensed by VARA prior to commencing operations.
Application submissions can be made through Dubai Economy and Tourism [DET] for mainland firms, or any Dubai Freezones [FZ] in the Emirate of Dubai [excluding DIFC].
For more information about DET and Free Zones, please visit: Why Dubai section 
Apply for a VARA Licence [New Firms]
Applying for a VASP Licence is completed in two stages: First, application for an Approval to Incorporate [ATI] to establish a legal entity and to commence operational setup, then an application for VASP Licence.
For firms carrying on VA Activities in or from Dubai [excluding DIFC] prior to 7 February 2023, please see the following section: Apply for a VARA Licence [Existing Firms]
Stage 1
- Submit an Initial Disclosure Questionnaire [IDQ] to Dubai Economy & Tourism [DET] or a relevant Free Zone [FZ].
- Provide additional documentation as required. Such documentation will include a business plan and details of the firm’s beneficial owners and senior management.
- Pay initial fees required to commence the application review [typically 50% of the licence application fee].
- Receive an Approval to Incorporate [ATI] to finalise the firm’s legal incorporation and to complete operational set-up including office space rental, employee on-boarding, and so forth.
NOTE: At this point, the firm is not permitted to carry on Virtual Asset activities
VARA reserves the right not to issue an Approval to Incorporate [ATI] should the firm’s activities fall outside the regulatory perimeter or where a firm may not meet appropriate standards to be regulated.
Stage 2
Following receipt of an Approval to Incorporate [ATI] a firm can apply for a full VASP Licence as follows:
- Prepare and submit documentation according with the guidance provided by VARA upon receipt of the Approval to Incorporate [ATI].
- Receive feedback directly from VARA on the submission which may include meetings, interviews, and submission of further documentation.
- Pay remaining portion of application licence fees and first year’s supervision fees.
- Receive a VASP Licence, which may be subject to operational conditions.
Details of VARA’s Licensing and Supervision fees can be found in Schedule B of the Virtual Assets and Related Activities Regulations 2023.
Details of VARA’s Capital Requirements can be found in Part IV of the Company Rulebook.
VARA reserves the right not to issue a VASP Licence should the firm’s activities fall outside the regulatory perimeter or where a firm may not meet appropriate standards to be regulated.
Apply for a VARA Licence [Existing Firms]
Supporting the entire Dubai virtual asset ecosystem is a high priority for VARA as it plays a crucial role in ensuring economic stability and fostering growth.
To facilitate a smooth transition for firms carrying out VA activities prior to February 2023 (Legacy VA Operators), VARA has extended an invitation to all such firms to apply for the Dubai Legacy Programme. This program enables organisations to seamlessly transition to VARA's regulatory framework. In collaboration with the Department of Economy and Tourism and the Free Zone Council, VARA has conducted various training sessions and awareness programs in this regard.
As part of the regulatory process, VARA has requested all Legacy VA Operators in Dubai to register by completing an Initial Disclosure Questionnaire (IDQ). VASPs that receive an Application Acknowledgment Notice (AAN) can then proceed to obtain the Legacy Operating Permit (LOP) or No Objection Certification (NOC).
The Legacy Operating Permit offers VASPs the opportunity to transition to the full VA regulatory regime over a limited period of time, assuming they meet the baseline regulatory requirements. It comes with additional benefits, including up to a 50% discount on licensing fees and reduced capital requirements. This permit is valid for 12 months, allowing VASPs the necessary time to develop and comply with full licensing and supervision requirements.
For VASPs who missed the deadline to apply for an AAN, immediate application for the Legacy Operating Permit (LOP) is advised to avoid any potential disciplinary actions. VARA remains committed to facilitating a smooth and supportive regulatory transition for all Legacy VA Operators in Dubai.
Legacy Operating Permit
- The permit allows the VASPs to transition to the full VA regulatory regime in a gradual manner and provides relief in terms of discounted licencing fees and capital requirements,
- You may apply through Department of Economy and Tourism, or your preferred Free Zone as your commercial licensor.
Applicable Rulebooks for a Virtual Asset Service Provider Licence Application
All firms applying for a VARA Virtual Asset Service Provider Licence must comply with four Compulsory Rulebooks:
In addition, firms must comply with Rulebooks for the VA activities that they are licensed for:
Virtual Asset Service Provider Licence Application Documentation
The following is a non-exhaustive list of documents required for a Virtual Asset Service Provider Licence application. Through the process of licensing VARA may require further documentation to be supplied.
1Certificate of entity incorporation
2List of Ultimate Beneficial Owner(s) (UBOs)
3Fit and Proper confirmations
4Source of funds evidence
5Organisational structure
6Governance framework
7Local entity website
8Key personnel details:
a Job descriptions
b CVs
c Passport copies
9Regulatory Business Plan
10Financial projections
11Group-level and entity-level financial statements
12Proof of paid-up capital
13Available capital locked-up
14Reserve account report
15Insurance certificate(s)
16Succession plan
17Wind-down plan
18Close links / associated entities analysis