Dubai VARA Crypto License Advisory
Any virtual asset business in Dubai outside DIFC needs a licence from the Virtual Assets Regulatory Authority (VARA). We help you plan the structure and set up the company side, and work alongside the specialist legal and compliance advisers who prepare the VARA application.
Description
The Virtual Assets Regulatory Authority (VARA) was set up under Dubai Law No. 4 of 2022 to regulate virtual assets across Dubai, on the mainland and in every free zone except the Dubai International Financial Centre (DIFC), which has its own regulator, the DFSA. If you plan to offer crypto or other virtual asset services in or from Dubai, you need a VARA licence before you start.
VARA licenses eight activities: advisory services, broker-dealer services, custody services, exchange services, lending and borrowing services, management and investment services, transfer and settlement services, and virtual asset issuance. Each activity is licensed separately, so you apply for each one you will carry out. Every licensed firm must follow VARA's four compulsory rulebooks (Company, Compliance and Risk Management, Technology and Information, and Market Conduct) plus the rulebook for each of its activities. These are published on VARA's rulebook site.
The licence is granted in two stages. In stage one you file an Initial Disclosure Questionnaire with DET if you are on the mainland, or with your free zone, together with a business plan and details of your beneficial owners and senior management. If VARA is satisfied, it issues an Approval to Incorporate. That lets you form the company, take an office and hire, but not carry out any virtual asset activity. In stage two you submit the full application VARA asks for, including governance, compliance, risk and technology documents, financial projections and proof of capital. VARA may hold meetings and interviews and ask for more. If approved, you receive the VASP licence, which can carry conditions.
Capital is a regulatory requirement, not a fee. VARA's Company Rulebook sets minimum paid-up capital per activity, usually as the higher of a fixed amount or a share of fixed annual overheads. For example, advisory services need AED 100,000; custody services the higher of AED 600,000 or 25% of fixed annual overheads; exchange services the higher of AED 1,500,000 or 25%, reduced to the higher of AED 800,000 or 15% if client assets are held by a VARA-licensed custodian. Firms with several activities hold the capital for each one. VARA also sets net liquid asset and insurance requirements. Check the current rulebook before you plan your funding, as VARA updates it.
Our role is the company and coordination side. We help you choose between the mainland and a free zone such as DMCC for VARA-regulated activities, or DIFC if the DFSA framework suits you better. We prepare the corporate documents, handle incorporation once you hold the Approval to Incorporate, arrange office and visas including the Dubai investor visa, and support the corporate bank account application. The VARA application itself, including the compliance and risk frameworks, is prepared by specialist legal and compliance advisers; we work with them and keep the timeline joined up. We do not give legal opinions or promise approval, which is VARA's decision.
Timelines depend on VARA's review, the quality of your application and how quickly you answer questions. Cost depends on the activities you apply for, the jurisdiction, office, visas and the specialist advisers involved. Message us on WhatsApp or live chat to discuss your plan and get a written quote for our part.
What's Included
- Initial consultation on which VARA activities your business model needs
- Jurisdiction comparison: Dubai mainland, a Dubai free zone, or DIFC (DFSA)
- Introduction to specialist legal and compliance advisers for the VARA application
- Support with the Initial Disclosure Questionnaire through DET or the free zone
- Company incorporation after Approval to Incorporate
- Memorandum of Association and corporate documents
- Office or Ejari arrangements
- Establishment card, investor visa and staff visas
- Support with the corporate bank account application
- Project coordination between you, your advisers and the authorities
Requirements / Prerequisites
- A defined business model and the VARA activities it requires
- Funds to meet VARA's paid-up capital, net liquid asset and insurance requirements for those activities
- Beneficial owners and senior management who can pass VARA's fit and proper assessment
- Clear source of funds and source of wealth evidence
- Willingness to appoint specialist legal and compliance advisers for the application
- A plan to operate without virtual asset activity until the VASP licence is issued
Required Documents
- Passport copies and CVs of beneficial owners and senior management
- Source of funds and source of wealth evidence
- Regulatory business plan and financial projections
- Organisational structure and governance framework
- Group and entity financial statements (for corporate shareholders)
- Proof of paid-up capital and locked-up capital
- Compliance, risk and technology policies aligned with VARA's rulebooks
- Succession and wind-down plans
- Insurance certificates
Our Process
- Consultation on business model, activities and jurisdiction
- Appointment of specialist legal and compliance advisers
- Initial Disclosure Questionnaire filed with DET or the free zone
- VARA review and Approval to Incorporate
- Company incorporation, office and visas
- Full VARA application and capital evidence
- VARA questions, meetings and interviews
- VASP licence issued, possibly with conditions
- Bank account and start of licensed operations
Pricing
Contact us on WhatsApp for a tailored quote for this service.
Frequently Asked Questions
Who needs a VARA licence?
Any business carrying out a virtual asset activity in or from Dubai, on the mainland or in a free zone, except DIFC. DIFC firms are regulated by the DFSA instead.
What are the stages of a VARA licence?
Stage one is the Initial Disclosure Questionnaire, filed with DET or your free zone, which leads to an Approval to Incorporate. Stage two is the full application to VARA, which leads to the VASP licence. You cannot carry out virtual asset activity until the licence is issued.
What is the minimum capital for a VARA licence?
It depends on the activity. VARA's Company Rulebook sets, for example, AED 100,000 for advisory services and the higher of AED 600,000 or 25% of fixed annual overheads for custody. Exchange services range from the higher of AED 800,000 or 15% (with a VARA-licensed custodian) to the higher of AED 1,500,000 or 25%. Each licensed activity carries its own requirement.
How long does a VARA licence take?
VARA does not publish a fixed timeline. It depends on how complete your application is, how many activities you apply for and how quickly you answer VARA's questions. Your company, office and team need to be ready during this period, even though you cannot trade yet, so plan your funding for that.
How much does a VARA licence cost?
The total is made up of VARA's application and supervision fees for each activity, your company licence, office and visas, the specialist advisers who prepare the application, and our fee. It varies a lot by activity. Message us for a written quote for our part and an overview of what else to budget for.
Does Octavon apply for the VARA licence?
We handle the company setup and coordination and work alongside specialist legal and compliance advisers who prepare the VARA application. We do not give legal opinions or guarantee approval.
Should I set up in DMCC, on the mainland or in DIFC?
Mainland and free zone companies such as DMCC are both licensed by VARA for virtual asset activities, and the application is filed through DET or the free zone. DIFC uses the DFSA framework instead. The right choice depends on your activities, clients and office needs.
Can a crypto business open a bank account in Dubai?
It is possible, but banks assess virtual asset businesses carefully and appetite varies. Having your VARA licence, clear source of funds and strong compliance documents makes the application stronger.