Asia & Middle East · AE
Dubai / VARA
Dubai's Virtual Assets Regulatory Authority (VARA) licenses virtual asset businesses activity by activity across Dubai, including its free zones other than the DIFC.
At a glance
- Status
- Emirate-level regime within the UAE
- Region
- Asia & Middle East
- Regulated sectors
- Crypto
- Authorities
- VARA · DFSA
- Licensing routes
- 2
- See also
- United Arab Emirates
Overview
The framework
VARA was established in 2022 as the dedicated regulator for virtual assets in Dubai. Its jurisdiction covers mainland Dubai and Dubai's free zones, with the exception of the Dubai International Financial Centre (DIFC), where the DFSA regulates financial services, including activities involving crypto tokens.
Licences are activity-based: advisory, broker-dealer, custody, exchange, lending and borrowing, management and investment, and transfer and settlement services are licensed separately, alongside rules on virtual asset issuance and marketing. We map your model to these licences and prepare the filing.
Authorities
Who regulates what
- Virtual Assets Regulatory Authority (VARA)
- Licensing and supervision of virtual asset activities in Dubai, outside the DIFC.
- Dubai Financial Services Authority (DFSA)
- Financial services in the DIFC, including crypto token activities.
Regimes
Licensing routes
VASP licence (activity-based)
A separate licence for each regulated virtual asset activity, such as exchange, broker-dealer or custody services.
Sectors: Crypto
Virtual asset issuance
Rules for issuing virtual assets in or from Dubai.
Sectors: Crypto
Our Regulatory & Licensing practice prepares the applications for these routes and manages them through to the regulator's decision.
Considerations
What to weigh up
- Choose between VARA and the DIFC based on clients, products and the legal system you need.
- Plan marketing to people in Dubai within the virtual asset marketing rules, which also apply to firms licensed elsewhere.
- Plan local substance and resident management; both are expected.
This overview is general information, summarised at a high level. Requirements change and depend on the specific activity; seek advice on your circumstances before acting.
Industries
Relevant industries
Across jurisdictions
Cross-jurisdiction capabilities
Services we support across the jurisdictions in our directory, described once on their own pages. We deliver each to the requirements that apply locally, coordinating local specialists where local law, registration, representation or professional requirements require it.
- Privacy & Data ProtectionExternal DPO services and working privacy programmes: GDPR and global privacy laws, DPIAs, data mapping, transfers and ISO/IEC 27701.
- Information Security & CybersecurityFractional CISO support, ISMS and security programmes, certification and audit readiness, DORA, NIS2 and customer assurance for enterprise sales.
- AI GovernanceGovernance that lets AI adoption scale: EU AI Act readiness, ISO/IEC 42001 management systems, AI risk and impact assessments, and vendor risk.
- AML & Financial Crime ComplianceAML/CFT programmes, MLRO-as-a-Service, independent AML/CFT audits, risk assessments, monitoring, sanctions and inspection support.
- IP Registration & ProtectionTrademark and patent registration, copyright, domain disputes and enforcement that protect your brand, software and content across markets.
- Legal OpinionsRegulatory, business model, perimeter, payment, gaming, crypto-asset and cross-border opinions that answer what banks and investors ask.
- Bank Account OpeningHelp organising your banking with banks and EMIs that fit your model, from the onboarding file and account structure to periodic reviews.
- Merchant Account / Acquiring SetupMerchant applications, acquiring structure and negotiated terms for online and high-risk merchants that need stable card and local payment acceptance.
Support
Dubai / VARA: how we support your business
- Regulatory & LicensingStrategy, applications and regulator engagement for the crypto routes listed above.
- Corporate StructuringGroup architecture, incorporation, substance and governance built around your licences, banking and investors.
- Market Entry & Regulatory StrategyMarket prioritisation, regulatory roadmaps and launch readiness that let you expand into new jurisdictions in the right order.
Dubai / VARA: the right fit for your business?
We look at your product, target clients and banking needs to see whether this jurisdiction fits or another would serve you better, then send a written proposal with scope, timetable and fee.