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Licence guide

Dubai VARA virtual asset licence.

Exchanges, broker-dealers and custodians building in Dubai’s mainland and free zones outside the DIFC hold this licence, with each virtual asset activity licensed on its own terms.

Published 16 October 2026 · Last reviewed 17 October 2026 · Reviewed against the regulator’s current publications
VARARegulator
AED 100k–1.5mPaid-up capital
AED 40k–100kApplication fee
AED 80k–200kAnnual supervision fee
6 to 9 months from the initial disclosure questionnaire, across both stagesOur realistic timeline

Firms we have licensed.

Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.

Since 2013Advising global payment firms
60+Countries licensed in
250+Licences obtained globally
Clients
ClearBankVolkswagenStaysureOval MoneyEMQCentus
nexpayPayment Institution

Obtained Nexpay’s FCA Authorised Payment Institution licence.

dzingElectronic Money Institution

Obtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.

Payment Institution

Obtained Orbital’s FCA Authorised Payment Institution licence.

What you get

6 to 9 months from the initial disclosure questionnaire, across both stagesLicence granted

Our realistic timeline from submission, set against the regulator’s own published figures.

Day oneReady to trade

Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.

Your teamKey people in place

Candidates introduced for two senior managers based in the UAE, each assessed against the regulator’s standard.

Same dayWritten proposal

A reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.

How the firm obtains the licence

  1. Scoping and proposal. The business model is mapped to VARA’s eight licensed activities, with the capital per activity, the custodian choice that sets it and the application and supervision fees confirmed in writing before the initial disclosure questionnaire.
  2. Application pack. The regulatory business plan, projections, governance framework, key personnel files, proof of paid-up capital, reserve account report, insurance certificates and succession and wind-down plans against VARA’s rulebooks.
  3. Banking. The UAE bank trust account for paid-up capital, the client fiat accounts and the operating accounts are arranged through the firm’s relationships before the decision, with the financial crime framework prepared to the standard those banks review.
  4. Regulator engagement. Both stages, approval to incorporate and the full submission after incorporation, office lease and staffing, run through one process with VARA’s questions answered, until the licence issues on payment of the fee balance and first-year supervision fee.

Key people, banking and technology

You will need two full-time senior managers who live in the UAE or hold UAE passports, approved by VARA before the licence and kept in post.

Key peopleThe firm introduces candidates for two senior managers based in the UAE from its register of senior compliance, financial crime, risk and finance professionals, and assesses each against the regulator’s approval standard before they are put forward.
BankingSafeguarding, operating and settlement accounts, card acquiring and payment processing, arranged through the institutions that serve regulated firms, in parallel with the application.
TechnologyBespoke white-label technology for accounts, payments, wallets and card programmes, built and ready to go live with the licence.

One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.

The licence in detail

The regulator’s requirements, capital, timing, fees and the questions firms ask, from the regulator’s own publications.

Key takeaways
  • Any firm carrying on virtual asset activities in or from Dubai, in the mainland or any free zone other than the DIFC, is licensed by VARA under Dubai Law No. 4 of 2022 and the Virtual Assets and Related Activities Regulations 2023 before it starts operating.
  • Eight activities are licensed separately: advisory, broker-dealer, custody, exchange, lending and borrowing, management and investment, transfer and settlement, and Category 1 issuance.
  • Paid-up capital is the higher of a fixed amount and a percentage of fixed annual overheads: from AED 100,000 for advisory to AED 800,000 or AED 1,500,000 for an exchange, held in a UAE bank trust account naming VARA as beneficiary or by surety bond.
  • The application fee is AED 100,000 for the main activities and AED 40,000 for advisory and transfer and settlement; the annual supervision fee is AED 200,000 or AED 80,000 per activity, and each additional activity costs 50% of the lower application fee.
  • Two responsible individuals, each a full-time employee and a UAE resident or passport holder, are approved by VARA and maintained at all times; a private office in Dubai is required for every activity except advisory.
  • Net liquid assets of at least 1.2 times monthly operating expenses, reserve assets equal to 100% of client liabilities held one-to-one in the same virtual asset, and professional indemnity, directors’ and officers’ and crime insurance are maintained throughout.

Who needs the licence

Exchanges, broker-dealers, custodians, lending platforms, virtual asset fund managers, transfer and settlement services and issuers of fiat-referenced tokens operating in or from Dubai need a VARA licence before they begin. VARA covers the Dubai mainland and every free zone except the DIFC, where the DFSA’s regime applies; elsewhere in the UAE the federal Securities and Commodities Authority regulates. A proprietary trader with no clients needs a no-objection certificate and, above a volume threshold, registration. Each activity is a discrete licence applied for separately, so an exchange that also offers custody and broker-dealer services holds three.

Activities, capital and fees

ActivityPaid-up capital (higher of)Application feeAnnual supervision fee
Advisory servicesAED 100,000AED 40,000AED 80,000
Broker-dealer servicesAED 400,000 or 15% of fixed overheads with a VARA-licensed custodian; otherwise AED 600,000 or 25%AED 100,000AED 200,000
Custody servicesAED 600,000 or 25% of fixed overheadsAED 100,000AED 200,000
Exchange servicesAED 800,000 or 15% of fixed overheads with a VARA-licensed custodian; otherwise AED 1,500,000 or 25%AED 100,000AED 200,000
Lending and borrowing servicesAED 500,000 or 25% of fixed overheadsAED 100,000AED 200,000
VA management and investment servicesAED 280,000 or 15% of fixed overheads with a VARA-licensed custodian; otherwise AED 500,000 or 25%AED 100,000AED 200,000
VA transfer and settlement servicesAED 500,000 or 25% of fixed overheadsAED 40,000AED 80,000
Category 1 issuance (fiat-referenced)AED 1,500,000 plus 2% of available supplyAED 100,000AED 200,000

Capital is held per activity and reconciled monthly. VARA may impose additional or varied fees according to the risk profile of the applicant.

What VARA requires

  • Entity and premises. A company incorporated through the Department of Economy and Tourism on the mainland or in a free zone other than the DIFC, after VARA’s approval to incorporate; a physical presence in Dubai, with a private office for every activity other than advisory.
  • Responsible individuals. Two responsible individuals, each a full-time employee, fit and proper, and a UAE resident or UAE passport holder, approved by VARA before the licence and maintained at all times; changes are pre-approved.
  • Capital and liquidity. Paid-up capital per activity in a UAE bank trust account naming VARA as beneficiary or by surety bond; net liquid assets of at least 1.2 times monthly operating expenses, reconciled daily and reported monthly.
  • Client assets and insurance. Reserve assets equal to 100% of client liabilities, held one-to-one in the same virtual asset, reconciled daily and audited every six months; professional indemnity, directors’ and officers’ and crime insurance.
  • Application pack. Certificate of incorporation, beneficial owner list, fit and proper confirmations, source of funds, governance framework, key personnel CVs and passports, regulatory business plan, financial projections, group financials, proof of paid-up capital, reserve account report, insurance certificates, succession plan, wind-down plan and close links analysis.
  • Rulebooks. Compliance with the Company, Compliance and Risk Management, Technology and Information and Market Conduct rulebooks and the rulebook for each licensed activity.

Capital

RequirementAmount
AdvisoryAED 100,000
Broker-dealerAED 400,000 or 15% of fixed overheads (VARA-licensed custodian); otherwise AED 600,000 or 25%
CustodyAED 600,000 or 25% of fixed overheads
ExchangeAED 800,000 or 15% of fixed overheads (VARA-licensed custodian); otherwise AED 1,500,000 or 25%
Lending and borrowing; transfer and settlementAED 500,000 or 25% of fixed overheads
Management and investmentAED 280,000 or 15% of fixed overheads (VARA-licensed custodian); otherwise AED 500,000 or 25%
Fiat-referenced issuanceAED 1,500,000 plus 2% of available supply
Net liquid assetsAt least 1.2 times monthly operating expenses

Capital is calculated per activity under Part VI of the Company Rulebook, held in trust for VARA or by surety bond, and reconciled monthly; reserve assets of 100% of client liabilities are held in addition.

Timing

FigureValueSource
Statutory decision periodNo statutory period; VARA publishes no processing timelineVirtual Assets and Related Activities Regulations 2023; VARA licence applications page
Application preparation8 to 12 weeksFrom instruction to submission, including banking in parallel
Our realistic timeline6 to 9 months from the initial disclosure questionnaire, across both stagesThe firm’s own figure, from the regulator’s published data and its own applications

Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.

Fees and costs

ItemAmountNotes
Application fee, main activitiesAED 100,000Broker-dealer, custody, exchange, lending and borrowing, management and investment, Category 1 issuance; about 50% paid at the initial disclosure stage, the balance before licence
Application fee, advisory and transfer and settlementAED 40,000Same split
Extension fee per additional activity50% of the lower application feeWhere more than one activity is applied for
Annual supervision fee, main activitiesAED 200,000Per activity; first year paid before the licence
Annual supervision fee, advisory and transfer and settlementAED 80,000Per activity
Risk-based variationAt VARA’s discretionVARA may impose additional or varied fees
Professional feesFixed, in writingQuoted after scoping

Geographic scope

The licence covers virtual asset activity in or from Dubai, mainland and free zones, excluding the DIFC. Elsewhere in the UAE the federal Securities and Commodities Authority regime applies. A VARA firm serving clients in the European Union holds a MiCA authorisation and one serving the United Kingdom the FCA cryptoasset authorisation; the firm obtains each.

Why applications are delayed

VARA states that it may refuse an approval to incorporate or a licence where the proposed activities fall outside its regulatory perimeter or its standards are not met, and that an application is not processed until the fees are received. From the published process, VARA looks for the following.

  1. Activities within the perimeter. A business model mapped to the eight licensed activities, with each applied for separately.
  2. Responsible individuals and premises in place. Two approved, resident, full-time responsible individuals and the private office leased before the full submission.
  3. Capital, reserves and insurance evidenced. Proof of paid-up capital in the trust account or bond, the reserve account report and the insurance certificates in the pack.
  4. Fees paid at each stage. About half the application fee at the initial disclosure stage, and the balance with the first-year supervision fee before the licence issues.

Banking

A virtual asset firm needs accounts for client fiat funds, separated from its own, and operating accounts in the markets it serves. Banks that serve the sector review the financial crime framework first: customer due diligence, transaction monitoring, travel rule arrangements and the wallet screening tools. The firm arranges the accounts through institutions that serve licensed virtual asset firms and prepares the framework they review alongside the application. See banking and payment processing.

Questions firms ask

How long does a VARA licence take?

VARA publishes no processing timeline. The process runs in two stages, approval to incorporate and then the full licence submission after incorporation, office lease and staffing; the firm plans for six to nine months across both.

What capital does an exchange need?

AED 800,000 or 15% of fixed annual overheads, whichever is higher, where a VARA-licensed custodian is used; otherwise AED 1,500,000 or 25%. Capital is held in a UAE bank trust account naming VARA as beneficiary or by surety bond.

What are the fees?

AED 100,000 on application for the main activities and AED 40,000 for advisory and transfer and settlement, each additional activity at 50% of the lower fee, and an annual supervision fee of AED 200,000 or AED 80,000 per activity.

Who must be in Dubai?

Two responsible individuals, each a full-time employee and a UAE resident or passport holder, approved by VARA, in a private office in Dubai for every activity other than advisory.

Does a VARA licence cover the DIFC or the rest of the UAE?

No. The DIFC is regulated by the DFSA and the rest of the UAE by the federal Securities and Commodities Authority.

References

  1. VARA: licence applications
  2. VARA: frequently asked questions
  3. Virtual Assets and Related Activities Regulations 2023, Schedule 2: fees
  4. VARA Company Rulebook, Part VI: capital and prudential requirements
  5. VARA Company Rulebook, Part I.C: responsible individuals
  6. VARA VA Issuance Rulebook: fiat-referenced virtual asset capital

About Buckingham Capital Consulting

A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm advises on authorisation, compliance, safeguarding, banking and transactions, and builds the white-label payment and card technology its clients launch on.

A written proposal on cost, timing and requirements, the same day: speak to an expert.

This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.

How we work.

  • Senior-ledEvery engagement is led by the practitioners who prepare the application and attend the regulator.
  • Same dayA reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing, before you commit.
  • ConfidentialYour plans, your application and any listing stay private. Clients are named only with their agreement.
  • Live workspaceEvery engagement runs in a shared workspace on Hector: documents, regulator questions, messages and progress in one place, visible to your team at every stage.

Why firms choose BCC.

  • OperatorsWe have taken firms through licensing, run regulated payments and consumer credit businesses, and signed the regulatory returns ourselves.
  • BankingSafeguarding, operating and settlement accounts arranged alongside the authorisation, through the institutions that serve this market.
  • FoundersThe firm is run by founders who have built and run regulated payments businesses, so every position is given with the launch date and the cost of waiting in mind.
  • One firmLicensing, key people, banking, compliance, technology and transactions from the same team, for the life of the regulated firm.

Apply for this licence.

The requirements, the cost and the timing for your business, in a written proposal the same day.