GCG Structuring

Corporate services / digital assets

VARA licence in Dubai

01_introduction

VARA is Dubai’s virtual asset regulator. It covers the whole Emirate, mainland and free zones, except the DIFC. A trade licence does not authorise virtual asset activity. Holding client assets, executing client orders or advising on virtual assets needs VARA authorisation. See Crypto license UAE for the comparison across jurisdictions.

02

What needs a VARA licence rather than a trade licence?

Three tiers, decided by who the company acts for.

Fully licensed, client-facing

Lighter licensed tier

No VARA licence needed

One licence per activity. Who the company acts for decides the tier.

Advisory and 
back office.

Own funds,
or no client assets.

Exchange, custody, broker-dealer, lending and borrowing, management and investment, Category 1 issuance

Advisory Services, 
VA Transfer and 
Settlement Services

Proprietary trading of the company's own funds: VARA No-Objection Certificate

One licence is required for each activity

Lower application, supervision 
and capital requirements 
than the client-facing tier

Software and infrastructure that never touches client assets: ordinary trade licence, see DMCC company formation

Both a capital requirement and an annual supervision fee apply per activity

Additional activities are added 
at a reduced fee

The test is simple: acting for third parties means VARA. Where the entity sits inside Dubai is a commercial choice, made on cost, visas and banking. The VARA track runs on top.

03

01
How long does VARA licensing take?

Scoping first, entity setup second, then the application pack: Initial Disclosure Questionnaire, business plan, AML/CFT framework, technology and information security documentation. The pack runs parallel to incorporation.

Market figures put a No-Objection Certificate at four to eight weeks and a full licence at four to seven months from complete submission. VARA assesses every application on its own merits.

The licence is continuing. What recurs is the annual supervision fee, charged per activity and paid in advance, alongside the minimum capital the activity requires.

That recurring cost, not the application fee, is what a founder should budget against.

04

How we approach this

GCG maps the business model onto VARA’s categories before anything is filed.

Proprietary trading and broker-dealer are two different licences, and the line between them decides months of work and the size of the budget. The zone is chosen on commercial grounds. The VARA track runs on top. We prepare the IDQ and the application pack and manage the process through review to issuance. VARA decides. The file goes in complete and correctly scoped, or not at all.

HIDE

Scope the activity before you file

Confirm the activity scope before any VARA fee is committed.

book a consultation

05_faq

The cost depends on the activity. Application and annual supervision fees are charged per activity, with client-facing activities carrying higher fees and capital requirements than advisory and back-office ones. Each additional activity is added at a reduced fee. Entity setup, capital and compliance come on top. GCG sets out the full cost picture for your specific activities in the consultation.

No. VARA covers the Emirate of Dubai; the DIFC is DFSA territory and ADGM is regulated by the FSRA. There is no passporting between them. A business serving several emirates structures entity by entity.

Yes, and for regulated activity it must. DMCC issues the trade licence; VARA authorises the virtual asset activity. Proprietary trading needs the No-Objection Certificate, client-facing services need the full licence.

Annual supervision fees in advance, AML and CFT obligations, technology and information security standards, market conduct rules, and regulated marketing. Most licensed firms carry a compliance officer or an outsourced function from day one.

06_related pages

  • Da
Digital Assets
  • CL
Crypto license UAE
  • adgm
ADGM company formation
  • difc
DIFC company formation.

07_SOURCES

VARA Virtual Assets and Related Activities Regulations 2023, Schedule 2 (rulebooks.vara.ae);

DMCC guidance on regulated VA activity; timelines are market figures.