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Exchanges, broker-dealers and custodians building in Dubai’s mainland and free zones outside the DIFC hold this licence, with each virtual asset activity licensed on its own terms.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money and cryptoasset firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
Our realistic timeline from submission to decision.
Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.
We assemble your team: two senior managers based in the UAE.
The licence, the requirements, the cost and the timing for your business.
You will need two full-time senior managers who live in the UAE or hold UAE passports, approved by VARA before the licence and kept in post.
One programme, from scoping to launch. Speak to an expert about this licence.
Requirements, capital, timing, fees and common questions, drawn from the regulator’s own publications.
Exchanges, broker-dealers, custodians, lending platforms, virtual asset fund managers, transfer and settlement services and issuers of fiat-referenced tokens operating in or from Dubai need a VARA licence before they begin. VARA covers the Dubai mainland and every free zone except the DIFC, where the DFSA’s regime applies; elsewhere in the UAE the federal Securities and Commodities Authority regulates. A proprietary trader with no clients needs a no-objection certificate and, above a volume threshold, registration. Each activity is a discrete licence applied for separately, so an exchange that also offers custody and broker-dealer services holds three.
| Activity | Paid-up capital (higher of) | Application fee | Annual supervision fee |
|---|---|---|---|
| Advisory services | AED 100,000 | AED 40,000 | AED 80,000 |
| Broker-dealer services | AED 400,000 or 15% of fixed overheads with a VARA-licensed custodian; otherwise AED 600,000 or 25% | AED 100,000 | AED 200,000 |
| Custody services | AED 600,000 or 25% of fixed overheads | AED 100,000 | AED 200,000 |
| Exchange services | AED 800,000 or 15% of fixed overheads with a VARA-licensed custodian; otherwise AED 1,500,000 or 25% | AED 100,000 | AED 200,000 |
| Lending and borrowing services | AED 500,000 or 25% of fixed overheads | AED 100,000 | AED 200,000 |
| VA management and investment services | AED 280,000 or 15% of fixed overheads with a VARA-licensed custodian; otherwise AED 500,000 or 25% | AED 100,000 | AED 200,000 |
| VA transfer and settlement services | AED 500,000 or 25% of fixed overheads | AED 40,000 | AED 80,000 |
| Category 1 issuance (fiat-referenced) | AED 1,500,000 plus 2% of available supply | AED 100,000 | AED 200,000 |
Capital is held per activity and reconciled monthly. VARA may impose additional or varied fees according to the risk profile of the applicant.
| Requirement | Amount |
|---|---|
| Advisory | AED 100,000 |
| Broker-dealer | AED 400,000 or 15% of fixed overheads (VARA-licensed custodian); otherwise AED 600,000 or 25% |
| Custody | AED 600,000 or 25% of fixed overheads |
| Exchange | AED 800,000 or 15% of fixed overheads (VARA-licensed custodian); otherwise AED 1,500,000 or 25% |
| Lending and borrowing; transfer and settlement | AED 500,000 or 25% of fixed overheads |
| Management and investment | AED 280,000 or 15% of fixed overheads (VARA-licensed custodian); otherwise AED 500,000 or 25% |
| Fiat-referenced issuance | AED 1,500,000 plus 2% of available supply |
| Net liquid assets | At least 1.2 times monthly operating expenses |
Capital is calculated per activity under Part VI of the Company Rulebook, held in trust for VARA or by surety bond, and reconciled monthly; reserve assets of 100% of client liabilities are held in addition.
| Figure | Value | Source |
|---|---|---|
| Statutory decision period | No statutory period; VARA publishes no processing timeline | Virtual Assets and Related Activities Regulations 2023; VARA licence applications page |
| Application preparation | 8 to 12 weeks | From instruction to submission, including banking in parallel |
| Our realistic timeline | 6 to 9 months from the initial disclosure questionnaire, across both stages | Our own figure, from the regulator’s published data and our applications |
Regulator figures are quoted as published and converted to months. Our realistic timeline assumes a complete, well-prepared application.
| Item | Amount | Notes |
|---|---|---|
| Application fee, main activities | AED 100,000 | Broker-dealer, custody, exchange, lending and borrowing, management and investment, Category 1 issuance; about 50% paid at the initial disclosure stage, the balance before licence |
| Application fee, advisory and transfer and settlement | AED 40,000 | Same split |
| Extension fee per additional activity | 50% of the lower application fee | Where more than one activity is applied for |
| Annual supervision fee, main activities | AED 200,000 | Per activity; first year paid before the licence |
| Annual supervision fee, advisory and transfer and settlement | AED 80,000 | Per activity |
| Risk-based variation | At VARA’s discretion | VARA may impose additional or varied fees |
| Professional fees | Fixed | Quoted after scoping |
The licence covers virtual asset activity in or from Dubai, mainland and free zones, excluding the DIFC. Elsewhere in the UAE the federal Securities and Commodities Authority regime applies. A VARA firm serving clients in the European Union holds a MiCA authorisation and one serving the United Kingdom the FCA cryptoasset authorisation; we obtain each.
VARA states that it may refuse an approval to incorporate or a licence where the proposed activities fall outside its regulatory perimeter or its standards are not met, and that an application is not processed until the fees are received. From the published process, VARA looks for the following.
A virtual asset firm needs accounts for client fiat funds, separated from its own, and operating accounts in the markets it serves. Banks review the financial crime framework first: customer due diligence, transaction monitoring, travel rule arrangements and the wallet screening tools. We open the accounts alongside the application, with the financial crime framework the banks review. See banking and payment processing.
VARA publishes no processing timeline. The process runs in two stages, approval to incorporate and then the full licence submission after incorporation, office lease and staffing; we plan for six to nine months across both.
AED 800,000 or 15% of fixed annual overheads, whichever is higher, where a VARA-licensed custodian is used; otherwise AED 1,500,000 or 25%. Capital is held in a UAE bank trust account naming VARA as beneficiary or by surety bond.
AED 100,000 on application for the main activities and AED 40,000 for advisory and transfer and settlement, each additional activity at 50% of the lower fee, and an annual supervision fee of AED 200,000 or AED 80,000 per activity.
Two responsible individuals, each a full-time employee and a UAE resident or passport holder, approved by VARA, in a private office in Dubai for every activity other than advisory.
No. The DIFC is regulated by the DFSA and the rest of the UAE by the federal Securities and Commodities Authority.
A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm builds licensed payment, e-money, crypto and stablecoin businesses: the licence, the team, the technology, the bank accounts and card issuing.
This guide is general information, not legal advice. Requirements and fees change, and the regulator’s own publications take precedence.
The licence, your team, banking and technology, delivered as one programme.