VARA Licence Guide: How to Get a Crypto Licence in Dubai

This guide is a general overview for founders and product teams, not legal advice. Regulations change, so always confirm current requirements with qualified legal advisers.

Dubai has positioned itself as a global hub for virtual assets, and the Virtual Assets Regulatory Authority (VARA) is central to that strategy. If you plan to run an exchange, broker, custodian or other virtual asset business in Dubai, you'll almost certainly need a VARA licence. Here's an overview of how it works.

What is VARA?

VARA was established in 2022 under Dubai law as the regulator for virtual assets and related activities in the Emirate of Dubai. Its jurisdiction covers Dubai's mainland and free zones, except the Dubai International Financial Centre (DIFC), which has its own regulator, the DFSA. Abu Dhabi Global Market (ADGM) has a separate framework under its FSRA.

Activities VARA licenses

• Advisory services
• Broker-dealer services
• Custody services
• Exchange services
• Lending and borrowing services
• Management and investment services
• Transfer and settlement services
• Virtual asset issuance (under the issuance rules)

Each activity has its own requirements, and many businesses need more than one. An exchange that also holds customer assets, for example, typically needs both exchange and custody permissions.

The rulebooks

VARA's framework is set out in regulations and rulebooks. Some apply to all licensed firms, covering company matters, compliance and risk management, technology and information security, and market conduct. Others apply to specific activities. Your platform, policies and team must meet all the rulebooks that apply to you.

The licensing journey (overview)

1. Prepare: define your activities, business plan, ownership structure and key people.
2. Set up the company: register a legal entity with the relevant Dubai licensing authority.
3. Apply to VARA: submit the application with policies, financials and information about owners and management.
4. Initial or provisional approval: VARA may grant approval subject to conditions.
5. Meet conditions: finalise systems, staffing, audits and capital requirements.
6. Full licence: start operating once VARA grants the licence.

Timelines vary with the complexity of your activities and the completeness of your application.

What regulators expect from your technology

• KYC and AML: customer due diligence, sanctions screening and transaction monitoring.
• Travel Rule: sharing sender and recipient information for transfers.
• Custody controls: segregation of client assets, cold storage and key management.
• Information security: access controls, penetration testing, incident response and backups.
• Market conduct: fair treatment, clear disclosures and controls against market abuse.
• Record-keeping and reporting: complete audit trails and regulatory reports.

Marketing rules

VARA has specific rules on marketing virtual assets, including requirements for clear risk disclosures and restrictions on misleading promotions. Make sure your website, app and campaigns follow them, including content created by influencers or partners.

Common mistakes

• Underestimating the time and documentation required
• Building the platform before mapping it to the rulebooks
• Not hiring key compliance roles early
• Choosing the wrong jurisdiction (Dubai mainland vs DIFC vs ADGM) for the business model

People and governance

Regulators look closely at who runs a licensed firm. Expect requirements around qualified senior management, a compliance officer, a money laundering reporting officer and other key roles, with appropriate experience and presence. Governance arrangements, such as a board, risk committee and clear reporting lines, must be documented and working in practice, not just on paper. Hiring these people early also helps you design compliant processes from the start.

Policies you'll need

• AML and counter-terrorist financing policy
• Customer due diligence and onboarding procedures
• Information security and data protection policies
• Custody and safeguarding procedures
• Conflicts of interest and market conduct policies
• Business continuity and incident response plans
• Complaints handling procedures

Mapping your platform to the rules

A practical approach is to build a compliance matrix: list each relevant rule, then record which product feature, process or policy meets it and where the evidence lives. This makes applications faster, helps during regulatory reviews and shows gaps early. Development teams can use the same matrix to prioritise features.

Ongoing obligations

A licence isn't the finish line. Licensed firms have ongoing reporting, audits, fee payments and supervisory engagement, and must notify the regulator of significant changes. Budget for compliance operations after launch, and keep your platform's reporting tools up to date as rules evolve.

Technology checklist for a VARA-regulated platform

• KYC, AML screening and transaction monitoring integrations
• Travel Rule messaging with other providers
• Segregated client asset records and reconciliation
• Cold storage and key management procedures
• Access controls, logging and security monitoring
• Regulatory reporting and audit trails
• Arabic and English customer communications

Choosing between Dubai mainland, DIFC and ADGM

VARA covers mainland Dubai and most free zones, the DFSA covers the DIFC, and the FSRA covers ADGM in Abu Dhabi. Each has different processes, costs and expectations. Your business model, target clients and investors influence the best choice, so compare options with local legal advisers before setting up.

Working with service providers

Licensed firms usually rely on several external providers: KYC and screening tools, blockchain analytics, custody technology, cloud hosting, auditors and legal advisers. Regulators expect firms to choose providers carefully, document due diligence and keep oversight of outsourced functions. Choose technology partners who understand VARA's expectations and can supply evidence of their own security and compliance controls.

Your development partner should also be able to support you during regulatory reviews, explaining how the platform implements controls and providing technical documentation when needed. This collaboration can save significant time during the licensing process.

Frequently asked questions

Do I need a VARA licence to serve UAE customers?

If you carry out virtual asset activities in or from Dubai, generally yes. Serving customers across the UAE may involve other regulators too, so take local legal advice.

Can a foreign company get a VARA licence?

Foreign groups typically set up a Dubai entity with local presence and management to apply.

How long does it take?

It varies, but plan for several months, and longer for complex or multiple activities.

Key takeaways

• VARA licenses specific virtual asset activities in Dubai.
• Rulebooks shape both policies and technology.
• Key people and governance matter as much as documents.
• Plan for ongoing compliance after licensing.

Build a VARA-ready platform

AnAInfo builds exchanges, wallets and tokenisation platforms designed around VARA's requirements, working alongside your legal advisers. See our UAE page, or contact us.