VARA License in Dubai with Application Support

Is Your Virtual Asset Business a Fit for Dubai VASP Licensing?

Potential Fit
A client profile involving regulated customer services in or from Dubai outside DIFC, such as brokerage, exchange or custody.

Separate Assessment Needed
Software-only models and own-account trading require assessment of the actual activities. Company registration alone does not authorize regulated services. The territorial scope excludes DIFC.

Which Permissions Should Your VARA License Cover?

Your license must cover every regulated service you provide. Several activities can share one license, but custody requires a separate company and a standalone license.

Your Business Plan	What to Apply For	Company Structure
One service, such as exchange	Permission for that activity	One company
Exchange and brokerage	Permissions covering both activities	One company may hold both
Custody only	Standalone custody license	Dedicated custody company
Custody alongside other services	Custody license plus permissions for the other services	Separate companies for custody and other services

These arrangements follow the requirements for combining activities and separating custody.

Which Virtual Asset Activities Match Your Business?

These VASP business models map to the service activities in Schedule 1.

Business Model	Regulated Activity
Personalized investment recommendations	Advisory Services
Arranging orders or dealing for customers	Broker-Dealer Services
Safekeeping customers’ assets	Custody Services
Operating exchange or order-book functions	Exchange Services
Lending assets subject to repayment	Lending and Borrowing Services
Virtual asset management, including portfolios or staking	VA Management and Investment Services
Moving or settling assets for customers	VA Transfer and Settlement Services

Token issuance is assessed separately under the VA Issuance Rulebook. Category 1 issuance requires a license. Other categories have different conditions. Tokenization requires assessment of the token’s rights and structure alongside any service permissions.

What Determines the VARA License Cost?

The cost estimate depends on the activities, company structure and preparation required. Agree the service scope before work begins.

Budget Component	What Determines It
Professional support	Documents to draft or review, existing materials and regulator responses
Regulatory charges	Application fee, additional activity permissions and annual supervision
Company setup	Mainland or free-zone establishment and premises
Operational readiness	Staffing, systems, insurance and external providers

Capital and liquidity requirements must be assessed separately from fees. The official fee schedule sets regulatory charges, while professional fees depend on the agreed work.

How Does the Application Process Work?

The VARA licensing process has two application stages for new firms:

1. Approval to Incorporate. The applicant submits an Initial Disclosure Questionnaire through Dubai Economy and Tourism or the relevant free zone. Gofaizen & Sherle supports preparation. Approval allows incorporation and operational setup, but not regulated operations.
2. License Application and Decision. The applicant submits detailed documents and readiness evidence. Our team supports submission and follow-up responses. The regulator reviews the file, may request interviews or additional documents, and decides whether to issue a license with operating conditions.

What Must You Prepare?

VARA license requirements depend on the activities and business model. For our initial assessment, provide your proposed services, target markets, ownership information and existing client documents.

The application file typically addresses:

• Ownership and management: corporate documents, beneficial owners, group structure, CVs and fit-and-proper evidence.
• Business and finances: business plan, financial forecast, funding sources, capital and liquidity arrangements.
• Governance: responsibilities, conflicts of interest, succession and wind-down plans.
• Risk and compliance: risk assessments, internal controls, AML/CFT policies and record keeping.
• Technology and continuity: cybersecurity, wallet security, data protection, business continuity and recovery plans.
• External relationships: outsourcing arrangements, customer terms and marketing controls, including target-country restrictions.

The official application checklist is non-exhaustive. Supporting policies must reflect actual operations and providers. A template alone does not demonstrate that controls are implemented.

What Determines the Licensing Timeline?

The VARA license timeline depends on three work periods:

1. Document Preparation. Gofaizen & Sherle prepares the agreed documents using your business information. Missing records or inconsistent financial assumptions can delay completion.
2. Operational Setup. Your company recruits staff, arranges funding and implements systems and controls. Timing depends on what is already ready.
3. Regulatory Assessment. The regulator reviews the file and may request interviews, explanations or revised documents. These requests affect the application timeline independently of preparation.

What Makes Up the VARA Regulatory Framework?

The Dubai virtual assets regime combines the Virtual Assets and Related Activities Regulations 2023 with mandatory rulebooks and activity-specific rulebooks.

The four compulsory VARA rulebooks are:

• Company Rulebook
• Compliance and Risk Management Rulebook
• Technology and Information Rulebook
• Market Conduct Rulebook

The 2024 Marketing Regulations separately govern relevant promotions.

What Is the Current Regulatory Status?

The requirements are operative. As checked on September 24, 2026, the current Company Rulebook, Compliance and Risk Management Rulebook, and VA Issuance Rulebook show an effective date of June 19, 2025. Applicants must also check subsequent regulatory notices before filing.

Where Does Each Regulator Apply?

VARA jurisdiction covers Dubai mainland and free zones outside DIFC. Other locations require a separate regulatory assessment.

Location	Authority to Assess
Dubai mainland and free zones outside DIFC	Virtual Assets Regulatory Authority
DIFC	DFSA
ADGM	FSRA
UAE federal framework outside financial free zones	Capital Market Authority, formerly SCA, alongside applicable local arrangements

What Does Ongoing Compliance Require?

VARA compliance involves ongoing obligations under the Compliance and Risk Management Rulebook, including:

• AML/CFT controls, customer due diligence and sanctions screening.
• Transaction monitoring, suspicious-transaction reporting and applicable Travel Rule duties.
• Governance, audits, regulatory reporting and record keeping.
• Client-asset safeguards, outsourcing oversight and updated policies.

What Are the Consequences of Non-Compliance?

VARA enforcement powers include:

• Orders to remedy breaches or stop activities.
• License restrictions, suspension or revocation.
• Fines and additional supervision.

To manage regulatory risk, check permissions and outstanding conditions before launch or expansion.

How Should You Compare Alternative Routes?

For VARA vs ADGM or DIFC, compare how each framework treats your services and assets.

Alternative	Regulatory Assessment	What to Establish Before Choosing
ADGM	Financial-services permissions under the FSRA framework	Whether the proposed activities and assets fit that framework
DIFC	DFSA financial-services permissions involving Crypto Tokens	Whether the activity is a financial service and the tokens meet applicable requirements

Compare entity setup, capital, staffing and controls for the proposed business in each location.

A license does not automatically authorize every activity throughout the UAE or abroad.