Business

Virtual Asset (Crypto) Business Approval in Dubai: VARA Licensing Process 

The process of getting a Dubai VARA crypto license begins by understanding the type of virtual asset activity you want to carry out. VARA is the body that controls virtual asset activities in Dubai, and a general commercial license cannot give you permission to conduct any crypto activities. The kind of approval needed for your business will depend on what category you fall into: Exchange, Broker-Dealer, Custodian, Advisory Firm, or any other Virtual Asset Service Provider (VASP). 

VARA licensing is applicable in Dubai mainland and most of Dubai free zones, while the DIFC operates in a separate regulatory regime. Normally, there are two phases involved in VARA licensing: the initial stage is the approval phase, while the second phase involves obtaining operational approval after VARA compliance and meeting governance and operational requirements. 

Not sure which Dubai VARA crypto license you need? Enterslice can help you find the right route for VARA licensing and assist you in all stages of licensing, from approval to operational readiness. 

What Is a Dubai VARA Crypto License? 

What the VARA license authorises 

The Dubai VARA crypto license allows for the operation by the Virtual Asset Service Provider (VASP) of certain types of regulated virtual asset services that have been sanctioned by the Virtual Assets Regulatory Authority (VARA). These can include Exchange, Broker-Dealer, Custody, Advisory, Lending and Borrowing, Transfer and Settlement, among others. The nature of sanctioning is determined based on the business model of the applicant and type of activity. 

A VARA license is not the same as a Dubai commercial license 

Requirement	Purpose	Authority
Commercial license	Establishes the legal entity	DET/free zone
ATI	Permits incorporation and setup	VARA process
VASP license	Authorises regulated VA activity	VARA
NOC/Registration	Activity-specific approval	VARA

The ATI enables the process of incorporation and preparation for operation but does not give the authority to carry out virtual asset operations. 

Why Are Crypto and Virtual Asset Activities Regulated in Dubai? 

Investor and Market Protection 

Regulations in Dubai exist for virtual asset activities to provide investor and consumer protection, preserve market integrity, foster innovation responsibly, and assist in the prevention of any financial crime. VARA regulates Virtual Asset Service Providers (VASPs) as well as formulates regulations aimed at fostering confidence and accountability within the virtual assets space. 

Regulatory Perimeter 

Classification plays an important role in obtaining a Dubai VARA crypto license. There are specific risks in terms of custody, market behaviour, technology, AML/CFT, and consumer protection for different business models. VARA’s regulatory regime is concerned with regulating virtual assets and VASPs, as well as investors and market participants, via activity-based regulation. 

Who Regulates Virtual Asset Businesses in Dubai? 

Role of VARA 

The Virtual Assets Regulatory Authority (VARA) is Dubai’s authority regulating the activities related to virtual assets. A Dubai VARA crypto license is obtained in accordance with the regulations of VARA and is mandatory for businesses offering regulated virtual asset services in the jurisdiction of VARA. 

DET and Dubai Free Zones 

For new license applications, the licensing pathway is made through Dubai Economy and Tourism (DET) or the respective Dubai free zone first and then through VARA’s licensing process. 

DIFC Is Independent 

The Dubai International Financial Centre (DIFC) is not covered by the VARA jurisdiction and functions under a different regulation. 

Which Crypto Activities Require a VARA License? 

Advisory Services 

This category pertains to businesses providing investment advisory services, investment recommendations, market advice, and other forms of strategic guidance to their clients. Professional advisory service provider companies must first get the appropriate VARA authorisation to conduct business. 

Broker-Dealer Services 

The Broker-Dealer Services category applies to companies that assist in, arrange for, or facilitate any transaction of virtual assets. This is typically applied to companies that act as intermediaries between buyer and seller. 

Custody Services 

Custody services involve the safekeeping, holding or control of customers’ virtual assets. These are companies that manage the assets of their customers directly, hence the need for stricter rules and regulations. 

Exchange Services 

Exchange Services involve platforms that offer markets for the purchase, sale, and exchange of virtual assets. These companies should adhere to standards of regulation concerning market operations and consumer protection. 

Lending, Management and Transfer Services 

Lending and Borrowing involves virtual asset lending products. Management and Investment applies to portfolio or asset management services, while Transfer and Settlement involve facilitating the movement of virtual assets from one party to another. 

VA Issuance 

Category 1 VA Issuance is regulated as a licensed activity. Category 2 VA issuance follows a separate approval framework and does not require a VARA License. However, all placement or distribution should be carried out by a licensed distributor. 

Business Model	Relevant VARA Route
Crypto advisory	Advisory Services
Crypto brokerage	Broker-Dealer
Crypto custody	Custody
Crypto exchange	Exchange
Crypto lending	Lending & Borrowing
Crypto fund management	Management & Investment
VA transfer infrastructure	Transfer & Settlement
Certain VA issuance	Category 1: VARA license / Category 2: No VARA License, but distribution through a licensed distributor

Choosing the right category of activity is one of the key considerations to be made during the application process for a Dubai VARA crypto license. 

Dubai VARA Crypto License Eligibility and Key Requirements 

Establish an Eligible Dubai Legal Entity 

The Dubai VARA crypto license can only be applied for by means of a legitimate entity incorporated with Dubai Economy and Tourism (DET) or a recognised Dubai free zone, not the DIFC. Typically, VARA will look for applicants who operate through legitimate corporate entities, such as an LLC or FZCO, and not through sole proprietorships. 

Fit and Proper Management 

Suitability for management of a regulated virtual asset business needs to be proven for senior management and important staff. The requirement to have Responsible Individuals who are full-time staff and undergo a fit and proper assessment is mandatory under VARA rules. Certain Responsible Individuals should also meet UAE residence criteria. 

Capital and Prudential Requirements 

The capital requirements will differ according to the regulated activity and the risk profile. Some examples are: 

Activity	Paid-Up Capital Requirement
Advisory	AED 100,000
Custody	Higher of AED 600,000 or 25% of fixed annual overheads
Lending & Borrowing	Higher of AED 500,000 or 25% of fixed annual overheads
Transfer & Settlement	Higher of AED 500,000 or 25% of fixed annual overheads
Exchange	Higher of AED 1.5 million or 25% of fixed annual overheads

The relevant capital requirement depends on the particular classification of activities and method of licensing. 

Documents Required for a VARA License in Dubai 

Corporate and Ownership Documents 

Documents required by applicants for a Dubai VARA crypto license usually include: 

• Certificate of incorporation 
• Ultimate Beneficial Owner (UBO)information 
• Organisation structure 
• Governance framework 
• Analysis of close links and associated entities 

Management and Financial Documents 

Documents which VARA may require include: 

• Fit and proper confirmations 
• CVs of senior management 
• Copies of passports of key personnel 
• Source of funds evidence 
• Financial projections 
• Group or entity financial statements 
• Evidence of paid-up capital 
• Reserve account details, where appropriate 

Operational and Risk Documents 

Documents included in the application form usually include: 

• Regulatory business plan 
• Insurance certificates 
• Succession plan 
• Wind-down plan 
• Technology, risk management, and compliance documents 

VARA License Application Form Document Requirements Checklist 

• Corporate records 
• Ownership disclosures 
• Management information 
• Financial evidence 
• Governance framework 
• Risk and compliance policies 

VARA application form document requirements are not exhaustive, meaning other documents can be requested during the application process. 

Need assistance in drafting your VARA application documents? Enterslice is here to help with document gathering and full-service support for your Dubai VARA crypto license application. 

Step-by-Step VARA Licensing Process in Dubai 

Step 1: Map the Business Model 

Specify exactly how you are going to utilise virtual assets, as the type of your business model will determine your regulatory approach. 

Step 2: Choose the Correct VA Activity 

Select the right kind of activity that falls under categories such as Advisory, Broker-Dealer, Custody, Exchange, Lending & Borrowing, Management & Investment, Transfer & Settlement, Category 1 Issuance, etc., or other VARA licensing processes. 

Step 3: Submit the Initial Disclosure Questionnaire 

Submit the Initial Disclosure Questionnaire (IDQ) through DET or the relevant Dubai free zone. 

Step 4: Apply for Approval to Incorporate 

Submit your business plan, beneficial owner details, senior management details, and other necessary documentation. The initial application fee should also be paid at this stage. 

Step 5: Complete the Incorporation Process and Set Up Your Business 

Following the receipt of ATI, set up your office, hire staff, create systems, and build governance structures and compliance arrangements. It should be noted that ATI does not authorise your operations with virtual assets. 

Step 6: Submit the VASP License Application 

Submit the full application. During the review process, VARA can ask for additional data or hold an interview. 

Step 7: Pay Licensing and Supervision Fees 

Pay the rest of the licensing fees and the first year’s annual supervision fee. 

Step 8: Obtain the VARA VASP License 

With regulated activity approval in the UAE, your company will receive their license, which may come with certain conditions. Fulfilling these steps is important to get a Dubai VARA crypto license. 

VARA License Fees and Other Costs 

Current VARA Application and Supervision Fees 

Activity	Application Fee	Annual Supervision Fee
Advisory	AED 40,000	AED 80,000
Broker-Dealer	AED 100,000	AED 200,000
Custody	AED 100,000	AED 200,000
Exchange	AED 100,000	AED 200,000
Lending & Borrowing	AED 100,000	AED 200,000
Management & Investment	AED 100,000	AED 200,000
Transfer & Settlement	AED 40,000	AED 80,000
Category 1 Issuance	AED 100,000	AED 200,000

License costs for Dubai VARA crypto licensing depend on the regulated business being operated. Businesses that wish to engage in additional licensed activities will also have license extension costs. 

Other Business Expenses 

Apart from VARA expenses, businesses must cater for: 

• Commercial or free zone license expenses 
• Office and personnel expenses 
• Professional advisors 
• Technology and security infrastructure 
• Insurance coverage 
• Compliance and governance structures 
• Applicable capital requirements 

Costs of these expenses differ depending on business model, activity type, and operational scale. 

How Long Does VARA Licensing Take? 

There is no set time frame to obtain a Dubai VARA crypto license. The process includes several steps and involves both approval in principle and an evaluation of the full license application. VARA may ask for further documentation, clarification, or evidence during its assessment process. Interviews or meetings with the management and the Responsible Individuals may also be a part of the review process. However, the entire duration of the assessment process depends on many things, including the nature of the proposed activity, the governance framework, technological capabilities, financial readiness, among others. 

Compliance and Renewal After Getting a VARA License 

Annual Renewal 

VARA crypto license issued for Dubai is valid for one year and needs to be renewed every 12 months. Notifications from VARA regarding the renewals are provided in advance, and the annual supervision fee needs to be paid upon renewal. 

Ongoing Capital and Prudential Compliance 

Capital requirements are not something that should be addressed once. The VASP with a VARA license needs to maintain the required paid-up capital, as well as adhere to the prudential requirements. It depends on the activity whether there are also requirements for net liquid assets, reserve assets and notification. 

AML/KYC, Technology and Market Conduct 

The rulebooks of VARA that VASPs need to follow include the Company, Compliance and Risk Management, Technology and Information, and Market Conduct frameworks. Besides, there are activity-specific rulebooks which depend on the licensed activity. 

Marketing Compliance 

Marketing compliance can apply to licensed and unlicensed organisations and to some foreign organisations carrying out activities under the VARA regulatory framework. 

Common Mistakes in Dubai VARA Licensing 

Applying for a general cryptocurrency license without indicating the particular virtual asset activity involved. 

• Presuming that having a Dubai Trade License also means having a crypto license. 
• Considering Approval to Incorporate as authorisation to start operating. 
• Choosing the DIFC jurisdiction without considering VARA regulation. 
• Not having a proper understanding of capital and prudential requirements. 
• Not designating competent Responsible Individuals. 
• Filing for incomplete governance, risk or compliance-related documents. 
• Starting marketing of virtual asset services without being sure of marketing compliance requirements. 
• Thinking that having one Dubai VARA crypto license suffices for all regulated activities. 
• Considering Category 2 VA issuance a normal VASP activity. 

VARA demands that every virtual asset activity be authorised separately, and further activities may also require different approvals. 

What Happens If You Operate Without VARA Approval in Dubai? 

Unlicensed Activity 

A business needs to have the proper authorisation to conduct regulated virtual asset activity in Dubai. A commercial license does not entitle businesses to undertake regulated virtual asset services when authorisation from VARA is needed. 

Enforcement Consequences 

VARA is able to enforce against businesses that are not complying with the regulations, such as: 

• Written reprimands 
• Enforcement notice 
• Fines and civil penalties 
• Increased regulatory supervision 
• And other enforcement measures permitted under its framework 

Real Enforcement Example 

Regulatory enforcement exists and operates in real life. For instance, in October 2025, VARA took regulatory action against 19 unregistered firms, issuing cease and desist notices and fines of between AED 100,000 and AED 600,000. 

A commercial license will not shield the operators from VARA enforcement if the underlying VA activities require VARA authorisation, including a Dubai VARA crypto license. 

How Enterslice Can Help with VARA Licensing? 

The Enterslice team assists enterprises that are interested in obtaining a Dubai VARA crypto license by analysing the appropriate regulatory perimeter and choosing the right license. The services provided by Enterslice include: 

• Analysis of business model and regulatory perimeter 
• Classification of activity and selection of the right approach to licensing 
• Entity and jurisdiction structuring in Dubai mainland and free zones 
• Preparation and review of application documents 
• IDQ and ATI process 
• Coordinating VARA application and communication with the regulator 
• Development of the compliance regime, including governance, AML/KYC, and risk management policies 

In case of entering into regulated virtual asset activities, enterprises have to first determine whether Regulated Activity Approval is required and which regulator-specific authorisation is needed. Enterslice will assist applicants in obtaining VARA licenses effectively. 

Conclusion 

Getting a Dubai VARA crypto license does not mean just applying for a single generic crypto license. In fact, the way to go about regulation will be dependent on what kind of virtual asset activity the business will carry out, which can be Advisory, Broker-Dealer, Custody, Exchange, Lending, Management, Transfer, and any other activity relating to issuance. Additionally, it is essential to note that approval to incorporate (ATI) does not automatically grant an entity permission to start operations, since commercial licensing is different from VARA licensing. 

After the approval is granted, businesses will still be expected to meet the requirements in relation to capital, governance, AML/KYC, technology, marketing, and supervision. Businesses will need to conduct an analysis of the business model prior to beginning the process of obtaining authorisation. 

Frequently Asked Questions