VARA Token Issuance: Launching a Token in Dubai
Issuing a virtual asset to the public in or from Dubai is regulated under VARA's Virtual Asset Issuance Rulebook. Category 1 issuances (fiat-referenced and asset-referenced virtual assets) need a VARA licence and VARA approval of each token. Category 2 issuances do not need a VARA licence, but must be placed and distributed by a VARA Licensed Distributor (a broker-dealer), which is responsible for the issuer's compliance with the Rulebook. VAF Global prepares the compliance side of your token launch.
Who needs this licence?
- Blockchain projects launching a token from Dubai
- Issuers of asset-referenced or fiat-referenced tokens
- Projects running token sales or airdrops to the public
- Real-world asset (RWA) tokenisation projects
How VARA regulates issuance
Category 1 issuance
Fiat-referenced and asset-referenced virtual assets require a VARA licence and VARA approval of each token.
Category 2 issuance
No VARA licence is needed, but all placement and distribution must be done by a VARA Licensed Distributor (a VASP licensed for Broker-Dealer Services). A Category 2 token is not approved by VARA.
Whitepaper and disclosures
Clear disclosure of the project, token rights, risks and team.
Exemptions
Some issuance types may be exempt; this depends on the token and the offering.
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
- Whitepaper meeting VARA disclosure requirements
- Investor KYC/AML onboarding and sanctions screening
- Risk disclosures and marketing compliance
- Reserve and redemption arrangements for fiat- and asset-referenced tokens
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 Token Issuance: FAQ
Can I launch a token in Dubai without a VARA licence?
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Depending on the token, yes. Category 2 issuances need no VARA licence, but must be distributed through a VARA Licensed Distributor that ensures the issuer meets the Rulebook's whitepaper and disclosure requirements. Fiat- and asset-referenced tokens (Category 1) need a licence. Confirm the current procedure with VARA before launching.
Is a stablecoin issuance regulated by VARA or the Central Bank?
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Tokens pegged to the UAE dirham fall solely under the Central Bank of the UAE. Other fiat-referenced tokens issued under VARA are Category 1 and cannot be used to pay for goods and services in the UAE. Payment-token activity may also need to comply with the CBUAE's Payment Token Services Regulation.
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.