How to Get a VARA Licence in Dubai: Requirements, Costs and Process (2026)
A VARA licence is a Virtual Asset Service Provider (VASP) licence issued by the Virtual Assets Regulatory Authority — the sole regulatory body governing crypto and digital asset businesses across Dubai's mainland and free zones, excluding DIFC. Any business providing regulated virtual asset services in or from Dubai must hold a VARA licence before commencing operations. This is a legal requirement under Dubai Law No. 4 of 2022, not a recommendation.
| Quick Facts | 2026 Details |
|---|---|
| Governing authority | VARA — Virtual Assets Regulatory Authority |
| Legal basis | Dubai Law No. 4 of 2022 |
| Process | Two stages: Approval to Incorporate (ATI) → Full VASP Licence |
| Application route | Dubai Economy & Tourism (DET) or any Dubai Free Zone (excluding DIFC) |
| Timeline | 4 to 7 months for prepared applications |
| Cost range | AED 250,000 to AED 600,000+ (first year, all-in) |
| Physical office | Mandatory |
| DIFC covered | No — DIFC falls under the DFSA |
What Is VARA?
VARA was established under Dubai Law No. 4 of 2022 as the world's first standalone regulatory authority dedicated exclusively to virtual assets. It operates under the governance of the Dubai World Trade Centre Authority and holds legal personality and financial autonomy. VARA regulates all virtual asset service providers across Dubai's mainland and free zones, working in coordination with the UAE Central Bank and the Securities and Commodities Authority at the federal level.
The authority's core objective is to create a secure, transparent, and innovation-friendly environment for virtual asset businesses while protecting investors and ensuring compliance with international standards, including FATF requirements.
Who Needs a VARA Licence?
Any business that commercially provides regulated virtual asset services in or from Dubai needs a VARA licence. This covers crypto exchanges, OTC trading desks, custody and wallet providers, lending and borrowing platforms, asset management firms dealing in virtual assets, token issuers, NFT marketplace operators, advisory firms, and transfer and settlement service providers.
The requirement applies to Dubai-incorporated entities and to foreign companies operating in or targeting the Dubai market. Individuals holding virtual assets for personal use do not require a licence. Proprietary traders with a cumulative 30-day rolling volume above USD 250 million must register with VARA even if they do not serve external clients.
Businesses operating exclusively within DIFC are regulated by the DFSA under a separate framework and do not fall under VARA's jurisdiction.
Licence Categories
VARA does not issue a single blanket crypto licence. Licences are issued per regulated activity, and a business offering multiple services must satisfy the requirements for each activity separately. The eight regulated activity categories are Advisory Services, Broker-Dealer Services, Custody Services, Exchange Services, Lending and Borrowing Services, Management and Investment Services, Transfer and Settlement Services, and VA Issuance Services.
Most businesses entering Dubai's virtual asset market start with the Advisory Services licence, which carries the lowest application fee and minimum capital requirement. Exchange licences carry the highest cost and compliance burden and are suited for established platforms with significant operational infrastructure already in place.
VARA Licence Requirements
VARA's requirements reflect its position as one of the most rigorous virtual asset regulators globally. Meeting these before applying is essential — incomplete applications are the primary cause of delays and rejections.
Every applicant must have a functioning compliance infrastructure in place. This means a documented AML policy aligned with UAE AML Law (Federal Decree-Law No. 20 of 2018) and FATF recommendations, a KYC framework covering client onboarding and ongoing monitoring, a sanctions screening policy, and a counter-terrorism financing procedure. These cannot be drafted after the ATI is submitted — they must be operational and evidenced at the Full VASP Licence stage.
All directors, senior managers, and key officers must satisfy VARA's fit-and-proper assessment, which evaluates professional background, regulatory history, and financial integrity. VARA also requires the business to demonstrate technology and cybersecurity readiness in line with its Technology and Information Rulebook — covering data protection, business continuity, and incident response.
A physical office in Dubai is mandatory. Virtual offices do not meet VARA's operational presence requirement.
Mandatory Officer Appointments
Before VARA will issue a Full VASP Licence, five key officers must be appointed and individually approved: a Compliance Officer, a Money Laundering Reporting Officer (MLRO), a Chief Risk Officer, a Chief Information Security Officer, and a Chief Technology Officer. Each role has specific qualification criteria, and VARA assesses every candidate individually through a fit-and-proper review.
The MLRO must be UAE-resident. For smaller applicants, some roles may be combined subject to VARA's approval and the absence of conflict of interest. Identifying and onboarding qualified candidates typically takes two to four months, so this should begin in parallel with business plan preparation — not after the ATI is received.
The Two-Stage Licensing Process
VARA's licensing process runs in two mandatory stages. No virtual asset activity is permitted between ATI approval and Full VASP Licence issuance.
Stage 1 — Approval to Incorporate (ATI). The applicant submits an Initial Disclosure Questionnaire (IDQ) through DET or a chosen Dubai free zone, along with a comprehensive Regulatory Business Plan, beneficial owner details, and director and management documentation. The initial application fee — typically 50% of the full licence fee — is paid at this stage. On approval, the ATI authorises the company to incorporate and begin operational setup including office leasing and staff onboarding. The ATI does not permit any virtual asset activity.
Stage 2 — Full VASP Licence. After incorporation and setup, the applicant submits the Full VASP Licence application with evidence of completed office setup, confirmed officer appointments, finalised compliance documentation, and capital adequacy evidence. The remaining fee balance is paid. VARA reviews the application and, on approval, issues the Full VASP Licence. The company is then listed on VARA's public register of licensed VASPs.
Well-prepared applications complete this process in four to seven months. Applications with compliance gaps, unconfirmed officers, or incomplete documentation routinely take twelve months or longer.
Costs and Fees in 2026
VARA licence fees are governed by Cabinet Resolution No. 83 of 2025. Application fees start from approximately AED 40,000 for Advisory Services and exceed AED 200,000 for Exchange Services. Annual supervision fees apply on top of the initial application fee and must be paid each year to maintain the licence.
Minimum capital requirements range from AED 100,000 for advisory activities to AED 1,000,000 or more for exchange and custody activities. These capital levels must be maintained on an ongoing basis, not just at the point of application.
The all-in first-year cost — covering VARA application fees, office setup, officer appointments, compliance framework build-out, company incorporation, and professional advisory — typically falls between AED 250,000 and AED 600,000 for a single-activity licence. Multi-activity exchange licences regularly exceed AED 1,000,000 in first-year expenditure.
Penalties for Operating Without a Licence
Operating regulated virtual asset services in Dubai without a valid VARA licence is a serious breach. Consequences include financial penalties under Cabinet Resolution No. 111 of 2022, forced cessation of operations, and public enforcement notices published on VARA's website. In cases involving fraud or market manipulation, criminal referral is possible. VARA actively monitors the market and has issued enforcement actions against multiple unlicensed operators since 2023.
Start Your VARA Licence Application
The VARA licensing process rewards preparation. Businesses that arrive with a complete Regulatory Business Plan, confirmed officer candidates, and a structured compliance framework move through the process significantly faster. Those who begin without this foundation face costly delays.
RAS Corporate Advisors advises virtual asset businesses across every stage of the VARA licensing process — from jurisdiction selection and company formation through to Regulatory Business Plan preparation, officer appointment support, compliance framework structuring, and application submission management.
Call: +971 4589 6885 Email: info@rca.ae Contact RAS Corporate Advisors
Related Services: Mainland Company Formation · Freezone Company Formation · Tax Planning and Structuring · Corporate and Commercial Transactions
Frequently Asked Questions
How long does it take to get a VARA licence? Four to seven months for well-prepared applications. Up to twelve months where compliance gaps or officer vacancies exist.
How much does a VARA licence cost? First-year all-in costs typically range from AED 250,000 to AED 600,000 depending on the activity and operational setup required.
Can I operate while my application is pending? No. Virtual asset activities are not permitted between ATI approval and Full VASP Licence issuance. Legacy operators may be eligible for a Legacy Operating Permit (LOP) to continue transitionally.
Does VARA cover DIFC businesses? No. DIFC-based virtual asset businesses are regulated by the DFSA under a separate framework.
What happens if I operate without a licence? Financial penalties, forced closure, and public enforcement action. VARA actively monitors and acts against unlicensed operators.
