VARA Licensing Explained: What It Means for Web3 Businesses in Dubai

Frequently Asked Questions

01.What does a VARA licence cost?

Two numbers sit in VARA's published Schedule 2. The application fee is AED 40,000 for Advisory Services and for Transfer and Settlement Services, and AED 100,000 for Broker-Dealer, Custody, Exchange, Lending and Borrowing, Management and Investment, and Category 1 VA Issuance. The annual supervision fee is AED 80,000 or AED 200,000 against the same split, and extension fees apply for each additional activity. Separately, paid-up capital under Rule VI.B.1 of the Company Rulebook runs from AED 100,000 for Advisory to AED 1,500,000 for an Exchange that does not use a VARA-licensed custodian, with no overheads test on Advisory; the other activities take the higher of the fixed amount or fifteen percent of fixed annual overheads where a VARA-licensed custodian is used, twenty-five percent where one is not. Legal, audit, hiring and technology build costs sit outside all of these figures.

02.Can I start with an MVP before applying for a VARA licence?

You can build and test the product, but you cannot serve clients in or from Dubai until VARA grants the full licence. An Approval to Incorporate (ATI) is conditional and confers no permission to operate or onboard users. The sensible sequence is to build the system that the Technology and Information Rulebook and the Compliance and Risk Management Rulebook will be assessed against, run it against synthetic or internal flows, and treat the period after the ATI as the window to complete the full VASP Licence application with a working system rather than a slide deck.

03.Does VARA regulate marketing by companies that are not licensed in Dubai?

Yes. The marketing rules are extra-territorial and apply to any entity promoting virtual assets in Dubai, domestic or foreign, licensed or not. Material must be fair, clear and not misleading, must be identifiable as promotional, must carry a prominent disclaimer addressing the unpredictable and volatile nature of virtual asset values, and must not imply safety, guaranteed returns or urgency. In October 2025 VARA penalised nineteen unlicensed firms with fines from AED 100,000 to AED 600,000, with marketing breaches among the cited violations.

04.How long does the VARA licensing process take?

The process runs in two stages. Stage one is the Initial Disclosure Questionnaire and the assessment that leads to an Approval to Incorporate (ATI). Stage two is the full VASP Licence application, which VARA does not cap with a published deadline. The elapsed time depends far more on the applicant's readiness than on the regulator, because the second stage requires named fit and proper individuals, audited capital, documented controls and a technology stack that can be inspected rather than described.