VARA Licence UAE: Requirements, Process and Costs in 2025

The Dubai Virtual Assets Regulatory Authority (VARA) is the mandatory regulator for any business conducting virtual asset activities in Dubai. Established under Dubai Law No. 4 of 2022, VARA operates across all of Dubai including free zones, except the DIFC which is covered by the DFSA. VARA Rulebook Version 2.0 came into effect on 19 June 2025 and applies to all new applicants and existing licensees.

The 7 Licensed Activity Categories

• Advisory Services — investment advice on virtual assets
• Broker-Dealer Services — executing trades on behalf of clients
• Custody Services — holding and safeguarding virtual assets
• Exchange Services — operating a VA trading platform
• Lending Services — VA-backed credit or direct VA lending
• Transfer and Settlement Services — moving VA between parties
• VA Issuance — creating and distributing new tokens

Capital Requirements

• Advisory: AED 150,000 minimum
• Broker-Dealer: AED 2,000,000
• Custody: AED 4,000,000
• Exchange: AED 4,000,000 plus surety bond
• Lending: AED 4,000,000
• Transfer: AED 2,000,000
• ARVA Issuance: AED 1,500,000 or 2% of reserves — whichever is higher

Application Process

• Pre-application readiness self-assessment against applicable rulebooks
• Submission via VARA portal: corporate docs, business plan, governance framework, technology architecture, AML/CFT programme
• VARA initial review: 4 to 8 weeks
• Detailed assessment including management interviews: 3 to 6 months
• Operational readiness verification before final licence: 1 to 3 months

Key Rulebook 2.0 Changes You Must Know

• New token categories: FRVA, ARVA, Category 2, Exempt — each with different obligations
• Near real-time STR submission via goAML mandatory
• 48-hour response window to VARA compliance queries
• Technology Governance and Risk Assessment Framework required for all licensees
• Stricter custody standards: full asset segregation and formal insurance
• Sponsored VASP framework allows licensed entities to sponsor unlicensed affiliates

What Takes the Longest

Most VARA applications stall on documentation, not on the business model. Incomplete technology architecture blueprints, AML/CFT programmes that do not map to VARA's specific requirements, and governance structures missing key roles are the three most common causes of delay. A complete, well-prepared application moves through assessment in 6 to 9 months. Incomplete applications take 12 to 18 months or more.