VARA licence in Dubai: who needs one, the process, fees and capital
If your business will offer crypto or other virtual-asset services in or from Dubai, it will generally need a licence from the Virtual Assets Regulatory Authority (VARA), subject to limited exemptions. This guide sets out who needs one, how the two-stage process works, and the fees and capital VARA publishes.
The short answer
- Who: generally, any business carrying out a regulated virtual-asset (VA) activity in or from Dubai — mainland or free zone, except DIFC — needs VARA authorisation first, subject to limited exemptions, and each activity must be covered by the licence.
- How: two stages — an Approval to Incorporate, applied for through the commercial licensor (the Department of Economy and Tourism or a Dubai free zone), then the Virtual Asset Service Provider (VASP) licence itself.
- Fees: VARA's published licence application fee is AED 40,000 or AED 100,000 for the first activity, with an extension fee for each additional activity, plus an annual supervision fee of AED 80,000 or AED 200,000 for each activity.
- Capital: minimum paid-up capital ranges from AED 100,000 (advisory) to AED 1,500,000 (an exchange without a VARA-licensed custodian); for most activities it is the higher of that amount or a percentage of fixed annual overheads, and Category 1 issuance follows its own rulebook.
Which activities need a VARA licence?
- Advisory services
- Broker-dealer services
- Custody services
- Exchange services
- Lending and borrowing services
- Virtual-asset management and investment services
- Virtual-asset transfer and settlement services
- Category 1 virtual-asset issuance
Some related cases are treated differently under the Regulations:
- Trading your own funds: VARA's FAQ says firms trading only their own funds, with no clients, do not need a licence at this time. Under the Regulations, an entity that actively invests USD 250 million or more (about AED 918 million) of its own portfolio in virtual assets within any rolling 30-day period must register with VARA, before investing or within three working days after; registration is not a licence and does not permit dealing in other people's assets.
- Professional exemption: registered lawyers, accountants and other professionally licensed business consultants may not need a licence where the virtual-asset activity is wholly incidental to their professional practice. They must remain authorised by their professional body to operate in Dubai and hold professional indemnity insurance, and VARA decides whether the exemption applies.
- Technology providers offering distributed-ledger technology services to other businesses, without carrying on any virtual-asset activity, may register with VARA voluntarily. Registration is not a licence; a provider that carries on a virtual-asset activity needs one.
- Category 2 issuance: VARA's FAQ says issuers of Category 2 virtual assets in Dubai must obtain VARA's prior approval.
How does the VARA licensing process work?
Stage 1 — Approval to Incorporate
- An Initial Disclosure Questionnaire is submitted to the Department of Economy and Tourism (for mainland companies) or the relevant Dubai free zone, with documents such as a business plan and details of beneficial owners and senior management.
- VARA's licensing page indicates an initial payment to start the review — typically 50% of the licence application fee.
- The Approval to Incorporate allows the company to be incorporated and operations to be prepared. VARA's licensing page notes that at this point the firm is not permitted to carry on virtual-asset activities. VARA may refuse an approval where activities fall outside its remit or standards are not met.
Stage 2 — VASP licence
- The full documentation is prepared in line with the guidance VARA provides — covering structure, governance, risk, compliance, technology and financials, including projections, paid-up capital and a wind-down plan.
- VARA may hold meetings and interviews and ask for more documents.
- If VARA is satisfied, the remaining licence fees and the first year's supervision fees are paid and the licence may be issued, possibly with operational conditions.
Licensees must comply with VARA's four compulsory rulebooks — Company; Compliance and Risk Management; Technology and Information; and Market Conduct — the current rulebook for each licensed activity, and other applicable laws and VARA directions. VARA's FAQ also notes that a limited liability company or free zone company is preferable (sole proprietorships are not accepted), that VASPs must have a physical presence in Dubai, that each VASP needs two full-time Responsible Individuals, and that the licence is renewed annually.
VARA licence fees
VARA publishes its fees in Schedule 2 of the Virtual Assets and Related Activities Regulations 2023 (current version, effective 19 June 2025). VA stands for virtual asset.
| Activity | Licence application fee (first activity) | Annual supervision fee (each activity) |
|---|---|---|
| Advisory Services | AED 40,000 | AED 80,000 |
| Broker-Dealer Services | AED 100,000 | AED 200,000 |
| Custody Services | AED 100,000 | AED 200,000 |
| Exchange Services | AED 100,000 | AED 200,000 |
| Lending and Borrowing Services | AED 100,000 | AED 200,000 |
| VA Management and Investment Services | AED 100,000 | AED 200,000 |
| VA Transfer and Settlement Services | AED 40,000 | AED 80,000 |
| Category 1 VA Issuance | AED 100,000 | AED 200,000 |
Where more than one activity is applied for, a licence extension fee of 50% of the lower licence application fee(s) is payable for each additional activity. The annual supervision fee is payable for every licensed activity, in advance. VARA may charge additional supervision fees based on a firm's risk profile, and its fees are separate from the commercial licensor's fees.
Paid-up capital
Under Part VI of VARA's Company Rulebook (current version, effective 19 June 2025), paid-up capital must be held at all times, at the following levels; percentages refer to fixed annual overheads:
| Activity | Paid-up capital |
|---|---|
| Advisory Services | AED 100,000 |
| Broker-Dealer Services | Using a VARA-licensed custodian (or another arrangement VARA approves): higher of AED 400,000 or 15%. Otherwise: higher of AED 600,000 or 25% |
| Custody Services | Higher of AED 600,000 or 25% |
| Exchange Services | Using a VARA-licensed custodian (or another arrangement VARA approves): higher of AED 800,000 or 15%. Otherwise: higher of AED 1,500,000 or 25% |
| Lending and Borrowing Services | Higher of AED 500,000 or 25% |
| VA Management and Investment Services | Using a VARA-licensed custodian (or another arrangement VARA approves): higher of AED 280,000 or 15%. Otherwise: higher of AED 500,000 or 25% |
| VA Transfer and Settlement Services | Higher of AED 500,000 or 25% |
| Category 1 VA Issuance | As set in the Virtual Asset Issuance Rulebook |
A firm licensed for several activities must hold the required capital for each one, reconciled monthly. The capital may be held in a trust account with a UAE-licensed bank, or as a surety bond with no end date from a UAE-authorised surety company, naming VARA as beneficiary, or in another way VARA specifies. Other prudential rules also apply, including net liquid assets of at least 1.2 times monthly operating expenses, insurance and, where relevant, reserve assets.
Where to set up, banking and tax
- Where: the commercial licensor can be the Department of Economy and Tourism or a Dubai free zone. For an IFZA company, see IFZA crypto licence; for the wider picture, see crypto business setup in the UAE.
- Banking: many UAE banks treat virtual-asset businesses as higher risk, so enhanced due diligence is likely, and account opening is at each bank's discretion. See bank account opening assistance.
- Tax: Corporate Tax and VAT registration and treatment are worth considering at the planning stage. See Corporate Tax.
Fees, capital levels and rulebooks change; the figures above are as published in the current versions cited, checked on 23 October 2026. We check the current published position (and, where relevant, with the commercial licensor) and send a written, itemised quote before you commit. Licensing decisions are made by VARA and the licensing authorities. ProBiz Setup is not affiliated with, endorsed by or regulated by VARA or any other authority named on this page, does not carry on or promote any virtual-asset activity, and cannot guarantee any approval, licence, timeline or bank account.
Sources: VARA, "Licence Applications" (vara.ae); Virtual Assets and Related Activities Regulations 2023 — Part IV.A Licensing Requirements and Schedule 2 Supervision and Authorisation Fees (rulebooks.vara.ae, current version dated 19 May 2025, effective 19 June 2025); VARA Company Rulebook — Part VI.B Paid-Up Capital and VI.C Net Liquid Assets (rulebooks.vara.ae, current version dated 19 May 2025, effective 19 June 2025); VARA licensing FAQ (vara.ae).
Working with us: five steps
Map your activities
We help you set out your planned activities against VARA's published activity definitions; where the position is unclear, we recommend confirming it with VARA or a licensed legal adviser.
Choose the commercial licensor
We compare suitable Dubai licensors for your activities and agree the proposed route with you before you apply.
Stage 1: Approval to Incorporate
We help prepare the Initial Disclosure Questionnaire and supporting documents for submission through the commercial licensor.
Stage 2: VASP licence
We help prepare the full application and coordinate responses to VARA's information requests, up to VARA's decision.
Bank, visas and tax
Bank account file, residence visas, and Corporate Tax and VAT registration as applicable; account opening is at the bank's discretion.
Frequently asked questions
Who needs a VARA licence in Dubai?
Generally, any business that wants to carry out a regulated virtual-asset activity in or from Dubai — such as exchange, broker-dealer, custody, advisory, lending and borrowing, management and investment, transfer and settlement, or Category 1 issuance — needs a VARA licence before it starts, subject to limited exemptions, and each activity must be covered by the licence. VARA covers the Emirate of Dubai — mainland and free zones — but not DIFC.
Can I start operating once I receive VARA's Approval to Incorporate?
No. The Approval to Incorporate lets you incorporate the company and prepare operations, but VARA's licensing page notes that at that point the firm is not permitted to carry on virtual-asset activities. Virtual-asset activities should not begin until the Virtual Asset Service Provider (VASP) licence is issued and any conditions attached to it are met.
How much does a VARA licence cost?
VARA's published fees (Schedule 2 of the Regulations, current version effective 19 June 2025) are a licence application fee of AED 40,000 or AED 100,000 for the first activity, an extension fee of 50% of the lower application fee for each additional activity, and an annual supervision fee of AED 80,000 or AED 200,000 for each licensed activity. On top of that come the commercial licence, paid-up capital, staff, compliance and professional costs, which depend on your plan.
Do I need a VARA licence to invest my own crypto?
VARA's FAQ says firms trading only their own funds, with no clients, do not need a VARA licence at this time. However, under the Regulations an entity that actively invests USD 250 million or more (about AED 918 million) of its own portfolio in virtual assets within any rolling 30-day period must register with VARA, before investing or within three working days after. Registration is not a licence and does not permit dealing in other people's assets.
Does VARA regulate crypto businesses in DIFC or Abu Dhabi?
No. VARA's remit is the Emirate of Dubai — its mainland and free zones — excluding DIFC. DIFC and Abu Dhabi Global Market (ADGM) have their own financial regulators, and virtual-asset activity elsewhere in the UAE outside Dubai is generally regulated at federal level, so the route depends on where you set up.
Planning a VARA-regulated business?
Book a short online meeting. We'll review your planned activities, discuss the likely licensing route and send a written quote.