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 VA Issuance (FRVA/ARVA): As specified in the VA Issuance Rulebook and its Annexes (Company Rulebook VI.B.1); the AED 1,500,000 plus 2% of supply figure is unverified against Annex 1..

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.

← Back to licensing guides|Licensing→UAE — Dubai→VARA VASP Licence

Verify recommended:28 July 2026·Source →

VARA VASP Licence

Q: How long does the VARA VASP Licence take?

In practice: No published processing time and no statutory clock. Two-stage discretionary process: Initial Disclosure Questionnaire, then Approval to Incorporate, then the full application with VARA feedback, meetings and interviews (vara.ae Licence Applications page; Regulations IV.A.2 says the process is 'as prescribed'). No VARA figure for elapsed time has been located; the Public Register lists licensed VASPs.

Q: What does the VARA VASP Licence application cost?

Application fee: AED 100,000. Ongoing: Annual Supervision Fee per licensed activity: AED 200,000 (Broker-Dealer, Issuance, Custody, Exchange, Lending, Management) or AED 80,000 (Advisory, Transfer and Settlement), payable in advance of conducting the activity; VARA may add risk-based fees (Sch 2 paras 3-4). Licence update AED 500, withdrawal AED 10,000 (VARA notice 22 Jun 2023).

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 VA Issuance (FRVA/ARVA)	As specified in the VA Issuance Rulebook and its Annexes (Company Rulebook VI.B.1); the AED 1,500,000 plus 2% of supply figure is unverified against Annex 1.	Fiat-referenced virtual asset issuance

Application process

Initial Disclosure Questionnaire (IDQ)

Submitted through the Dubai Department of Economy and Tourism or the relevant Free Zone: the proposed business, ownership and VA Activities applied for.

Business plan, UBOs, senior management and initial fee

Business plan, ultimate beneficial owners and proposed senior management, with the first part of the application fee - VARA's page says typically 50% (Regulations Sch 2 states the fee is due at submission).

Approval to Incorporate

Permits establishment steps - incorporation, premises, hiring - but no VA Activity. It is not a licence and does not allow operating.

Stage 2 documentation

Per VARA's guidance, including the non-exhaustive public list of 54 documentation items: attested AML/CFT policies and procedures, Cybersecurity Policy, Travel Rule demonstration, and the Rulebook-driven policies and evidence.

VARA feedback, meetings and interviews; balance of fees

Review rounds with VARA, meetings and interviews of Responsible Individuals; the balance of the application fee and the first year's Supervision Fee before licence issue (Sch 2 para 3).

VASP Licence with conditions

Licence granted with conditions per activity; Responsible Individuals approved; licence number, licensed activities and Responsible Individuals to be published as the Market Conduct Rulebook Part V requires.

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 feeAED 100,000

Ongoing feesAnnual Supervision Fee per licensed activity: AED 200,000 (Broker-Dealer, Issuance, Custody, Exchange, Lending, Management) or AED 80,000 (Advisory, Transfer and Settlement), payable in advance of conducting the activity; VARA may add risk-based fees (Sch 2 paras 3-4). Licence update AED 500, withdrawal AED 10,000 (VARA notice 22 Jun 2023).

Realistic timelineNo published processing time and no statutory clock. Two-stage discretionary process: Initial Disclosure Questionnaire, then Approval to Incorporate, then the full application with VARA feedback, meetings and interviews (vara.ae Licence Applications page; Regulations IV.A.2 says the process is 'as prescribed'). No VARA figure for elapsed time has been located; the Public Register lists licensed VASPs.

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.