Two Pillars Advisory / Insights

VARA License Requirements for Virtual Asset Businesses

Learn about Dubai's Virtual Assets Regulatory Authority (VARA) licensing framework.

What is VARA?

The Virtual Assets Regulatory Authority (VARA) is Dubai's dedicated regulator for virtual assets and related activities, established to create a comprehensive regulatory framework for crypto and blockchain businesses.

VARA License Categories

1. Advisory Services

For businesses providing advice on virtual asset investments.

2. Broker-Dealer Services

For intermediaries facilitating virtual asset transactions.

3. Custody Services

For businesses safeguarding virtual assets for clients.

4. Exchange Services

For platforms enabling virtual asset trading.

5. Lending and Borrowing Services

For platforms facilitating virtual asset lending.

Key Requirements

Capital Requirements

  • Advisory Services: AED 100,000 paid-up capital.
  • Exchange Services: higher of AED 1,500,000 or 25% of fixed annual overheads; with a qualifying custody arrangement, higher of AED 800,000 or 15%.
  • Custody Services: higher of AED 600,000 or 25% of fixed annual overheads.
These are capital requirements, not licence fees. Confirm the VARA Company Rulebook. Figures reviewed 20 October 2026.

Governance Requirements

  • Board of Directors with relevant experience
  • Compliance officer appointment
  • Risk management framework

Technology Requirements

  • Robust cybersecurity measures
  • Cold and hot wallet management
  • Business continuity planning

Application Process

  1. Initial Application via VARA portal
  2. Assessment of business plan
  3. Provisional Approval
  4. Operational Readiness demonstration
  5. License Issuance

Timeline and Costs

StageDurationEstimated Cost (AED)
Advisory Services applicationNo guaranteed review periodAED 40,000 application fee
Advisory Services supervisionAnnualAED 80,000 per year
Exchange or Custody applicationNo guaranteed review periodAED 100,000 per activity application
Exchange or Custody supervisionAnnualAED 200,000 per activity per year
Single-activity figures from VARA Schedule 2, reviewed 20 October 2026. Capital, incorporation, premises and compliance costs are separate. Multiple-activity application fees follow the extension provisions, not simple multiplication.

Planning to launch a virtual asset business in Dubai? Contact Two Pillars Advisory for VARA licensing assistance.

Review and authoritative references

Last reviewed: . Presentation and reference review; full numerical verification pending.

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.