VARA Licence in Dubai: Requirements and Compliance Support
Any business carrying out virtual asset activities in or from Dubai (outside the DIFC) needs a licence from the Virtual Assets Regulatory Authority (VARA). VARA licenses each activity separately and expects a working compliance framework before it grants approval. VAF Global helps applicants prepare the compliance side of a VARA application and run it after launch.
Who needs this licence?
- Crypto exchanges and trading platforms operating from Dubai
- OTC desks, brokers and dealers in virtual assets
- Custody and wallet providers holding client assets
- Asset managers and advisers offering virtual asset products
- Lending and borrowing providers, and staking services (which VARA treats as Management & Investment)
- Projects issuing virtual assets to the public from Dubai
VARA licensed activities
Advisory Services
Giving personalised recommendations on virtual asset transactions.
Broker-Dealer Services
Buying, selling and arranging virtual asset trades for clients, as agent or principal.
Custody Services
Safekeeping virtual assets or private keys on behalf of clients.
Exchange Services
Operating a platform that matches buyers and sellers of virtual assets.
Lending & Borrowing Services
Arranging or providing virtual asset loans.
VA Management & Investment Services
Managing virtual asset portfolios or investment products for clients.
VA Transfer & Settlement Services
Transferring virtual assets between parties or settling transactions.
Virtual Asset Issuance
Issuing virtual assets, governed by VARA's issuance rulebook and its categories.
Key requirements
- A commercial licence from Dubai Economy and Tourism (DET) or the relevant Dubai free zone authority
- Compliance with VARA's compulsory rulebooks (Company; Compliance & Risk Management; Technology & Information; Market Conduct) and the rulebook for each activity
- Fit and proper shareholders, directors and senior management, including a Compliance Officer and MLRO
- A documented AML/CFT framework aligned with UAE federal AML/CFT legislation, including sanctions screening and Travel Rule procedures
- Paid-up capital, net liquid assets, insurance and reserve assets as set for each activity in Part VI of VARA's Company Rulebook
- Technology governance, cybersecurity controls and independent audits
- Client asset protection, complaints handling and marketing compliance
The licensing process
- 1
Scoping
Confirm which VARA activities your business model needs and whether VARA, DFSA, ADGM or the CMA is the right regulator.
- 2
Initial Disclosure Questionnaire
Submit VARA's Initial Disclosure Questionnaire (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 (ATI). You set up the company and operations, but cannot carry out virtual asset activities yet.
- 4
Full application
File the full licence application with policies, risk assessments, financials and key personnel, and respond to VARA's feedback.
- 5
VASP Licence
VARA issues the VASP Licence, which may carry operational conditions to meet before or after launch.
- 6
Supervision and renewal
Ongoing reporting, audits, supervision and annual licence renewal.
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 and regulator selection
- AML/CFT, KYC, sanctions and Travel Rule policies and procedures
- Business-wide and customer risk assessments
- Compliance manuals aligned to VARA rulebooks
- Outsourced MLRO (where VARA permits) and support for your in-house Compliance Officer
- KYT transaction monitoring with our KYT tool
VARA Licence (Dubai): FAQ
Who needs a VARA licence?
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Businesses carrying out virtual asset activities in or from Dubai, including Dubai free zones other than the DIFC, generally need a VARA licence for each activity they perform. Businesses in the DIFC are regulated by the DFSA instead.
How long does a VARA licence take?
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Timelines depend on the activities, the quality of the application and how quickly conditions are met. Applicants should plan for several months from the Initial Disclosure Questionnaire to the full licence. A complete, well-prepared compliance framework is one of the biggest factors in avoiding delays.
What are VARA's Compliance Officer and MLRO requirements?
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VARA requires both roles. The Compliance Officer must be approved by VARA, have at least five years' experience, be a UAE resident or UAE passport holder and be a full-time employee. The MLRO needs at least two years' AML/CFT experience and may be outsourced subject to VARA's conditions; VAF Global provides outsourced MLRO services.
Can one VARA licence cover several activities?
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Yes. A VARA licence specifies each activity the firm is authorised to carry out, and many firms apply for several, for example Exchange, Broker-Dealer and Custody. Each activity brings its own rulebook requirements.
Related insights
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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.