Dubai VARA Licence Guide: The VASP Licensing Regime and Application Process

VARA (Virtual Assets Regulatory Authority) is the world's first dedicated virtual asset regulator, established under Dubai Law No. 4 of 2022 with jurisdiction across the Emirate of Dubai (excluding the DIFC financial free zone, where the DFSA regime applies). Any business conducting virtual asset activities in Dubai must first obtain a VASP licence. The authority lists 8 regulated activities: advisory, broker-dealer, custody, exchange, lending and borrowing, management and investment, and transfer and settlement, among others, licensed activity by activity.

The regulatory framework consists of 4 mandatory Rulebooks (Company; Compliance and Risk Management; Technology and Information; Market Conduct) plus an activity-specific Rulebook for each licensed activity. Capital requirements sit in the Company Rulebook and the activity rules, tiered by activity type.

Stage one: submit an Initial Disclosure Questionnaire (IDQ) to the Dubai Department of Economy and Tourism (DET) or your free zone, pay roughly 50% of the application fee to start the review, and on passing receive an Approval to Incorporate (ATI), which lets you incorporate the company and prepare operations. Note that an ATI is not an operating permit: conducting business before the full licence is granted is prohibited. Stage two: complete the full document set under VARA's guidance (ownership structure, AML/CFT, technology and governance), work through meetings, interviews and follow-up requests, then pay the balance and the first year's supervision fee to receive the VASP licence (which may carry operating conditions).

Itemised fees appear in Schedule B of the 2023 Regulations, priced by activity type; the regulator has not published a decision timeline. Existing operators once had a Legacy program (a 12-month operating permit and up to a 50% licence fee discount), but new entrants all follow the standard two-stage process.