VARA Licence Dubai: Application & Readiness Guide
Identify the regulated activity, prepare the application and distinguish VARA permission from company formation, capital and operating costs.
Start with the activity and jurisdiction
VARA regulates virtual asset activities in and from Dubai, including its free zones, except DIFC. DIFC/DFSA and ADGM/FSRA have separate frameworks. A commercial trade licence is not permission to operate a regulated exchange, brokerage or custody business. Token issuance must be assessed under the applicable issuance rules.
Prepare a licensing and readiness file
Confirm the application sequence with VARA and the relevant commercial licensing authority. Prepare a clear business model, ownership and source-of-funds evidence, governance arrangements, qualified personnel, compliance policies and a technology and security plan tailored to the proposed activity.
- Identify each regulated activity before selecting a formation package.
- Assess AML/CFT, customer due diligence, sanctions screening and reporting.
- Document custody and client-asset controls where applicable.
- Assess capital, liquidity, insurance and operational requirements separately.
- Do not begin regulated activity before the necessary permission is in place.
Fees and paid-up capital are different
The following figures are VARA regulatory fees in UAE dirhams (AED), checked against the official fee schedule on 20 October 2026. They are not all-inclusive company setup prices.
| Regulated VA activity | Application fee (one activity) | Annual supervision fee (per activity) |
|---|---|---|
| Advisory Services | AED 40,000 | AED 80,000 per year |
| VA Transfer and Settlement Services | AED 40,000 | AED 80,000 per year |
| Broker-Dealer Services | AED 100,000 | AED 200,000 per year |
| Custody Services | AED 100,000 | AED 200,000 per year |
| Exchange Services | AED 100,000 | AED 200,000 per year |
| Lending and Borrowing Services | AED 100,000 | AED 200,000 per year |
| VA Management and Investment Services | AED 100,000 | AED 200,000 per year |
| Category 1 VA Issuance | AED 100,000 | AED 200,000 per year |
Example, advisory only: AED 40,000 application + AED 80,000 annual supervision = AED 120,000 in these two regulatory charges. This excludes required capital, company incorporation, premises, salaries, compliance and any other applicable charges. It is not a complete first-year quote.
Source: VARA Schedule 2: Supervision and Authorisation Fees. ADGM/FSRA and DIFC/DFSA have separate fee schedules; the AED figures above must not be applied to those jurisdictions.
Component 2: Minimum Capital Requirements
VARA's Company Rulebook sets the following paid-up capital requirements, checked on 20 October 2026. For overhead-linked rows, take the higher amount, not the lower amount. All fixed amounts below are in AED; percentages apply to fixed annual overheads.
| Regulated VA activity | Paid-up capital requirement |
|---|---|
| Advisory Services | AED 100,000 |
| Broker-Dealer Services, qualifying custody arrangement | Higher of AED 400,000 or 15% of fixed annual overheads |
| Broker-Dealer Services, otherwise | Higher of AED 600,000 or 25% of fixed annual overheads |
| Custody Services | Higher of AED 600,000 or 25% of fixed annual overheads |
| Exchange Services, qualifying custody arrangement | Higher of AED 800,000 or 15% of fixed annual overheads |
| Exchange Services, otherwise | Higher of AED 1,500,000 or 25% of fixed annual overheads |
| Lending and Borrowing Services | Higher of AED 500,000 or 25% of fixed annual overheads |
| VA Management and Investment Services, qualifying custody arrangement | Higher of AED 280,000 or 15% of fixed annual overheads |
| VA Management and Investment Services, otherwise | Higher of AED 500,000 or 25% of fixed annual overheads |
| VA Transfer and Settlement Services | Higher of AED 500,000 or 25% of fixed annual overheads |
| Category 1 VA Issuance | As specified in the VA Issuance Rulebook or its annexes |
Calculation example: an exchange outside that custody condition with AED 8,000,000 in fixed annual overheads calculates 25% × AED 8,000,000 = AED 2,000,000. Since this exceeds the AED 1,500,000 floor, its requirement under this formula is AED 2,000,000, not AED 1,500,000.
Capital must be maintained in the manner required by VARA. Multiple licensed activities have separate capital calculations under the rulebook; other prudential obligations, including net liquid assets, insurance and reserves where applicable, must also be assessed. ADGM/FSRA and DIFC/DFSA use their own prudential frameworks.
Source: VARA Company Rulebook, Part VI.B: Paid-Up Capital.
Timing and application outcomes
There is no guaranteed approval period. Timing depends on the activity, application completeness, regulator questions and operational readiness. Do not rely on an old provisional/MVP/FMP-stage description as the current application checklist; confirm the live process with VARA.
Tax and banking
Under the standard UAE Corporate Tax regime, taxable income above AED 375,000 is subject to 9% tax. Free-zone treatment is conditional, and crypto gains should not be described as universally tax-exempt. Bank acceptance is a separate due-diligence decision and is not guaranteed by incorporation or regulatory permission.
Sources and next steps
The fee and capital schedules above were reviewed on 20 October 2026. Confirm the current rulebooks before committing funds. Read the full crypto budget guide and jurisdiction comparison, or discuss your business model.
Two Pillars Advisory is an independent consultancy, not a government entity or regulator. This is general information, not legal, tax or investment advice. Approval, banking and timing are not guaranteed.
Review and authoritative references
Last reviewed: . Regulatory content and presentation review.
Official references explain the applicable framework; they do not validate every estimate below. Authority fees, bank tariffs and eligibility can change. Confirm the current requirements before committing funds.