VARA Exchange Services Licence: Run a Crypto Exchange in Dubai
Operating a platform that matches buyers and sellers of virtual assets in or from Dubai requires a VARA licence for Exchange Services. VARA expects exchanges to show strong market integrity, token listing controls, client asset protection and AML/CFT before they launch. VAF Global builds and runs the compliance framework behind your exchange application.
Who needs this licence?
- Centralised crypto exchanges with an order book
- Crypto-to-fiat and crypto-to-crypto trading platforms
- Hybrid exchanges combining matching with brokerage
- Platforms offering trading to retail or institutional clients in Dubai
What the Exchange licence covers
Order matching
Matching orders between multiple buyers and sellers of virtual assets.
VA-to-fiat and VA-to-VA trading
Conversion between virtual assets and fiat or other virtual assets on the platform.
Token listing
Admitting virtual assets to trading under a documented listing and due diligence policy.
Related activities
Custody, brokerage or transfer services usually need their own VARA activity licence or a licensed partner.
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
- Market surveillance and market abuse controls (manipulation, insider dealing, wash trading)
- Token listing and delisting policy with due diligence on each virtual asset
- Order handling, fair access and transparent fee disclosure
- Segregation and protection of client virtual assets and fiat
- Exchange-grade technology, cybersecurity and independent audits
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 Exchange Licence: FAQ
Does a crypto exchange in Dubai also need a custody licence?
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Holding client virtual assets is a separate regulated activity. Exchanges either obtain the Custody Services licence as well or use a VARA-licensed custodian, depending on their model.
What is the difference between an exchange and a broker-dealer under VARA?
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An exchange runs a venue matching many buyers and sellers. A broker-dealer handles trades for its own clients as agent or principal. The two have different rulebooks and requirements.
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.
Related insights
VARA Licence Checklist: Compliance Documents to Prepare Before You Apply
The compliance documents and decisions to have ready before submitting a VARA licence application, from risk assessments to Travel Rule procedures.
Read articleKYT Explained: Crypto Transaction Monitoring for UAE Businesses
Know Your Transaction (KYT) explained: what it is, why UAE regulators expect it and how to screen wallets and transactions for risk.
Read articleOther 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.