VARA Licence in Dubai 2026: Approval to Incorporate to Full Licence, Capital, Fees and Documents

In short: To get a VARA licence you apply through DET (mainland) or a Dubai free zone, receive VARA’s Approval to Incorporate, form the company, hire two UAE-resident Responsible Individuals, put up the paid-up capital, then file the full application and pay the remaining fees. You may not offer, or market, any virtual asset service until the licence is issued.

The VARA licence is Dubai’s licence for virtual asset service providers. It is issued by the Virtual Assets Regulatory Authority, one licence per regulated activity, after a two-stage process that starts with your commercial licensing authority. Until VARA issues it, a trade licence that mentions crypto or blockchain does not let you serve clients.

This page covers the VARA process itself: which activity you need, the stages, documents, capital, fees, rulebooks, incorporation, marketing rules and penalties. If you are still choosing between regulators (VARA, the DFSA in DIFC, the FSRA in ADGM, or the federal Capital Market Authority), start with our crypto business licence guide, which compares them. Every figure below comes from VARA’s website, its rulebook site and Dubai Law No. 4 of 2022, checked on 19 October 2026. VARA’s Regulations and Company Rulebook in force when we checked are the versions dated 19 May 2025.

What is a VARA licence?

A VARA licence is the Virtual Asset Service Provider licence issued by Dubai’s Virtual Assets Regulatory Authority. Any firm that wants to carry on virtual asset activity in or from Dubai, excluding DIFC, must hold it before it starts, whether its clients are in Dubai or abroad.

• Legal basis. Law No. 4 of 2022 Regulating Virtual Assets in the Emirate of Dubai created VARA. Article 15 says no person may conduct the activity without a permit from VARA, the business must be set up in Dubai in a legal form the commercial licensing authority approves, and VARA’s approvals come before the commercial licensing procedure.
• Where it applies. All of Dubai, including Special Development Zones and free zones such as DMCC and DWTC, but not the Dubai International Financial Centre, which has its own regulator.
• The rules. The Virtual Assets and Related Activities Regulations 2023, the Marketing Regulations 2024 and VARA’s rulebooks. VARA can amend them at any time and publishes the current versions on rulebooks.vara.ae.
• No exemptions by default. VARA’s FAQ says no virtual asset activity is exempt: every activity needs a licence, a registration or a No Objection Certificate.

Which VARA activity do you need? A decision table

You need the VARA activity that matches what you actually do for clients, and you need one for each activity. VARA’s FAQ says each activity is “discrete” and must be applied for explicitly. Several activities can sit under one licence, except custody.

Sources: VARA Licensed Activities and FAQ; Regulations 2023, Part IV.A (professional exemption, proprietary trading registration). Two structural rules apply on top: a licensed VASP may not carry on proprietary trading or trade its group’s assets under its licence (a separate company is needed), and custody must be a distinct legal entity with a standalone licence.

How does the VARA licensing process work, stage by stage?

VARA licenses new firms in two stages: an Approval to Incorporate, then the VASP licence. Applications are not made to VARA directly; they go through the Department of Economy and Tourism (DET) for mainland firms or the Dubai free zone where the company will sit, which passes them to VARA.

Source: VARA Licence Applications page and FAQ; Company Rulebook Part VI.

Is the MVP licence still a stage?

No. When VARA launched in 2022 it ran a Minimum Viable Product (MVP) phase, and several firms received “MVP preparatory” or “MVP operational” licences, which VARA still lists in its news archive. The process VARA publishes today for new firms has only the two stages above: Approval to Incorporate, then the VASP licence. Firms that operated before 7 February 2023 had a separate legacy route with a Legacy Operating Permit, valid for 12 months, not renewable, and requiring the full application at least 90 days before it expires.

How long does a VARA licence take? The timeline

VARA does not publish a processing time for either stage, so nobody can promise you a date. What VARA does publish are the fixed time points below; everything else depends on how complete your file is and how quickly you answer VARA’s questions.

Sources: VARA Licence Applications page and FAQ; Law No. 4 of 2022, Article 22. Budget for rent, salaries and capital between the ATI and the licence, when the company exists but cannot earn virtual asset revenue. The company formation step is usually the faster part; the regulatory review is the longer one. Confirm current timing expectations with VARA.

What documents does a VARA licence application need?

VARA publishes a non-exhaustive document list for the full licence application, grouped under corporate structure, risk and compliance, technology and other. It may ask for more during the review.

Source: VARA Licence Applications page, “Virtual Asset Service Provider Licence Application Documentation”. Most of these are policies and frameworks written to VARA’s rulebooks, which is why VARA files are normally prepared by compliance specialists, not by a PRO firm. The corporate items (incorporation certificate, passport copies, UBO list, office lease, visas) are where company formation and PRO work come in. Your UBO filing with the licensing authority is explained in our UBO register guide.

How much capital do you need for a VARA licence?

VARA sets minimum paid-up capital per activity in Part VI of its Company Rulebook, from AED 100,000 for advisory to the higher of AED 1,500,000 or 25% of fixed annual overheads for an exchange. Where a firm uses a VARA-licensed custodian, or is otherwise approved during licensing, some activities qualify for a lower figure.

Source: VARA Company Rulebook (version of 19 May 2025), Part VI. The rest of Part VI matters as much as the headline number:

• Per activity. A firm licensed for several activities holds the capital for each one, using the overheads of that activity.
• How it is held. In a trust account with a UAE-licensed bank naming VARA as beneficiary, in a surety bond with no end date naming VARA, or in another way VARA specifies in the licence.
• Net liquid assets. Current liquid assets above current liabilities of at least 1.2 times monthly operating expenses, held in cash and equivalents or VARA-approved USD or AED referenced tokens.
• Insurance. Professional indemnity, directors’ and officers’, and commercial crime cover for hot-wallet assets, with a regulated insurer.
• Reserve assets. 100% of what is owed to clients, held one-to-one in the same virtual asset.
• More on request. VARA can require extra capital, liquidity, insurance or reserves based on size, complexity and risk.

What are VARA’s licence fees for each activity?

VARA charges a one-off licence application fee of AED 40,000 or AED 100,000 for the first activity, and an annual supervision fee of AED 80,000 or AED 200,000 for each licensed activity, under Schedule 2 of the Regulations (version of 19 May 2025, checked 19 October 2026).

Source: Regulations 2023, Schedule 2. How the schedule works:

• Extra activities. Each additional activity in the same application carries a Licence Extension Fee of “50% of lower Licence Application Fee(s)”. When the activities carry different application fees, confirm with VARA which fee it treats as the base.
• When it is paid. Application and extension fees are due on submission; the supervision fee is paid for each activity before you start operating, then at each renewal.
• No refunds. Regulation IV.B.4 says no fees are refunded if an application is denied or withdrawn.
• Risk-based extras. VARA may add supervision fees based on market share, client base, complexity or compliance record.
• Other authorities’ fees are separate. DET or free zone licence, office, visa and bank costs come on top.

Worked examples from the published figures: a single Advisory licence means AED 40,000 plus AED 80,000, so AED 120,000 to VARA in year one. A single Exchange licence means AED 100,000 plus AED 200,000, so AED 300,000. Exchange plus Broker-Dealer in one application means AED 100,000, plus a AED 50,000 extension fee, plus AED 400,000 in supervision fees, so AED 550,000 in year one, before any capital.

Other VARA charges announced in June 2023: a proprietary trading NOC at AED 1,000 a year; a licence update fee of AED 500 per request; a licence withdrawal fee of AED 10,000; a whitepaper submission fee of AED 5,000 plus up to AED 50,000 for the detailed review; and up to AED 4,000 for a legal review of the licensing perimeter. These come from VARA’s fees clarification of 22 June 2023; confirm the current amounts with VARA.

Which VARA rulebooks apply to your licence?

Every VASP must comply with four compulsory rulebooks, plus the activity rulebook for each activity it is licensed for. VARA published Version 2.0 of its activity rulebooks on 19 May 2025, with full compliance required by 19 June 2025.

Sources: Regulations 2023, Part V; VARA’s Version 2.0 rulebooks announcement; the rulebook texts on rulebooks.vara.ae. The Company Rulebook also requires VARA’s written approval before any material change to your ownership or control.

How do DET or free zone incorporation and VARA fit together?

You need both a commercial licence and a VARA licence, and VARA comes first: Article 15 of Law No. 4 of 2022 requires VARA’s approvals before the commercial licensing procedure starts. In practice you file through the licensing authority, receive the ATI, and only then incorporate.

• Mainland. DET accepts the regulated virtual asset activities at its business centres, and VASPs can also add them to an existing licence. Our mainland company formation guide covers the DET side.
• Free zones. Any Dubai free zone except DIFC can be the commercial licensor. A free zone licence alone does not authorise a regulated virtual asset activity, a point DMCC makes in its own published rules; see our DMCC guide and DWTC guide for their packages and office rules.
• Legal form and office. An LLC or FZ-CO, no sole proprietorship, and a private office for every activity except advisory. VARA sets no minimum size; check space against your staffing with DET or the zone.
• People and visas. The two Responsible Individuals must be UAE residents (or UAE passport holders) and full-time employees, so residence visas for them are part of the critical path. Shareholders who will live in Dubai usually take an investor or partner visa.
• Nationality. VARA says there are no nationality restrictions on applicants, provided the applicant is a legal entity set up with DET or a free zone outside DIFC.

For the full order of a UAE company setup, see our start-a-business route map.

What are VARA’s marketing rules?

Only a VARA-licensed VASP, or someone acting for it and with its approval, may market a virtual asset activity in or targeting the UAE. VARA’s Regulations on the Marketing of Virtual Assets and Related Activities 2024 apply to everyone, licensed or not, domestic or foreign.

• What counts as marketing. Any advertisement, invitation, solicitation, offer or promotion, including social media posts, endorsements, podcasts, events, airdrops, sponsored editorial and educational content.
• Content rules. Fair, clear, not misleading and labelled as promotional. No claims that investments are safe or returns guaranteed, no urgency or fear of missing out, and no suggestion that past performance predicts future results. Paid third-party posts must say so prominently.
• Marketing a virtual asset itself. No call to buy, plus prominent warnings that virtual assets may lose all or part of their value and are extremely volatile, and that the investor can lose all the money invested with no financial protection.
• Incentives such as bonuses need a compliance confirmation from VARA.
• Records. Keep every piece of marketing and its distribution details for at least 8 years.
• Agencies and influencers. The firm stays responsible for its agency’s marketing, and the agency can be fined too. “Key opinion leaders” do not qualify for the journalistic or educational exemptions. Individuals who post paid promotions from the UAE also need the federal UAE Advertiser Permit.
• Events and outdoor ads. Unlicensed firms may market only at physical events, with a prominent “not licensed by VARA” disclaimer and no onboarding of UAE residents. Event permits go through DET’s e-Permit system under the virtual asset event category; outdoor advertising goes through the Dubai Municipality advertising system under the virtual asset category.

Sources: VARA Marketing Regulations 2024, Part I and Schedule 1; VARA FAQ (marketing questions).

What are the penalties for breaking VARA rules?

VARA can fine, suspend or revoke a licence, order a business to stop, and ask the licensing authority to cancel the commercial licence. Fines for unlicensed activity, rulebook breaches and market offences can reach the higher of AED 50 million or 15% of annual revenue for a company.

These are maximums: VARA decides each fine by severity and other factors. In a public notice of 9 October 2024, VARA said it had issued cease-and-desist orders with fines of AED 50,000 to AED 100,000 per entity to 7 firms operating without licences and breaching the marketing rules. You can challenge a VARA decision with a written grievance within 30 days of being notified.

Common reasons VARA applications stall

VARA does not publish refusal statistics, so this list is not a ranking. It is drawn only from VARA’s own published requirements: each one is a point where a file can be held up or refused.

1. The activity falls outside VARA’s perimeter, or the firm may not meet the standard. VARA reserves the right not to issue an ATI or a licence in either case.
2. Fees not paid. VARA does not process the application until the fees are received, and they are not refunded if you withdraw.
3. Wrong legal form. Sole proprietorships are not accepted.
4. Responsible Individuals who do not qualify. Both must be full-time, fit and proper, UAE-resident (or UAE passport holders) and approved by VARA.
5. Custody bundled with other activities. Custody needs its own legal entity and licence.
6. Proprietary trading inside the licensed entity. It needs a separate company and a No Objection Certificate.
7. No private office for activities that require one.
8. Unclear ownership. Trusts, nominee arrangements and DAO-linked structures must be explained to VARA, and every UBO identified.
9. Incomplete documents, such as a missing wind-down plan, source of funds evidence or penetration test results.
10. Capital not held the way VARA requires: a trust account or surety bond naming VARA.
11. Operating or marketing before the licence. The ATI is not permission to operate, and unlicensed marketing is fined separately.
12. Relying on someone who claims influence with VARA. VARA says it has no partnership with any consultancy, and that no firm may claim a relationship that speeds up an application. Misrepresenting one is itself a ground for a fine.

Sources: VARA Licence Applications page, Licensed Activities page and FAQ; Company Rulebook Parts I and VI; Regulations Schedule 2 and 3; VARA Notice Regarding Endorsements.

Applying for a VARA licence from abroad

You can start from abroad, but the business cannot stay abroad. VARA has no nationality restriction, yet the applicant must be a Dubai entity, the two Responsible Individuals must be UAE residents and full-time, and most activities need a private office in Dubai. Founders overseas usually plan the sequence like this:

• Agree the activity and structure with compliance and legal advisers, and prepare the questionnaire and business plan.
• File through DET or the chosen free zone; documents signed abroad may need notarisation and attestation for use in the UAE.
• After the ATI, incorporate, sign the office lease and start residence visas for the Responsible Individuals and other key staff.
• Fund the paid-up capital into the trust account or surety bond, then submit the full application.

If you already hold a VARA licence and expand abroad, Regulation IV.A.4 says you must meet VARA’s standard there as a minimum, or the local standard if it is higher.

How MIRDXB PRO helps with a VARA-regulated company

We handle the parts of a VARA project that are company formation and PRO work: the DET or free zone application and licence once VARA’s Approval to Incorporate is issued, trade name and activity, office lease and Ejari, establishment and immigration cards, residence visas and Emirates IDs for the Responsible Individuals and staff, document attestation, and the renewal diary for the trade licence, visas and Emirates IDs. You get a fixed fee in writing before anything is paid; government and VARA fees are paid at cost.

We are plain about the limits. The VARA application file itself (business plan, compliance, AML, risk, technology and market conduct policies) is specialist regulatory work, and VARA expects it to reflect its rulebooks; we work alongside your compliance advisers rather than replace them. MIRDXB PRO is a private PRO and visa services company in Al Barsha 1, Dubai. It is not VARA, DET or a free zone authority, it has no arrangement with VARA, and it cannot speed up or guarantee any decision.

See our business setup service in Dubai for what is included.

Frequently asked questions