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.
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
| Situation | What VARA publishes |
|---|---|
| Carrying on virtual asset activities in or from Dubai | A VASP licence is required before operations start |
| Operating in DIFC | Outside VARA's jurisdiction; VARA covers Dubai's mainland and free zones except DIFC |
| Category 2 virtual asset issuance | Needs prior VARA approval rather than a licence |
| Proprietary trading | Must be registered where 30-day rolling trading volume exceeds AED 1 billion |
| Marketing by unlicensed VASPs | Possible 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 activity | Licence application fee | Annual supervision fee |
|---|---|---|
| VA Advisory Services | AED 40,000 | AED 80,000 |
| VA Transfer and Settlement Services | AED 40,000 | AED 80,000 |
| VA Broker-Dealer Services | AED 100,000 | AED 200,000 |
| VA Custody Services | AED 100,000 | AED 200,000 |
| VA Exchange Services | AED 100,000 | AED 200,000 |
| VA Lending and Borrowing Services | AED 100,000 | AED 200,000 |
| VA Management and Investment Services | AED 100,000 | AED 200,000 |
| VA Issuance – Category 1 | AED 100,000 | AED 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)
| Item | Fee |
|---|---|
| Licence update, per request | AED 500 |
| Licence withdrawal when winding down Dubai operations | AED 10,000 |
| No-objection certificate for proprietary traders | AED 1,000 a year |
| Whitepaper submission, or whitepaper amendment review | AED 5,000 plus up to AED 50,000 for detailed review (maximum AED 55,000) |
| Legal review for a regulatory perimeter opinion | Up 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
| Business | Application fee | First-year supervision | VARA total |
|---|---|---|---|
| Advisory firm | AED 40,000 | AED 80,000 | AED 120,000 |
| Transfer and settlement provider | AED 40,000 | AED 80,000 | AED 120,000 |
| Exchange | AED 100,000 | AED 200,000 | AED 300,000 |
| Custodian | AED 100,000 | AED 200,000 | AED 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 to | Rulebooks |
|---|---|
| All VASPs | Company Rulebook (including capital and prudential requirements); Compliance and Risk Management; Technology and Information; Market Conduct |
| By activity | Advisory 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.
| Route | Points to weigh | Guide |
|---|---|---|
| Dubai mainland (DET) | Mainland licence costs and office; direct access to the Dubai market | Dubai mainland guide |
| DMCC | DMCC lists a Crypto Centre package at AED 31,000 including a DMCC licence and co-working access | DMCC guide |
| Other Dubai free zones | Check that the zone accepts virtual asset applicants before choosing | Free zone guide |
| DIFC | Outside VARA's jurisdiction; its own regime applies | DIFC 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
Build the company behind your VASP licence.
Explore connected PROXPAT services that support the same client journey.
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
More in Licences and Compliance
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.