Dubai · VARA licence route
The Dubai VARA Licence, Without the Shortcuts
Most pages ranking here sell certainty Dubai's regulator never offers. The real route: eight named VA Activities under Law No. 4 of 2022, published fees and capital floors, two UAE-resident Responsible Individuals, and a staged process whose early approvals permit no client activity. SKY7 scopes and runs fresh VARA authorisations - honestly, including what cannot be shortcut.
- 8
- VA Activities named in Schedule 1 of the Virtual Assets and Related Activities Regulations 2023 - licensing is per activity.
- 2
- Full-time, UAE-resident Responsible Individuals every VASP must appoint and keep VARA-approved under the Company Rulebook.
- AED 40,000
- Lowest application fee on Schedule 2 - Supervision and Authorisation Fees; most activities pay AED 100,000 plus AED 200,000 yearly supervision.
- 51
- Entries on VARA's public register, licensed VASPs plus IPA holders, counted 10 July 2026 - Binance and OKX entities among the licensed.
The route in short
Law No. 4 of 2022 created VARA with writ over the whole Emirate, mainland and free zones alike, excluding only the Dubai International Financial Centre. Eight VA Activities are licensable under Schedule 1 of the Virtual Assets and Related Activities Regulations 2023, each with published fees and a paid-up capital floor. The process is staged, early approvals permit no client business, and VARA publishes no end-to-end timeline. Where the route sits in Dubai's wider picture is mapped in the Dubai VARA jurisdiction overview.
Read this first
An approval is not a licence, and there is no shortcut market
Two habits dominate this search. The first is treating VARA's early-stage approvals as licences. The public register is blunt about the In-Principle Approval: IPA holders "are strictly prohibited from initiating operations, conducting any virtual asset activities, or servicing clients until they have obtained their full VASP licence from VARA." The second is offering VARA licences "for sale". A licence attaches to the approved entity, its VARA-approved Responsible Individuals and its conditions; the Regulations publish no change-of-control procedure, so any ownership change is direct VARA engagement, and no adviser can guarantee its outcome.
Nobody ranking for these queries shows genuine VARA inventory in our review - and neither do we, as we say plainly further down. What follows is the route as the official sources state it, every figure traceable to rulebooks.vara.ae or vara.ae.
The legal frame
Law No. 4 of 2022, and exactly where VARA's writ ends
Dubai Law No. 4 of 2022 Regulating Virtual Assets established VARA in March 2022 as the sole authority for virtual assets across Dubai's mainland, Special Development Zones and free zones, except within the Dubai International Financial Centre. The operative instrument is the Virtual Assets and Related Activities Regulations 2023, issued 7 February 2023 and consolidated effective 19 June 2025, above four compulsory Rulebooks, activity rulebooks and directives. Virtual-asset business in or from the DIFC belongs to the DFSA; that perimeter is on the DIFC DFSA licensing page.
Above the Emirate sits a federal layer: Cabinet Resolution No. 111 of 2022 Regulating Virtual Assets and the Related Service Providers applies UAE-wide, with the Securities and Commodities Authority (SCA) as federal regulator, while ADGM (FSRA) and the DIFC (DFSA) run their own regimes. One nuance deserves precision: under the SCA-VARA agreement of 5 September 2024, a VASP licensed by VARA for Dubai is automatically registered with the SCA to service the wider UAE, while VASPs in other Emirates need SCA licensing - a default federal registration riding on a Dubai licence, not a UAE-wide licence, and it opens neither the DIFC nor ADGM. Which perimeter fits which model is mapped in VARA, ADGM or DIFC: which UAE licence fits.
The official numbers
Eight VA Activities: capital and fees from the named schedules
| VA Activity (Schedule 1) | Paid-up capital (Company Rulebook VI.B) | Application fee (Schedule 2) | Annual supervision (Schedule 2) |
|---|---|---|---|
| VA Activity (Schedule 1) Advisory Services | Paid-up capital (Company Rulebook VI.B) AED 100,000 | Application fee (Schedule 2) AED 40,000 | Annual supervision (Schedule 2) AED 80,000 |
| VA Activity (Schedule 1) Broker-Dealer Services | Paid-up capital (Company Rulebook VI.B) AED 400,000-600,000 or 15-25% of fixed annual overheads, whichever is higher | Application fee (Schedule 2) AED 100,000 | Annual supervision (Schedule 2) AED 200,000 |
| VA Activity (Schedule 1) Custody Services | Paid-up capital (Company Rulebook VI.B) AED 600,000 or 25% of fixed annual overheads | Application fee (Schedule 2) AED 100,000 | Annual supervision (Schedule 2) AED 200,000 |
| VA Activity (Schedule 1) Exchange Services | Paid-up capital (Company Rulebook VI.B) AED 800,000-1,500,000 or 15-25% of fixed annual overheads | Application fee (Schedule 2) AED 100,000 | Annual supervision (Schedule 2) AED 200,000 |
| VA Activity (Schedule 1) Lending and Borrowing Services | Paid-up capital (Company Rulebook VI.B) AED 500,000 or 25% of fixed annual overheads | Application fee (Schedule 2) AED 100,000 | Annual supervision (Schedule 2) AED 200,000 |
| VA Activity (Schedule 1) VA Management and Investment Services | Paid-up capital (Company Rulebook VI.B) AED 280,000-500,000 or 15-25% of fixed annual overheads | Application fee (Schedule 2) AED 100,000 | Annual supervision (Schedule 2) AED 200,000 |
| VA Activity (Schedule 1) VA Transfer and Settlement Services | Paid-up capital (Company Rulebook VI.B) AED 500,000 or 25% of fixed annual overheads | Application fee (Schedule 2) AED 40,000 | Annual supervision (Schedule 2) AED 80,000 |
| VA Activity (Schedule 1) Category 1 VA Issuance | Paid-up capital (Company Rulebook VI.B) As specified in the VA Issuance Rulebook, or any Annex thereto | Application fee (Schedule 2) AED 100,000 | Annual supervision (Schedule 2) AED 200,000 |
Reading the table
The mechanics behind the figures
The capital column is Part VI.B (Paid-Up Capital) of VARA's Company Rulebook; the fee columns are "Schedule 2 - Supervision and Authorisation Fees" of the Regulations. Where a range is shown, the band turns on custody: the lower Broker-Dealer and Exchange figures apply where client virtual assets sit with a VARA-licensed custodian. One naming trap: "VA Transfer and Settlement Services" replaced the earlier "Payments and Remittances Services" - pages selling the old name describe a label Schedule 1 no longer contains. Staking sits under VA Management and Investment Services.
Extending to further activities costs 50% of the lower Licence Application Fee(s); application fees are payable on submission, supervision fees in advance of the activity, and VARA may add risk-based supervision fees for scale, complexity and compliance history. In practice, roughly half the application fee is collected at ATI stage, the balance plus first-year supervision before issue. The full walk-through, including the figures consultancy pages get wrong, is in what a VARA licence costs in 2026. SKY7's own fees are quoted on request, after scoping.
The staged process
Four gates, and what each one actually permits
The process starts inside the commercial licensing system: the Initial Disclosure Questionnaire is filed with Dubai Economy and Tourism or the chosen free zone, screened there, and transferred to VARA. Eligible applicants receive an Application Acknowledgement Notice before the two substantive stages. VARA publishes no end-to-end timeline; the official framing is completeness of submissions and feedback rounds that "may include meetings, interviews, and submission of further documentation". Consultancy estimates run from roughly four to seven months to as long as twelve - treat all of them, including anything we say on a call, as estimates rather than commitments.
What the register's IPA category and announcements of "initial approval" do and do not mean is walked through in the two-stages explainer.
Stage by stage
IDQ to licence, as officially published
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Initial Disclosure Questionnaire (IDQ)
Filed with Dubai Economy and Tourism or the relevant free zone authority, screened by those licensing bodies, then transferred to VARA for assessment.
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Application Acknowledgement Notice (AAN)
Issued to eligible applicants confirming the file is in VARA's process. It confers no permission to conduct VA Activities.
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Stage 1: Approval to Incorporate (ATI)
Business plan, beneficial ownership and senior management go in; typically 50% of the application fee is paid. The ATI covers incorporation and setup - in VARA's words, "At this point, the firm is not permitted to carry on Virtual Asset activities."
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Stage 2: VASP licence
Remaining documentation and feedback rounds, then the balance of the application fee plus first-year supervision. The licence "may be subject to operational conditions" - only it permits serving clients.
Substance
What VARA expects to exist in Dubai
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A Dubai legal entity
Incorporated through Dubai Economy and Tourism or a Dubai free zone (the DIFC is outside VARA's perimeter), the IDQ filed through that body.
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Two Responsible Individuals
The Company Rulebook requires two individuals of sufficient seniority, responsible for all legal and regulatory compliance - full-time employees, UAE residents or UAE passport holders.
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Fit-and-proper approvals that stay current
Responsible Individuals must be VARA-approved Fit and Proper Persons; replacing one requires VARA's prior approval, and RI status is validated annually.
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Capital locked with VARA as beneficiary
Paid-up capital per Company Rulebook Part VI.B sits in a UAE trust account or surety bond naming VARA as beneficiary, not free on the balance sheet.
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A compliance stack that moves
Four compulsory Rulebooks plus each activity rulebook apply in their current versions - Version 2.0 came with a one-month compliance window in 2025.
The trade-offs
Where VARA is the wrong answer, honestly
The recurring cost is the real number: AED 200,000 a year in supervision for most activities, per activity, before any risk-based uplift, plus two full-time senior UAE-resident hires carried from before revenue - VARA publishes no salary benchmarks, so budget genuine payroll. The mid-process gate is just as real: a fully incorporated, capitalised company can sit at the ATI or IPA stage legally able to do nothing client-facing while Stage 2 runs, on a clock nobody has committed to. No adviser can guarantee approval or a date.
Territorially, a VARA licence is Dubai's perimeter with the SCA nuance above - not a DIFC permission, not an ADGM one. The regime moves quickly: Version 2.0 in May 2025 tightened margin trading and token distribution controls with a month to comply, and VARA publishes enforcement notices, including fines against named operators, so conditions bind. On fit, the advisory market's common reading - which we share - is that retail-facing exchange and brokerage models are VARA's home turf; institutional managers serving professional investors often sit better in ADGM or the DIFC.
Moving targets
Dated changes to track, as of July 2026
The regime evolves through rulebook versions and circulars, and four dates matter as of July 2026. Version 2.0 of the activity Rulebooks was issued on 19 May 2025, with full compliance required by 19 June 2025. A consultation on UAE implementation of the OECD Crypto-Asset Reporting Framework opened on 10 October 2025 - tax-information reporting for VASPs. The UAE Virtual Assets Travel Rule took effect on 24 February 2026. An implementation circular on UAE AML/CFT requirements applicable to VASPs followed on 4 March 2026. Statements on this page are made as of July 2026 and must be verified against vara.ae and rulebooks.vara.ae before you rely on them.
Inventory honesty
No VARA licences in stock, and the honest alternative
SKY7 holds no VARA-licensed company for sale today. When a licensed Dubai VASP changes hands, the work is regulatory, not transactional: the licence stays with the entity, replacement Responsible Individuals need prior VARA approval, the register entry - licence or mere IPA - is the first diligence item, and the Regulations publish no change-of-control shortcut. A real buyer's sequencing is in buying a VARA-licensed company in Dubai.
What we can show you is one live UAE lot in a different perimeter: a ready-made ADGM Category 3A licensed entity, regulated by the FSRA in Abu Dhabi Global Market. Stated plainly, an ADGM Financial Services Permission is not a VARA licence - different regulator, jurisdiction and regulated activities, with virtual-asset scope only through the FSRA's own framework, described on the ADGM FSRA licensing page. For buyers whose timeline cannot absorb fresh VARA authorisation, it is the honest in-stock option - and ownership changes there run through the FSRA's change-in-control approval of the new owner, never a transfer of the licence itself.
FAQ
Dubai VARA licence FAQ
Straight answers to what operators ask. If yours isn't here, ask us directly
01 What does a VARA licence cost in official fees?
Per "Schedule 2 - Supervision and Authorisation Fees": AED 100,000 application and AED 200,000 annual supervision for most activities; AED 40,000 and AED 80,000 for Advisory Services and VA Transfer and Settlement Services; extensions at 50% of the lower application fee; possible risk-based uplifts. Paid-up capital under Company Rulebook Part VI.B runs from AED 100,000 to AED 1,500,000 by activity and custody arrangements. SKY7 fees are quoted on request.
02 How long does VARA licensing take?
VARA publishes no end-to-end timeline on any official page; the process is framed around completeness of submissions and feedback rounds. Consultancy estimates range from roughly four to seven months up to a year - treat every such figure as an estimate, not a commitment. No adviser can guarantee a licensing date.
03 Is a VARA Initial Approval the same as a licence?
No. The public register calls an In-Principle Approval a conditional step: IPA holders are strictly prohibited from initiating operations, conducting any virtual asset activities or servicing clients until the full VASP licence is obtained. The Approval to Incorporate carries the same bar on carrying on VA activities - it covers incorporation and setup only.
04 Does a VARA licence cover the DIFC?
No. Law No. 4 of 2022 gives VARA authority across Dubai's mainland and free zones except the Dubai International Financial Centre. Virtual-asset business in or from the DIFC is regulated by the DFSA under its own Crypto Token regime - a different regulator, rulebook and fee schedule.
05 Can I operate across the whole UAE with a VARA licence?
Not as a single licence. Under the SCA-VARA agreement of 5 September 2024, a Dubai VASP licensed by VARA is automatically registered with the federal SCA to service the wider UAE; VASPs in other Emirates need SCA licensing. That default registration opens neither the DIFC nor ADGM.
06 I only trade my own crypto - do I need to register with VARA?
Above defined scale you must register - and registration is not a licence to serve clients. The Regulations require proprietary investors at or above USD 250,000,000 in rolling 30-day periods to register within three working days; VARA's FAQ states the trigger as trading above AED 1 billion in 30-day rolling volume. Both appear on official pages - test your book against both. Smaller proprietary investors may register voluntarily.
07 Can I just buy a VARA-licensed company instead of applying?
Not as a shortcut. The licence attaches to the approved entity, its VARA-approved Responsible Individuals and its conditions; there is no published change-of-control transfer mechanism, and diligence starts with whether the register entry is a licence or only an IPA. Genuine VARA inventory is scarce to non-existent. Where speed decides, the live alternative is our ready-made ADGM Category 3A entity - a different perimeter, stated plainly.
Go deeper
Guides for this route
What a VARA licence costs in 2026
The official Schedule 2 fee table, Company Rulebook capital floors, and the numbers consultancies get wrong.
Initial Approval is not a licence
The IDQ, AAN, ATI and IPA stages, with the official stage-gate wording at each step.
Buying a VARA-licensed company
Why there is no licence-transfer shortcut, what a buyer diligences, and how ownership changes engage VARA.
VARA, ADGM or DIFC: which perimeter fits
The three-regulator map of the UAE by business model - without a "best jurisdiction" verdict.
Dubai VARA route overview
The jurisdiction hub - framework, activities, process and every VARA guide in one place.
Reviewed by the SKY7 advisory team. Last reviewed: 11 July 2026. This page is general information only, not legal, regulatory, tax, investment or financial advice. VARA's Regulations, Rulebooks and fee and capital schedules are moving targets: statements on this page are made as of July 2026 and must be verified against the primary sources - vara.ae, rulebooks.vara.ae and the schedules named above - before you rely on them.
Tell us what you need
Get a straight answer on the Dubai route
Tell us your model, your clients and your timeline. We will tell you whether VARA, ADGM or the DIFC is your perimeter, what the official schedules will actually cost, and whether the in-stock ADGM entity beats a fresh application in your case - before you spend anything.