How much capital do you need for the VARA VASP Licence?

AED 100k–1.5M by category. Advisory: AED 100,000; Broker-Dealer: Higher of AED 400,000 or 15% of fixed annual overheads with a VARA-licensed custodian; AED 600,000 or 25% otherwise; Custody: Higher of AED 600,000 or 25% of fixed annual overheads (Company Rulebook Rule VI.B); Exchange: Higher of AED 800,000 or 15% of fixed annual overheads with a VARA-licensed custodian; AED 1,500,000 or 25% otherwise; Lending & Borrowing: Higher of AED 500,000 or 25% of fixed annual overheads; VA Management & Investment: Higher of AED 280,000 or 15% with a VARA-licensed custodian; AED 500,000 or 25% otherwise; Transfer & Settlement: Higher of AED 500,000 or 25% of fixed annual overheads; Category 1 Issuance (FRVA): AED 1,500,000 plus 2% of available supply.

General information only. CryptoRegHub provides summaries for informational purposes and does not constitute legal or compliance advice. Always verify with official sources and consult qualified legal counsel before making compliance decisions.

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Recently verified:28 July 2026·Source →

VARA VASP Licence

Q: How long does the VARA VASP Licence take?

In practice: No statutory clock — a discretionary two-stage process. Stage 1 (Initial Disclosure Questionnaire to Initial Approval) commonly runs 6–12 weeks for a well-prepared file; the full path to an operational licence is typically quoted in months, not weeks.

Q: What does the VARA VASP Licence application cost?

Application fee: Approximately AED 100,000 per activity for the major categories (Broker-Dealer, Custody, Exchange, Lending, Management) and AED 40,000 for Transfer & Settlement; additional activities in one application attract a Licence Extension Fee of 50% of the lower application fee. Figures from VARA's public fee schedule via secondary sources — confirm at application.. Ongoing: Annual supervision fee per activity: approximately AED 200,000 for the major categories and AED 80,000 for Advisory and Transfer & Settlement.

UAE — DubaiExchange / tradingCustodyBroker / dealerTransfer / paymentsLive

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General information only — not legal advice

CryptoRegHub provides plain-English summaries of crypto regulations for informational purposes only. This does not constitute legal, compliance, or financial advice. Regulations change frequently — always verify information with official sources and consult qualified legal counsel before making any compliance decisions.

Dubai's dedicated virtual asset licence, covering all zones except the DIFC. One regulator, one application process, with seven activity categories — Advisory, Broker-Dealer, Custody, Exchange, Lending & Borrowing, VA Management & Investment, and Transfer & Settlement — whose capital and rulebook requirements stack per activity on top of four compulsory rulebooks. Rulebook v2.1 applies in 2026. Notably, capital tiers depend on custody architecture: using a VARA-licensed custodian lowers the paid-up capital requirement for several categories.

Capital requirements

Tier	Capital	Covers
Advisory	AED 100,000	Virtual asset advisory services
Broker-Dealer	Higher of AED 400,000 or 15% of fixed annual overheads with a VARA-licensed custodian; AED 600,000 or 25% otherwise	Broker-dealer services
Custody	Higher of AED 600,000 or 25% of fixed annual overheads (Company Rulebook Rule VI.B)	Custody services
Exchange	Higher of AED 800,000 or 15% of fixed annual overheads with a VARA-licensed custodian; AED 1,500,000 or 25% otherwise	Exchange services
Lending & Borrowing	Higher of AED 500,000 or 25% of fixed annual overheads	VA lending and borrowing
VA Management & Investment	Higher of AED 280,000 or 15% with a VARA-licensed custodian; AED 500,000 or 25% otherwise	VA management and investment services
Transfer & Settlement	Higher of AED 500,000 or 25% of fixed annual overheads	VA transfer and settlement services
Category 1 Issuance (FRVA)	AED 1,500,000 plus 2% of available supply	Fiat-referenced virtual asset issuance

Application process

Initial Disclosure Questionnaire (IDQ)

The entry point: disclosure of the proposed business, ownership and activities, with the first fee instalment invoiced after this stage.

Provisional approval

Permits establishment steps — incorporation, premises, hiring — but not operating. Not a licence to trade.

Full application per activity

Requirements stack per activity category on top of the four compulsory rulebooks (Company; Compliance & Risk Management; Technology & Information; Market Conduct). Multi-activity firms meet each category's requirements in full, with fixed annual overheads allocated mutually exclusively across activities.

Operational licence

Granted with conditions; go-live follows satisfaction of any pre-conditions and evidencing of the capital and insurance arrangements.

Ongoing obligations

Paid-up capital per activity — held in a UAE bank trust account with VARA as beneficiary, or via an acceptable surety bond; tiers depend on category and custody architecture.

Net liquid assets — at least 1.2× monthly operational expenses held in liquid form, alongside insurance requirements and, for issuance, reserve assets.

Per-activity rulebook obligations — each licensed category carries its own rulebook on top of the four compulsory rulebooks.

Records and reporting — extensive record-keeping (eight years for broker-dealers), monthly client statements, and marketing rules requiring factual content without projections.

Annual supervision fees — payable per activity band.

Common rejection & delay reasons

Custody architecture decided too late

Whether you use a VARA-licensed custodian swings the paid-up capital tier for several categories — deciding late forces capital restructuring.

Activity mapping drift

Models that blur management, brokerage and exchange activity attract reclassification and stacked requirements.

Underbudgeting the ongoing stack

Responsible Individual salaries, the 1.2× liquid-asset requirement and insurance are recurring costs that secondary estimates put at a first-year total well above the headline capital figure.

What's changing

Rulebook iteration — v2.1 in force, watch for further versions and AML guidance updates

· in force

UAE Federal Decree-Law 6/2025 full compliance deadline interacts with Dubai licensing for federal-scope activities

16 September 2026· confirmed

Frequently asked questions

JurisdictionUAE — Dubai

RegulatorVirtual Assets Regulatory Authority (VARA)

TypeLicence — 7 activity categories

CapitalAED 100k–1.5M by category

Application feeApproximately AED 100,000 per activity for the major categories (Broker-Dealer, Custody, Exchange, Lending, Management) and AED 40,000 for Transfer & Settlement; additional activities in one application attract a Licence Extension Fee of 50% of the lower application fee. Figures from VARA's public fee schedule via secondary sources — confirm at application.

Ongoing feesAnnual supervision fee per activity: approximately AED 200,000 for the major categories and AED 80,000 for Advisory and Transfer & Settlement.

Realistic timelineNo statutory clock — a discretionary two-stage process. Stage 1 (Initial Disclosure Questionnaire to Initial Approval) commonly runs 6–12 weeks for a well-prepared file; the full path to an operational licence is typically quoted in months, not weeks.

PassportingNone (Dubai only; separate regimes apply federally and in ADGM/DIFC)

Last verified28 Jul 2026

Dubai-incorporated entity (mainland or free zone, excluding DIFC) with named Responsible Individuals. Budget realistically for RI salaries and the liquid-asset requirement — both are commonly underestimated.

https://rulebooks.vara.ae →

UAE VARA Framework →UAE CMA Federal VASP →European Union: MiCA CASP Authorisation →

Disclaimer

This guide is for general informational purposes only and does not constitute legal advice. Figures change — always verify with the regulator and consult qualified counsel before applying.