Timeline 6 to 9 months

Dubai VARA license

VARA is the world's first dedicated virtual assets regulator. A Dubai license provides one of the most credible and business-friendly regulatory frameworks available for crypto businesses operating globally.

What this enables

VARA-regulated virtual asset activities


A single entity can hold licenses for multiple activities. Each activity beyond the first is charged at 50% of the standard application fee.

Advisory services
Broker-dealer services
Custody services
Exchange services
Lending and borrowing services
Management and investment services
Transfer and settlement services
Virtual asset issuance

Whis this is for

This structure is suited to:

Crypto exchanges seeking a globally recognised, well-regulated jurisdiction

Custodians, wallet providers, and institutional VASPs

OTC desks and crypto brokers

Crypto funds and investment managers

Token issuance platforms and Web3 infrastructure businesses

Businesses scaling internationally that need a credible license as a regulatory foundation

Who this is for

This is not the right fit if:

You require EU regulatory access or EEA passporting — a Latvian CASP registration is more appropriate

You are not prepared to commit the required capital deposit (AED 400,000 to AED 600,000) and ring-fence it as a regulatory safeguard

Your operations will be based in the DIFC, which falls outside VARA's jurisdiction

Registration process

01

Approximately 1 to 2 months

Initial disclosure and approval
Submission of the Initial Disclosure Questionnaire to the relevant free zone authority or the Department of Economy and Tourism. VARA issues initial approval, permitting the entity to proceed with incorporation and setup. Business activity cannot begin at this stage.
Your responsibility: provide detailed business model information and UBO/director documentation. 50% of DM Strategy's project fee is payable at this stage.
Incorporation and documentation
Establishment of the Dubai legal entity and completion of commercial licensing. Preparation of all required regulatory policies: AML/CFT framework, risk management, IT security, data protection, governance structure, and regulatory business plan. Fit and proper forms submitted for all key personnel.
Your responsibility: identify and onboard key compliance personnel, confirm the capital deposit structure. 50% balance of DM Strategy's project fee is payable prior to document submission to VARA.

02

Approximately 1 to 2 months

03

Approximately 3 to 6 months

VARA review and license issuance
VARA conducts its full assessment. DM Strategy manages all ongoing communication and documentation requests. Once all requirements are satisfied, the license is granted.
Your responsibility: pay balance of VARA application fees and first-year supervision fees. Availability for regulatory queries during the review period.
Total timeline: approximately 6 to 9 months.
What is included

Included in scope

Business model review and license category assessment
Policy and procedure development: AML/CFT framework, governance structure, risk management, IT security and data protection
Application preparation and submission
Operational setup support: entity formation, office sourcing if required, key staff onboarding
Regulatory strategy and structuring advice
Regulatory business plan preparation
All communication with VARA throughout the review process
Fit and proper filings for shareholders, directors, and compliance officers

Not included

VARA application and annual supervision fees, capital deposit, incorporation costs, office rental, staff salaries.

Multi-Activity Structure

A single entity can hold licenses for multiple virtual asset activities under one VARA structure.

Costs and regulatory requirements

Application fees (per activity)

Item
Detail
Advisory services
AED 40,000
Transfer and settlement services
AED 40,000
Broker-dealer services
AED 100,000
Custody services
AED 100,000
Exchange services
AED 100,000
Lending and borrowing services
AED 100,000
Management and investment services
AED 100,000
Virtual asset issuance
AED 100,000
Each additional activity beyond the first
50% of standard application fee

Annual supervision fees (per activity, per year)

Item
Detail
Advisory services
AED 80,000
Transfer and settlement
AED 80,000
All other activities
AED 100,000 each

Capital deposit

Item
Detail
Third-party custody model
AED 400,000 — ring-fenced in UAE corporate bank account
Own custody model
AED 600,000 — ring-fenced in UAE corporate bank account

Example — exchange and custody combined

Item
Amount (AED)
Exchange services (first activity)
AED 100,000
Custody services (additional activity at 50%)
AED 50,000
Total application fees
AED 150,000
Total annual supervision fees
AED 200,000 per year
Common queries

Frequently asked questions

What is the capital deposit and how does it work?

VARA requires a separate regulatory capital deposit of AED 400,000 (third-party custody model) or AED 600,000 (own custody model). This is separate from incorporation capital, ring-fenced in a UAE corporate bank account, and cannot be used for operations. VARA does not hold the funds but expects them to remain untouched as a financial safeguard. The deposit is placed after initial approval.

Is a local UAE director or shareholder required?

No. VARA does not require a local UAE national or resident as a UBO or director. An in-house compliance officer is required and cannot be outsourced. The compliance officer can also act as the MLRO.

Can I apply for multiple activities under one license?

Yes. A single entity can hold licenses for multiple activities. Each activity beyond the first is charged at 50% of the standard application fee. Annual supervision fees apply per activity.

Does a VARA license cover the DIFC?

No. VARA governs virtual asset activities across Dubai Mainland and most free zones, including DMCC, DWTCA, and DAFZA. The DIFC operates under a separate regulatory framework and is not covered by VARA.

What are the ongoing compliance obligations after the license is granted?

Post-licensing obligations include annual supervision fees per activity, AML/CTF compliance, cybersecurity requirements, real-time reporting obligations, and independent audit functions. The compliance officer must remain in-house and cannot be outsourced.

Understand your regulatory path before starting

The initial call covers your business model, the appropriate license categories, and whether the VARA framework is the right regulatory path for your situation.

Get in Touch
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