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VARA Crypto Licence Dubai

Plan a virtual asset business in Dubai around VARA's two-stage licensing process. PROXPAT handles the company formation, documents, office and visas while your legal and compliance advisers lead the VARA submissions.

Page last updated: . Requirements, government fees and processing times are set by the relevant UAE authority and can change.

PROXPAT is an independent private consultancy and is not affiliated with or endorsed by any UAE government authority. All approvals, government fees and processing times are determined by the relevant UAE authority and are subject to change. For official requirements and fees, see the Virtual Assets Regulatory Authority (VARA).

Virtual asset business preparing a VARA licence application in Dubai

VARA Crypto Licence in Dubai: Virtual Asset Service Provider Licensing

The Virtual Assets Regulatory Authority (VARA) regulates virtual asset activities across Dubai's mainland and free zones, except inside the Dubai International Financial Centre (DIFC). VARA states that any firm seeking to carry on virtual asset activities in or from Dubai, outside DIFC, must be licensed before it starts operating.

Licensing runs in two stages. First comes an Approval to Incorporate, which lets you set up the company. Then comes the full Virtual Asset Service Provider (VASP) licence. Applications enter through the Department of Economy and Tourism (DET) for the mainland, or through a Dubai free zone.

Please note: this page summarises what VARA publishes about licensing and fees. It is not legal or regulatory advice. VARA's Regulations and Rulebooks govern, and PROXPAT works alongside your legal and compliance advisers rather than replacing them.

Who Needs a VARA Licence

SituationWhat VARA publishes
Carrying on virtual asset activities in or from DubaiA VASP licence is required before operations start
Operating in DIFCOutside VARA's jurisdiction; VARA covers Dubai's mainland and free zones except DIFC
Category 2 virtual asset issuanceNeeds prior VARA approval rather than a licence
Proprietary tradingMust be registered where 30-day rolling trading volume exceeds AED 1 billion
Marketing by unlicensed VASPsPossible with the relevant permits, but they may not onboard Dubai residents, and marketing must state that the products are not available to Dubai residents

The Eight Licensed Activities and Their Fees

VARA licenses eight activities. Schedule 2 of the Virtual Assets and Related Activities Regulations 2023 sets the application fee and the annual supervision fee for each:

Licensed activityLicence application feeAnnual supervision fee
VA Advisory ServicesAED 40,000AED 80,000
VA Transfer and Settlement ServicesAED 40,000AED 80,000
VA Broker-Dealer ServicesAED 100,000AED 200,000
VA Custody ServicesAED 100,000AED 200,000
VA Exchange ServicesAED 100,000AED 200,000
VA Lending and Borrowing ServicesAED 100,000AED 200,000
VA Management and Investment ServicesAED 100,000AED 200,000
VA Issuance – Category 1AED 100,000AED 200,000

Other Fee Rules in Schedule 2

  • Adding activities. An extension fee of 50% of the relevant licence application fee applies to each additional activity.
  • No payment, no processing. VARA does not process an application until the fees are received.
  • Risk-based supervision fees. VARA may charge extra supervision fees based on factors such as market share, client base, business complexity, compliance history or the regulatory resources a firm needs.
  • Issuance approvals. VARA may charge for Category 1 issuance approvals and whitepaper submissions.
  • Other authorities. VARA's fees are separate from charges by other authorities, including the DET or free zone licence itself.

Further fees VARA announced (June 2023)

ItemFee
Licence update, per requestAED 500
Licence withdrawal when winding down Dubai operationsAED 10,000
No-objection certificate for proprietary tradersAED 1,000 a year
Whitepaper submission, or whitepaper amendment reviewAED 5,000 plus up to AED 50,000 for detailed review (maximum AED 55,000)
Legal review for a regulatory perimeter opinionUp to AED 4,000

The Two-Stage Licensing Process

Stage 1: Approval to Incorporate

Step 1: Submit the Initial Disclosure Questionnaire through DET or your chosen Dubai free zone (not DIFC).

Step 2: Provide the business plan and details of beneficial owners and senior management.

Step 3: Pay the initial fees, which VARA says are typically 50% of the licence application fee.

Step 4: Receive the Approval to Incorporate. You may now set up the legal entity, rent office space and hire staff, but you may not start operating.

Stage 2: VASP Licence

Step 1: Submit the licence documentation following VARA's guidance.

Step 2: Respond to VARA's feedback, which may include meetings, interviews and further documents.

Step 3: Pay the remaining application fee and the first year's supervision fee.

Step 4: Receive the VASP licence, which may carry operational conditions.

First-Year Regulatory Fees: Examples

BusinessApplication feeFirst-year supervisionVARA total
Advisory firmAED 40,000AED 80,000AED 120,000
Transfer and settlement providerAED 40,000AED 80,000AED 120,000
ExchangeAED 100,000AED 200,000AED 300,000
CustodianAED 100,000AED 200,000AED 300,000

These totals cover VARA's fees only. Company formation, office, staff, visas and professional advisers are separate, and VARA may add risk-based supervision fees. Budget for the full year before submitting the questionnaire.

The Rulebooks You Will Operate Under

VARA publishes rulebooks that apply to all licensed firms, plus rulebooks for each activity:

Applies toRulebooks
All VASPsCompany Rulebook (including capital and prudential requirements); Compliance and Risk Management; Technology and Information; Market Conduct
By activityAdvisory Services; Broker-Dealer Services; Custody Services; Exchange Services; Lending and Borrowing Services; Management and Investment Services; Transfer and Settlement Services; VA Issuance

Your capital, compliance framework and technology controls must be ready against these rulebooks before Stage 2. That work is for your legal and compliance advisers.

Mainland or Free Zone for a VASP?

VARA accepts applications through DET for mainland companies and through Dubai's free zones other than DIFC. The licensing jurisdiction decides your company costs, office options and visa quota, while VARA's fees stay the same.

RoutePoints to weighGuide
Dubai mainland (DET)Mainland licence costs and office; direct access to the Dubai marketDubai mainland guide
DMCCDMCC lists a Crypto Centre package at AED 31,000 including a DMCC licence and co-working accessDMCC guide
Other Dubai free zonesCheck that the zone accepts virtual asset applicants before choosingFree zone guide
DIFCOutside VARA's jurisdiction; its own regime appliesDIFC guide

Readiness Checklist Before the Questionnaire

A business plan describing the activities, clients and markets

Details of every beneficial owner

Senior management identified, with CVs

A clear choice of licensed activities (each extra one adds a 50% extension fee)

A budget covering VARA fees, company setup, office and staff

Legal and compliance advisers engaged on the rulebooks

Attested corporate documents for any corporate shareholders

An office and hiring plan ready to start after the Approval to Incorporate

How PROXPAT Helps

We handle the company-side work around your VARA application: jurisdiction comparison, company formation with DET or a free zone after the Approval to Incorporate, attested shareholder documents, office and Ejari, establishment card, and visas for management and staff. We do not advise on VARA rulebook compliance; we coordinate with your legal and compliance advisers so the corporate file and the regulatory file match.

See certificate attestation, establishment card and business setup costs.

Frequently Asked Questions

VARA states that any firm seeking to carry on virtual asset activities in or from Dubai, excluding DIFC, must be licensed by VARA before starting operations.

No. VARA regulates virtual assets across Dubai's mainland and free zones, except within DIFC.

Under Schedule 2, VA Advisory and VA Transfer and Settlement Services cost AED 40,000 to apply and AED 80,000 a year in supervision fees. The other licensed activities cost AED 100,000 and AED 200,000.

The first licensing stage. After the Initial Disclosure Questionnaire, business plan and ownership details are accepted, it allows the firm to set up its legal entity, office and staff, but not to begin operations.

VARA says initial fees, typically 50% of the licence application fee, are paid in the first stage. The remaining application fee and the first year's supervision fee are paid before the licence is issued.

Unlicensed VASPs may market in Dubai with the relevant permits, but they may not onboard Dubai residents, and their marketing must state that the products are not available to Dubai residents.

VARA requires proprietary trading to be registered when 30-day rolling trading volume exceeds AED 1 billion.

Schedule 2 sets an extension fee of 50% of the relevant licence application fee for each additional activity.
After the Licence

The licence is the start of the government work, not the end of it

Once the trade licence is issued, the sequence that actually lets you operate begins: the establishment card, the MOHRE and immigration files, your employee quota, then employee visas and work permits. After that it repeats every year — renewals, cancellations when people leave, and licence renewal and amendments.

Companies that would rather not build that function in-house put it on a monthly PRO retainer from AED 700, or use it per transaction. Government fees stay separate and itemised either way.

The first six months after incorporation

  • Establishment card issued through immigration
  • MOHRE file opened and e-signature completed
  • Employee quota checked before hiring
  • Offer letters, work permits and entry permits
  • Medical, Emirates ID and visa stamping
  • Corporate tax and VAT registration where they apply
See corporate PRO services

Plan the Company Behind Your VARA Licence

PROXPAT compares jurisdictions, forms the company after your Approval to Incorporate, prepares attested documents and handles office, establishment card and visas.