Advisory Services
Give a client a personal recommendation about a virtual-asset action or transaction. General education and personalised advice are different things.
← Knowledge HubCrypto business · start with the service
Understanding VARA licensing.
A crypto business needs permission for what it actually does. Buying for clients, holding their assets and running a trading platform are different services.
VANTABLACK / THE CONNECTED ROUTE
Follow the numbered routeCheck the service before the virtual-asset route.
Select a checkpoint for detail
01Define the actual VA serviceView checkpoint
Business facts and scope to clarify
02Check jurisdiction & exclusionsView checkpoint
Sources, evidence and open questions
03Map approvals & resourcesView checkpoint
Required records and responsibilities
04Prepare the application evidenceView checkpoint
Evidence, review and unresolved gaps
05Complete authority reviewView checkpoint
Written scope and acceptance
06Operate within permissionView checkpoint
Activity, conditions and issued record
VARA authorisation is separate from company formation. Activities, issuance categories, resources and any financial-centre exclusions must be checked in the detail below.
Read the steps
- Define the actual VA service — Business facts and scope to clarify
- Check jurisdiction & exclusions — Sources, evidence and open questions
- Map approvals & resources — Required records and responsibilities
- Prepare the application evidence — Evidence, review and unresolved gaps
- Complete authority review — Written scope and acceptance
- Operate within permission — Activity, conditions and issued record
Two permissions. Different jobs.
- Register the company
Your commercial licence establishes the business.
- Approve the crypto services
VARA reviews the activities and how they will be controlled.
- Check the operating conditions
Start only when the full licence and its conditions allow it.
Which service will you provide?
Broker-Dealer Services
Arrange, accept or carry out crypto orders, or bring buyers and sellers together. Some distribution and dealing models also belong here.
Exchange Services
Run a facility that trades or converts assets, matches orders or maintains an order book. A business name alone cannot settle the category.
Custody Services
Safeguard another person’s crypto and act on verified instructions. Who controls the keys and can move the assets is a key question.
Lending and Borrowing Services
Arrange a contract where crypto is lent and must be returned. The funding, repayment and customer risks need to be mapped.
Management and Investment Services
Manage virtual assets for someone else. Taking responsibility for staking can also fall within this category.
Transfer and Settlement Services
Move or settle virtual assets for another party. Moving value for customers is different from only selling software.
Category 1 VA Issuance
Issue fiat-referenced or asset-referenced virtual assets under the Category 1 rules. The token’s rights, backing and redemption model matter.
These are plain-language starting points, not complete legal definitions.
Each activity must be expressly applied for; approved combinations depend on the model.
Token issuance has separate categories below.
Calling a token an NFT does not settle its treatment.
Launching a token: three different categories.
Category 1 · licence required
Fiat-Referenced VAs (FRVAs) and Asset-Referenced VAs (ARVAs) fall here, alongside any other assets VARA places in this category. A VARA licence and approval of the Whitepaper before each issuance are required. Backing a token with property or commodities is not a route around regulation.
Category 2 · licensed distribution
The current Issuance Rulebook does not require the issuer to obtain a VARA licence or prior approval if all placement and distribution is through or by a Licensed Distributor. That distributor must check the issuer and token and follow its own regulatory submission process. This is not unrestricted self-distribution or VARA endorsement.
Exempt VAs · conditions still apply
The issuance category covers qualifying non-transferable and redeemable closed-loop VAs, and any other VAs VARA determines.
No pre-issuance requirements apply, but the issuer must comply with Part II and remains subject to supervision.
A product label alone does not establish eligibility.
Conflicting FAQ wording · confirm with VARA
VARA’s FAQ still describes prior approval for Category 2. The current Issuance Rulebook says no issuer prior approval under the licensed-distributor conditions, supported by the April guidance. Confirm the classification and filing route with VARA before launch. Anonymity-enhanced cryptocurrencies are prohibited.
VA Issuance Rulebook · Part I · VA Issuance guidance · 9 April 2026 · VARA FAQs · checked 20 October 2026
From idea to permission
- Map the business
Who pays you, who holds the assets, and who controls each transaction?
- Apply through DET or a Dubai free zone
Submit the initial disclosure and business information.
- Approval to Incorporate
Set up the company, team, office and controls. No client operations yet.
- Full licence and conditions
Complete the detailed review and meet the permitted operating scope.
VARA licence applications · checked 20 October 2026
How are application payments staged?
VARA’s application page says the initial payment is typically 50% of the application fee; the balance and first annual supervision fee are paid during the full-licence stage. Schedule 2 says application fees are due on submission and processing waits for payment. Confirm the instalments, due dates and refund treatment in your application instructions; do not treat a typical split as a universal entitlement.
VARA licence applications · VARA Regulations · Schedule 2 · checked 20 October 2026
Check these boundaries before spending
Where will the business operate?
VARA covers Dubai mainland and its free zones, excluding DIFC. DIFC and ADGM have different regulatory frameworks. Payment-token services also need a UAE Central Bank scope check; a VARA application does not settle every regulatory perimeter.
Are you only trading your own money?
VARA’s FAQ calls for a proprietary-trading NOC through DET or the free zone. Registration also applies at high trading volumes. Its FAQ contains conflicting AED and USD thresholds: confirm with VARA rather than relying on one figure. Trading for friends, family or third-party customers is not automatically own-account trading.
Will trading and custody share a company?
Plan proprietary trading separately from a licensed service-provider business, and confirm the proposed group arrangement with VARA. Custody must be a separate legal entity from group companies providing other VA activities, except that Transfer & Settlement may also be licensed in that entity subject to VARA’s approval and segregation requirements. Staking from custody requires explicit additional authorisation.
Technology, metaverse or NFT marketplace?
Providing technology or metaverse services does not automatically require a VASP licence; performing a regulated VA activity does. VARA’s FAQ says an NFT marketplace needs Exchange and/or Broker-Dealer permission according to its actual services. Map the transactions and asset control, not only the commercial activity name.
VARA FAQs · Custody Services Rulebook · Introduction · Staking from custody · authorisation · checked 20 October 2026
VARA fees: application and annual supervision.
These are the regulator’s charges, not Vantablack package prices. The table shows the application fee for one activity and annual supervision for each activity.
| Activity | Application · one activity | Annual supervision · per activity |
|---|---|---|
| Advisory | AED 40,000 | AED 80,000 |
| Broker-Dealer | AED 100,000 | AED 200,000 |
| Category 1 VA Issuance | AED 100,000 | AED 200,000 |
| Custody | AED 100,000 | AED 200,000 |
| Exchange | AED 100,000 | AED 200,000 |
| Lending & Borrowing | AED 100,000 | AED 200,000 |
| Management & Investment | AED 100,000 | AED 200,000 |
| Transfer & Settlement | AED 40,000 | AED 80,000 |
For each additional activity, Schedule 2 sets an extension fee of 50% of the lower application fee(s). Annual supervision is payable in advance of conducting the activity. VARA may adjust or add fees for risk and may charge separately for issuance applications or Whitepaper submissions.
VARA Regulations · Schedule 2 · checked 20 October 2026
DET/free-zone charges, office, staff, technology, audit, insurance and Vantablack’s fees are separate. Obtain a scoped quote rather than adding only the headline application fee.
Paid-up capital: money the business must maintain.
Capital is not a licence fee. Where the rule uses “higher of”, the overhead calculation may produce a requirement above the stated AED amount.
| Activity | Operating arrangement | Capital requirement |
|---|---|---|
| Advisory | All | AED 100,000 · fixed |
| Broker-Dealer | VARA-licensed custodian, or arrangement otherwise approved during licensing | Higher of AED 400,000 or 15% of fixed annual overheads |
| Broker-Dealer | Other arrangements | Higher of AED 600,000 or 25% of fixed annual overheads |
| Custody | All | Higher of AED 600,000 or 25% of fixed annual overheads |
| Exchange | VARA-licensed custodian, or arrangement otherwise approved during licensing | Higher of AED 800,000 or 15% of fixed annual overheads |
| Exchange | Other arrangements | Higher of AED 1,500,000 or 25% of fixed annual overheads |
| Lending & Borrowing | All | Higher of AED 500,000 or 25% of fixed annual overheads |
| Management & Investment | VARA-licensed custodian, or arrangement otherwise approved during licensing | Higher of AED 280,000 or 15% of fixed annual overheads |
| Management & Investment | Other arrangements | Higher of AED 500,000 or 25% of fixed annual overheads |
| Transfer & Settlement | All | Higher of AED 500,000 or 25% of fixed annual overheads |
| Category 1 VA Issuance | Token-specific | Requirements in the Issuance Rulebook and its applicable annexes |
Capital applies to each approved activity, using its allocated fixed annual overheads without double-counting or omitting costs. Reconcile monthly. Approved forms include a UAE-bank trust account naming VARA as beneficiary, a qualifying surety bond without an end date, or another arrangement VARA specifies.
Company Rulebook · Part VI · checked 20 October 2026
Fees, capital and operating costs are different budgets.
Planning example · an exchange using an approved custodian
AED 800,000Capital floor · or 15% of fixed annual overheads, if higher
AED 100,000Application fee · one activity
AED 200,000Annual supervision · that activity
Do not read these amounts as an all-in setup price or add them as if they were the same type of expense. Separate operating cash, liquidity, client reserves, staffing, office, technology, audit, insurance and other authority or adviser fees must also be funded.
Company Rulebook · Part VI · VARA Regulations · Schedule 2 · checked 20 October 2026
Keep financial protection in place after licensing.
Liquidity · not just a bank balance
Net Liquid Assets are current liquid assets minus current liabilities. Maintain at least 1.2 × monthly operating expenses, reconcile daily and report monthly. Allowed assets are cash/cash equivalents or VARA-approved USD/AED-referencing VAs; the agreed operational VA exposure counts towards liabilities.
Client reserves · separate from capital
Maintain reserves equal to 100% of client VA liabilities, held one-to-one in the same VA. Reconcile daily and obtain an independent third-party audit at least every six months. These are client-protection obligations, not money available to fund setup.
Insurance · part of the operating model
The Company Rulebook requires professional indemnity, directors’ and officers’, commercial crime cover for hot-wallet VAs, and any further cover VARA specifies.
Use a regulated insurer.
Any alternative protection or group policy must meet VARA’s conditions.
A shortfall needs immediate action
Notify VARA immediately if capital, liquidity, insurance or reserve requirements cannot be maintained.
Provide daily updates until corrected and accepted, unless VARA directs otherwise.
VARA may require additional protection for the firm’s risk profile.
Company Rulebook · Part VI · checked 20 October 2026
A practical readiness check
People and responsibility
Appoint two Responsible Individuals: sufficiently senior, full-time, Fit and Proper, UAE resident or UAE passport holder, and VARA-approved. Proposed changes need prior approval, with an immediate-notification exception for reasonably unforeseen circumstances. Plan qualified senior management, a Compliance Officer and an independent Company Secretary reporting to the Board.
Board and ownership
Each Board member must be assessed as Fit and Proper and approved by VARA, with ongoing annual reviews and training. The Compliance Officer and head of internal audit cannot sit on the Board. Maintain a transparent ownership chain to the UBOs; material ownership or structure changes require prior written approval.
Entity and office
VARA’s FAQ prefers an LLC or FZ-CO and does not accept sole proprietorships. Applicants face no nationality restriction. Physical presence is required; a private office is specified for all the licensed activities except Advisory. VARA sets no minimum office area, but the commercial licensor may have its own space rules.
Clients and permitted scope
Retail access depends on licence approval and conditions. VARA may restrict a firm to Qualified Investors or institutional clients. Confirm the activities, client classes and status on the Public Register; an in-principle approval is not permission to operate.
Company Rulebook · Part I · VARA FAQs · VARA Public Register · checked 20 October 2026
Prepare the full application: a practical document checklist
This is a preparation list, not a promise that it is complete or identical for every activity. VARA’s instructions following initial approval determine the final submission.
Ownership & people
Entity documents, ownership/UBO chart, source-of-funds evidence, Fit and Proper confirmations, organisation chart, key-personnel CVs and role descriptions.
Business & financial readiness
Regulatory business plan, customer journey, forecasts and group/entity financial statements, capital evidence, reserve arrangements, insurance, banking arrangements, succession and wind-down plans.
Governance & compliance
Governance, conflicts and outsourcing arrangements; compliance manual; AML/CFT, anti-bribery and risk policies; client terms, complaints handling and relevant listing policies.
Technology & continuity
Security and operational architecture, technology controls, continuity and disaster recovery plans, and applicable public wallet addresses. Never disclose private keys or seed phrases in an application enquiry.
VARA licence applications · checked 20 October 2026
Customer journeys, policy detail, banking arrangements and wallet materials vary by activity; confirm the final submission checklist with VARA.
Marketing permission is not operating permission.
Current rules apply beyond licensed firms
The Marketing Regulations effective in October 2024 apply to domestic and foreign entities, whether licensed or not. Marketing VA activities in or targeting the UAE generally must be by, or on behalf of and approved by, a VARA-licensed VASP. Exemptions and conditions need a separate check.
Unlicensed firms: do not rely on the older FAQ alone
The FAQ describes marketing permits with no Dubai-resident onboarding. The current regulations contain narrower rules, including a limited physical-event exemption. At those events an unlicensed firm cannot sign up or onboard UAE residents and must clearly disclose its unlicensed status. Confirm the intended campaign with VARA.
Events and outdoor advertising
The FAQ directs event organisers to DET’s e-Permit system and outdoor advertising to Dubai Municipality’s advertising system.
An event or advertising permit does not replace the current marketing rules or permission to provide a regulated service.
Keep the message factual
Do not imply guaranteed returns, safety or regulatory endorsement. Plan for fair, clear communications, risk disclosures and the permitted audience. Penalties can extend beyond fines to restrictions or closure.
Marketing Regulations · current framework · Marketing · general prohibitions · Marketing · physical events · VARA FAQs · checked 20 October 2026
After licensing: build a reporting calendar.
Licensing begins ongoing supervision. This is a selected baseline, not a complete calendar for every activity or licence condition.
| When | What to plan |
|---|---|
| Before relevant changes | Obtain approvals where required for material ownership/structure, Responsible Individuals and activity-specific changes; not every notification is a prior approval. |
| Daily | Reconcile Net Liquid Assets and client reserve assets. Notify financial-protection shortfalls immediately. |
| Monthly | Reconcile capital; report Net Liquid Assets, financial information, wallet addresses and applicable group/related-party transactions. |
| Quarterly | Submit Board/committee minutes, financial-compliance statements, projections and risk exposure reports. |
| At least every six months | Independent audit of reserve assets. |
| Annually | Audited financial statements and control assurance, compliance assessment, ownership/people and product information; renew the licence and pay supervision fees. |
| When incidents occur | Report breaches immediately; apply the specific cybersecurity and other notification rules. |
Company Rulebook · Part VI · Company Rulebook · Part I · Compliance Rulebook · regulatory reporting · Compliance Rulebook · notifications · VARA FAQs · checked 20 October 2026
The FAQ describes an annual licence, a 12-month renewal and notice 90 days ahead; the annual supervision fee is payable at renewal. Put the actual expiry and licence-specific reporting deadlines in the firm’s compliance calendar.
VARA FAQs · checked 20 October 2026
Supervision follows the firm’s risk
Expect information requests, inspections and reviews of the business and controls. Build the calendar from the firm’s actual activities, rulebooks and licence conditions; different firms may have additional reporting or monitoring requirements.
Enforcement can affect operations
VARA can issue warnings, cease-and-desist directions, fines, scope restrictions or suspension, and measures that can lead to closure. Check the Public Register and licence conditions rather than relying on a logo or a commercial licence alone.
VARA FAQs · VARA Public Register · checked 20 October 2026
Already operating before the regime? The legacy route is separate.
The published route for eligible pre-regime operators is IDQ → Application Acknowledgement Notice → Legacy Operating Permit → full licence. The FAQ states the permit lasts 12 months, is non-renewable and requires a full-licence application 90 days before expiry. Failure to meet the requirements can require cessation and wind-down. Name, UBO, address or activity changes need the applicable VARA review. Confirm eligibility and current availability; this is not a shortcut for a new firm.
VARA licence applications · VARA FAQs · checked 20 October 2026
How the rulebooks fit together.
VA Regulations
The framework for regulated activities, licensing, supervision and fees.
Compulsory rulebooks
Company · Compliance & Risk Management · Technology & Information · Market Conduct.
Your activity rulebooks and licence conditions
Additional requirements for each approved service, applied together.
VARA licence applications · VARA rulebooks · checked 20 October 2026
Version checks and recent updates
- The rulebooks carry May 2025 revisions; use each book’s actual effective date and current download, rather than calling every book the same version.
- The Exchange Services Rulebook is effective 31 March 2026 and includes exchange-traded derivatives rules on approval, margin, leverage and insurance funds.
- VARA’s Issuance guidance is dated 9 April 2026; it supports the licensed-distributor approach for Category 2.
- The Technology and Information page currently links its May 2025 document, effective June 2025. Check the current rulebook and any licence-specific directions before finalising the operating controls.
Exchange Rulebook · effective 31 March 2026 · VA Issuance guidance · 9 April 2026 · Technology and Information Rulebook · VARA rulebooks · checked 20 October 2026
Questions people ask
Is a free-zone crypto company licence enough?
No. Commercial registration does not replace regulatory permission. Identify the actual service, the responsible regulator and the licence conditions before operating.
Can I start operating after Approval to Incorporate?
No. Approval to Incorporate permits legal incorporation and operational preparation. Client services must wait for the full VASP licence and its conditions to be met.
How much does a VARA licence cost?
There is no single all-in price. Use the application and supervision table, then calculate capital for the actual services and overheads. Budget separately for premises, people, systems, insurance, audit, other authority charges and advisers.
Do I need UAE-resident staff?
The Company Rulebook requires two full-time, VARA-approved Responsible Individuals, each a UAE resident or UAE passport holder.
Other management and compliance appointments also have their own requirements.
Can custody and exchange sit in one company?
No.
The custody provider must be a separate legal entity from group entities providing other VA services, except that custody may be combined with Transfer & Settlement.
Staking from custody needs explicit additional authorisation.
I only trade my own money. Do I need anything?
VARA’s FAQ requires a proprietary-trading NOC and registration above a volume threshold.
Published FAQ thresholds conflict; confirm the applicable test with VARA.
Trading for clients or at third-party initiation is not automatically proprietary trading.
Can I issue a token without a VARA licence?
Category 2 issuance does not need the issuer’s licence or prior approval under the current rulebook if all placement and distribution is through a Licensed Distributor. Category 1 requires a licence and prior Whitepaper approval. Qualifying Exempt VAs have no pre-issuance requirement but remain subject to general rules. Confirm the category and process with VARA.
Can a foreign firm advertise without a VARA licence?
Do not treat a permit as a general exemption.
The current marketing rules limit who can market VA activities and provide a narrow physical-event exemption with conditions, including no UAE-resident signup or onboarding.
The FAQ uses older, broader permit wording; confirm the campaign with VARA.
How long does approval take?
No fixed approval period is promised. It depends on the activity, readiness, questions raised and VARA’s assessment. Vantablack does not guarantee approval or a completion date.
Where can I check a firm’s licence?
Use VARA’s Public Register and inspect the current status, approved activities and conditions. An in-principle approval or a commercial licence is not a full operating permission.
Does VARA cover DIFC and ADGM?
No.
VARA’s Dubai remit excludes DIFC, and ADGM is a separate jurisdiction.
A business must check the regulator for its location and service, including any UAE Central Bank requirements.
VARA licence applications · VARA Regulations · Schedule 2 · Company Rulebook · Part VI · Company Rulebook · Part I · VA Issuance Rulebook · Part I · Custody Services Rulebook · Introduction · VARA FAQs · Marketing Regulations · current framework · checked 20 October 2026
Start with the business model.
Bring the services, target clients, asset flows, proposed entity structure and funding plan. We can identify the licensing questions before a scoped proposal. Do not send private keys, seed phrases or identity documents through a public enquiry.
Apply this to your business
Which virtual-asset services will the company actually perform?
Why this matters
Commercial registration, regulatory permission and permitted operations are different steps. Location and asset flows determine the regulator and activity checks.
What could change the answer?
Handling a regulated transaction cannot be treated as an automatic extension of IT or general consulting.
A staged launch must stay inside its authorised initial scope.
Check these details first
- Service and customer type
- Dubai outside DIFC, DIFC, ADGM or another location
- Who holds assets, keys and customer money
- Required activities and operating conditions