Why the first cost figures you find are usually wrong
Run the obvious searches and you meet a wall of consultancy cost pages. When we mapped that landscape in July 2026, no official vara.ae page appeared in the top results, the pages disagreed with one another, and one widely read page put exchange capital at AED 15,000,000. The Company Rulebook's published requirement for Exchange Services is AED 800,000 to AED 1,500,000 depending on custody arrangements - the circulating claim is ten times the top of the official band.
The problem is a pattern, not any single firm: cost pages blend regulator fees, service fees, entity setup and salary guesses into one "total cost", usually without naming a source. The discipline here is simple: a figure appears only if a named official schedule publishes it; everything else is labelled a market estimate.
Schedule 2 - Supervision and Authorisation Fees, per VA Activity (as of July 2026)
| VA Activity | Licence application fee | Annual supervision fee |
|---|---|---|
| VA Activity Advisory Services | Licence application fee AED 40,000 | Annual supervision fee AED 80,000 |
| VA Activity Broker-Dealer Services | Licence application fee AED 100,000 | Annual supervision fee AED 200,000 |
| VA Activity Category 1 VA Issuance | Licence application fee AED 100,000 | Annual supervision fee AED 200,000 |
| VA Activity Custody Services | Licence application fee AED 100,000 | Annual supervision fee AED 200,000 |
| VA Activity Exchange Services | Licence application fee AED 100,000 | Annual supervision fee AED 200,000 |
| VA Activity Lending and Borrowing Services | Licence application fee AED 100,000 | Annual supervision fee AED 200,000 |
| VA Activity VA Management and Investment Services | Licence application fee AED 100,000 | Annual supervision fee AED 200,000 |
| VA Activity VA Transfer and Settlement Services | Licence application fee AED 40,000 | Annual supervision fee AED 80,000 |
Two fee tiers, the 50% extension rule, and when you pay
Schedule 2 is blunt. Advisory Services and VA Transfer and Settlement Services sit in the lower tier: AED 40,000 to apply and AED 80,000 a year in supervision. Every other activity pays AED 100,000 and AED 200,000. One vocabulary check: VA Transfer and Settlement Services replaced the retired Payments and Remittances Services category, so a quote built on the old name is working from a stale rulebook.
Licensing several activities does not multiply the application fee. An extension is charged at 50% of the lower application fee, so an exchange adding Broker-Dealer Services pays AED 100,000 plus AED 50,000, not AED 200,000. Supervision offers no discount: it applies per activity, so the same combination carries AED 400,000 of supervision every year.
Timing is part of the price. The Regulations state that "the application will not be processed until the payment of these fees is received"; in the published process, roughly half the application fee is collected at the Approval to Incorporate stage, and the balance plus the first year's supervision fee falls due before the licence is issued. You fund a full supervision year before you may serve a single client - and at the Approval to Incorporate and In-Principle Approval stages, no virtual asset activity is permitted at all, a gate we unpack in VARA licensing in two stages.
Risk-based uplifts: the schedule is a floor
The same schedule reserves VARA's right to levy additional risk-based supervision fees, calibrated to market share, client base, complexity and compliance history. A small advisory boutique will plausibly live at the published figures; a retail exchange at scale should treat AED 200,000 per activity as the starting point and budget for the uplift conversation.
Regulatory change is the other recurring cost the table does not show. VARA issued Version 2.0 of its activity rulebooks on 19 May 2025 and required full compliance by 19 June 2025 - a 30-day window. Re-papering margin and distribution arrangements on that cadence is real compliance spend, and it will recur; verify the current rulebook versions on rulebooks.vara.ae before you budget.
Paid-up capital: what moves the bands
Fees buy the regulator's attention; capital is the larger commitment. Part VI.B of the Company Rulebook sets minimum paid-up capital per activity, and for most activities the requirement is the higher of a fixed floor or a percentage of fixed annual overheads - a heavy cost base raises the requirement even within a single activity.
The bands also reward independent custody. Exchange Services is capitalised at AED 800,000 (or 15% of overheads) with a VARA-licensed custody provider and AED 1,500,000 (or 25%) without; Broker-Dealer Services works the same way across its AED 400,000-600,000 band. Custody structure is therefore a capital decision as much as an operational one.
Minimum paid-up capital - Company Rulebook, Part VI.B (as of July 2026)
| VA Activity | Minimum paid-up capital |
|---|---|
| VA Activity Advisory Services | Minimum paid-up capital AED 100,000 |
| VA Activity Broker-Dealer Services | Minimum paid-up capital AED 400,000-600,000, or 15-25% of fixed annual overheads if higher; lower band where a VARA-licensed custodian holds client virtual assets |
| VA Activity Custody Services | Minimum paid-up capital AED 600,000, or 25% of fixed annual overheads if higher |
| VA Activity Exchange Services | Minimum paid-up capital AED 800,000 (or 15% of overheads) with a VARA-licensed custody provider; AED 1,500,000 (or 25%) without |
| VA Activity Lending and Borrowing Services | Minimum paid-up capital AED 500,000, or 25% of fixed annual overheads if higher |
| VA Activity VA Management and Investment Services | Minimum paid-up capital AED 280,000-500,000, or 15-25% of fixed annual overheads if higher |
| VA Activity VA Transfer and Settlement Services | Minimum paid-up capital AED 500,000, or 25% of fixed annual overheads if higher |
| VA Activity Category 1 VA Issuance | Minimum paid-up capital As specified in the VA Issuance Rulebook or any Annex thereto |
The capital sits in trust, with VARA as beneficiary
Paid-up capital under the Company Rulebook is not a balance you quietly spend. It must be held in a trust account with a licensed bank in the UAE with VARA stated as the beneficiary, covered by a surety bond naming VARA as beneficiary, or held in another manner VARA specifies. The regulator, not the shareholder, controls that safety net - treasury planning treats it as committed funds alongside, not inside, working capital for as long as the licence lives.
What VARA does not publish
No processing timeline. VARA publishes no statutory or indicative processing time in the material we reviewed; the consultancy estimates that rank run from four to seven months to six to twelve, and they cannot all be right. Treat every timeline as an unverified market estimate.
No people costs. The published requirement is two full-time, VARA-approved Responsible Individuals, each a UAE resident or a UAE passport holder. What their seniority costs is not published: market estimates circulate around AED 200,000-500,000 and above per individual per year - we pass those on strictly as market colour. Office costs are the same story: advisers quote square-footage rules of thumb we cannot find in VARA's published rulebooks.
No all-in price. Entity setup through Dubai Economy and Tourism or a Dubai free zone (the DIFC excluded), visas, audit and advisory fees are real costs, and none of them are VARA numbers. Any "total cost of a VARA licence" figure is the seller's bundle, not the regulator's schedule.
Are you pricing the right perimeter?
One last check: these schedules govern the Emirate of Dubai excluding the DIFC. The DIFC prices through the DFSA's separate fee and capital modules, ADGM in Abu Dhabi through the FSRA's, and the SCA holds the federal layer for the wider UAE - three rulebooks, none interchangeable, and no figure from one perimeter prices another. If you are weighing centres as well as costs, start with our three-perimeter comparison.
Five checks before you trust a VARA cost quote
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Does it name the schedule?
Fees come from Schedule 2 - Supervision and Authorisation Fees; capital from Company Rulebook Part VI.B. A number that cannot name its source is a guess.
-
Does it separate regulator money from adviser money?
Application and supervision fees go to VARA; setup, visas and consulting fees do not. A blended total hides the split.
-
Which capital band - and why?
Exchange and broker-dealer bands turn on whether a VARA-licensed custodian holds client assets, and the overheads percentage can override the floor.
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Is the timeline sold as fact?
VARA publishes none. A confident end-to-end date is a marketing artefact, and no adviser can guarantee approval.
-
Is first-year supervision in the budget?
The final licensing step collects the remaining application fee plus a full year's supervision fee before any client work is permitted.
- AED 40,000
- lowest Schedule 2 application fee - Advisory Services
- AED 200,000
- annual supervision per heavier VA Activity, before risk-based uplifts
- 50%
- of the lower application fee for each additional VA Activity
- AED 1,500,000
- Exchange Services minimum capital without a VARA-licensed custodian
FAQ
Frequently asked questions
01 How much does a VARA licence cost in 2026?
The published numbers per VA Activity, as of July 2026: an application fee of AED 40,000-100,000, an annual supervision fee of AED 80,000-200,000, and minimum paid-up capital between AED 100,000 and AED 1,500,000 - or a percentage of fixed annual overheads if that is higher. Setup, people and advisory costs come on top and are not published by VARA.
02 Is the AED 15 million capital requirement for a Dubai crypto exchange real?
Not in the published rulebook. Company Rulebook Part VI.B sets Exchange Services capital at AED 800,000 with a VARA-licensed custody provider or AED 1,500,000 without, or 15-25% of fixed annual overheads if higher. Ask any source quoting a different figure to name its schedule.
03 How long does a VARA licence take to obtain?
VARA publishes no timeline. Consultancy estimates run from 4-7 to 6-12 months and conflict; treat them as unverified market estimates. Until the licence issues - including at the Approval to Incorporate and In-Principle Approval stages - no virtual asset activity is permitted.
04 Can we use the paid-up capital as working capital?
No. The Company Rulebook requires it held in a UAE trust account or under a surety bond with VARA stated as the beneficiary, or as VARA otherwise specifies. Budget it as committed funds alongside, not instead of, operating cash.
05 Do fees multiply if we license several VA Activities?
Application fees are softened: each additional activity is charged at 50% of the lower application fee. Annual supervision is not - it applies per activity, and VARA can add risk-based supervision fees on top.
Keep reading
Related reading
Dubai VARA licence: the full route
Scope under Law No. (4) of 2022, the eight VA Activities, process and requirements - the complete picture.
VARA licensing in two stages: Initial Approval is not a licence
What the Approval to Incorporate and In-Principle Approval stages actually permit - and the gate most announcements skip.
VARA, ADGM or DIFC: which UAE licence fits
Three regulators, three fee and capital regimes - how to choose by business model, not headline.