VARA Advisory Services Licence
Giving personalised recommendations on virtual asset transactions to clients in or from Dubai requires a VARA Advisory Services licence. Regulators focus on whether advice is suitable, fair and free from undisclosed conflicts. VAF Global prepares the conduct and AML/CFT framework that advisory firms need.
Who needs this licence?
- Crypto investment advisers and wealth managers
- Family offices advising on virtual asset allocations
- Platforms providing personalised trade recommendations
- Consultancies recommending specific virtual asset transactions
What advisory covers
Personalised recommendations
Advice tailored to a client's circumstances on buying, selling or holding virtual assets.
Portfolio advice
Recommendations on virtual asset allocation and strategy.
Not general information
General market commentary or education is usually distinct from regulated advice, though promotion rules may still apply.
Marketing rules
VARA's marketing regulations apply to how advisory services are promoted.
Key requirements
- A commercial licence from Dubai Economy and Tourism (DET) or a Dubai free zone authority
- Compliance with VARA's compulsory rulebooks: Company; Compliance & Risk Management; Technology & Information; Market Conduct
- Fit and proper shareholders, board and senior management, including a Compliance Officer and MLRO
- AML/CFT programme with KYC, transaction monitoring (KYT), sanctions screening, Travel Rule and goAML reporting
- Client classification and suitability assessment procedures
- Risk disclosures and record-keeping of advice given
- Conflicts of interest policy, including remuneration and inducements
- Marketing and promotion compliance
The licensing process
- 1
Activity mapping
Confirm exactly which VARA activities your model needs. Many businesses need more than one.
- 2
Initial Disclosure Questionnaire
Submit VARA's IDQ through DET or your Dubai free zone, with the business plan and owner and management details.
- 3
Approval to Incorporate
VARA issues an Approval to Incorporate. Set up the company and operations; no virtual asset activity is allowed yet.
- 4
Full application
File the full licence application with policies, risk assessments, financials and key personnel.
- 5
VASP Licence
VARA issues the licence, which may carry operational conditions; supervision and annual renewal follow.
How VAF Global helps
We prepare and run the compliance side of your licence, so your application meets the regulator's expectations from day one.
- Activity mapping across VARA rulebooks
- AML/CFT, KYC, sanctions and Travel Rule policies
- Business-wide and customer risk assessments
- Compliance manuals aligned to the activity rulebook
- Outsourced MLRO (where VARA permits) and support for your in-house Compliance Officer
- KYT transaction monitoring with our KYT tool
VARA Advisory Licence: FAQ
Do crypto influencers or educators need a VARA advisory licence?
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General education and commentary is different from personalised advice, but VARA's marketing rules can still apply to promotion of virtual assets. Each case needs to be assessed on its facts.
Can an advisory firm also execute trades?
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Executing trades for clients is a separate activity, typically Broker-Dealer Services, which needs its own licence.
Can I combine this with other VARA activities?
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Yes. A VARA licence lists each authorised activity, and many firms hold several. Each additional activity brings its own rulebook requirements, so it is best to plan the full scope before applying.
Other UAE licensing guides
Last reviewed October 2026. This guide is general information for compliance planning, not legal advice. Regulatory requirements change; always confirm current rules with the regulator. VAF Global is a compliance consultancy and does not provide legal services.