What is a
VARA licence?

What activities does a VARA licence cover?

VARA issues licences across several distinct VASP activity categories: Exchange Services, Custody Services, Broker-Dealer Services, Lending and Borrowing Services, Payment Services, Advisory Services, VA Management and Investment Services, and VA Issuance (Category 1 ARVAs and Category 2 FRVAs).

An applicant typically applies for one or more activity categories depending on the business model. The capital, governance, technology and reporting requirements vary by category.

Who needs a VARA licence?

Any entity carrying on virtual-asset activities in or from Dubai requires VARA authorisation. The perimeter is broad: it captures cryptocurrency exchanges, custodians, OTC desks, payment service providers handling virtual assets, fund managers investing in virtual assets, token issuers, and advisory firms operating in the VA space.

The carve-out for DIFC means entities operating exclusively within DIFC fall under the DFSA framework rather than VARA. Entities based outside the UAE but providing services to UAE persons may still require VARA authorisation depending on activity scope and marketing.

Where does a VARA licensee need to be incorporated?

The licensed entity must be incorporated in Dubai outside DIFC — the standard venue is DMCC, which hosts Dubai's Crypto Centre and is the dominant free zone for VARA-licensed VASPs. DIFC entities are regulated by the DFSA (separate regulator); ADGM entities are regulated by the FSRA in Abu Dhabi. Only a Dubai-incorporated entity outside DIFC can hold a VARA licence.

How does the application process work?

The application follows a four-stage process: Initial Disclosure Questionnaire (IDQ), Initial Approval, Full Compliance Package submission, and Operational Approval. Total timeline typically ranges 6–14 months depending on category complexity, capital arrangements, and the depth of the applicant's compliance framework.

VARA expects substantial physical presence in Dubai: real office, two Responsible Individuals (fit and proper, full-time UAE-resident), board governance, AML/CFT framework per VARA's Compliance & Risk Rulebook, technology governance per the Technology & Information Rulebook (TGRAF), and operational policies covering custody, market integrity, conduct of business and prudential matters.

What's the difference between VARA and ADGM for crypto?

VARA regulates virtual-asset activities specifically in Dubai. ADGM (Abu Dhabi Global Market) has its own Financial Services Permission framework administered by the FSRA. Both are credible regulated pathways but they are different regulators in different emirates — not interchangeable.