Dubai VARA Crypto Licensing Guide 2025: Fees, Rules & Restrictions

Posted By Tristan Valehart    On 19 Oct 2025    Comments (30)

Dubai VARA Crypto Licensing Guide 2025: Fees, Rules & Restrictions

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Looking to set up a crypto business in Dubai? You’ll need to navigate the VARA crypto licensing process, understand the fee structure, and comply with the latest restrictions. This guide walks you through everything a Virtual Asset Service Provider (VASP) must know to get licensed under the Dubai Virtual Assets Regulatory Authority (VARA) in 2025.

Dubai Virtual Assets Regulatory Authority (VARA) is the government body that oversees all virtual‑asset activities outside the Dubai International Financial Centre (DIFC). It issues licences to exchanges, custodians, wallet providers, brokers, and token‑issuers, and enforces AML/CFT standards aligned with the FATF.

Why VARA Matters for Crypto Businesses

Since its launch in 2022, VARA has become the most comprehensive regulator for digital assets in the Middle East. It offers a clear, digital‑first application portal, which speeds up approval compared with traditional financial licences. The authority also provides a stable tax environment and strong investor protection, making Dubai an attractive hub for firms targeting Europe, Asia and Africa.

Key Licensing Categories

VARA’s 2025 framework groups services into six main licence types. Each type carries distinct capital and compliance requirements.

  • Exchange Licence - Allows the operation of a crypto exchange that matches buyers and sellers.
  • Broker‑Dealer Licence - Covers fiat‑to‑virtual‑asset and virtual‑asset‑to‑virtual‑asset brokerage services.
  • Custody Licence - Permits secure storage of client crypto assets.
  • Wallet Provider Licence - Enables the issuance of non‑custodial or custodial wallets.
  • Token Issuance Licence - Required for launching asset‑backed, stablecoin, or utility tokens.
  • Transfer Service Licence - Allows the movement of virtual assets between wallets or platforms.

Capital Requirements & Fees

Capital thresholds vary by licence. Below is a quick snapshot:

Capital & Fee Overview (2025)
Licence TypePaid‑up Capital (AED)Application Fee (AED)Annual Supervision Fee (AED)
Exchange5,000,000100,000200,000
Broker‑Dealer1,000,00080,000150,000
Custody4,000,00090,000180,000
Wallet Provider100,00040,00080,000
Token Issuance500,00060,000120,000
Transfer Service250,00050,000100,000

For firms seeking multiple licences, the total capital commitment can exceed AED 10 million. Smaller startups often start with a wallet‑provider licence and scale up as they raise funding.

Cartoon office with six characters representing VARA license types around a table of floating coins.

Step‑by‑Step Licensing Process

  1. Incorporate a legal entity in Dubai mainland or an approved free zone (100 % foreign ownership is allowed in free zones).
  2. Prepare a comprehensive business plan covering market analysis, technology stack, security architecture, and financial projections.
  3. Develop AML/CFT policies that meet FATF recommendations - include KYC procedures, transaction monitoring, and record‑keeping.
  4. Complete the online VARA application portal, upload all documents, and pay the applicable fees.
  5. Undergo a fit‑and‑proper check on directors and senior managers.
  6. Respond to any regulator queries within the stipulated 10‑day window.
  7. Once approved, obtain the licence certificate and commence operations under VARA supervision.

Typical processing time ranges from 4 to 8 weeks for a single licence, assuming all documentation is complete.

Key Restrictions and Recent Updates (2025)

VARARules have tightened on several fronts:

  • Privacy‑focused tokens such as Monero and Zcash are banned outright under Administrative Order 2023/2024.
  • All marketing material must receive prior VARA approval; non‑compliant adverts can lead to fines of up to AED 500,000.
  • Token issuers must publish a detailed whitepaper and risk‑disclosure, vetted by VARA, before any sale.
  • DeFi protocols are now subject to a separate licensing track that requires a minimum capital of AED 3 million and a live audit of smart‑contract code.
  • DAOs (Decentralized Autonomous Organizations) are slated for a dedicated licence in Q4 2025, with initial capital set at AED 2 million.
Camel handing a golden VARA licence to a diverse team, with a compliance checklist in the background.

Comparing VARA with Other UAE Regulators

VARA vs DFSA vs FSRA (2025)
AspectVARADFSA (DIFC)FSRA (ADGM)
JurisdictionDubai mainland & free zonesDIFC onlyAbu Dhabi Global Market
Primary FocusAll VASPs, DeFi, NFTs, token issuanceInvestment dealing, custody, trading facilitiesBrokerage, fund management, advisory services
Capital MinimumAED 100k - 5 million (category‑specific)AED 1 million (standard)AED 2 million (standard)
Application ProcessFully digital, 4‑8 weeksHybrid, 8‑12 weeksHybrid, 6‑10 weeks
Key RestrictionsPrivacy‑token ban, mandatory marketing approvalStricter fit‑and‑proper, limited to securities‑related assetsFocus on AML/CFT, no explicit token ban

For most international crypto exchanges, VARA offers the widest market reach and the most crypto‑specific rules, while DFSA and FSRA are better suited for traditional fintech or securities‑focused firms.

Practical Tips for a Smooth VARA Application

  • Invest in compliance early. Build an AML/CFT system that can generate real‑time transaction reports. Regulators flag incomplete systems faster than missing paperwork.
  • Hire a local legal counsel familiar with VARA’s fit‑and‑proper criteria. Their network can accelerate background checks.
  • Prepare a modular technology architecture. If you plan to add a DeFi module later, design the API layer now to avoid re‑certification costs.
  • Document every policy decision. VARA auditors request evidence of board approvals for risk frameworks.
  • Consider starting with a wallet‑provider licence if capital is limited. It provides a legal foothold and can be upgraded later.

Next Steps After Licence Grant

Once you have the VARA licence, you’ll need to maintain ongoing compliance:

  1. Submit quarterly AML/CFT reports via the VARA portal.
  2. Renew the annual supervision fee before the licence anniversary.
  3. Undergo a full external audit at least once a year, covering technology, security, and financials.
  4. Update the regulator on any material change - new product launch, major acquisition, or shift in ownership.

Failure to meet these obligations can result in fines, licence suspension, or revocation.

What is the minimum capital required for a VARA exchange licence?

The exchange licence needs a paid‑up capital of AED 5 million, plus an AED 100,000 application fee and AED 200,000 annual supervision fee.

Can a foreign company own 100% of a VARA‑licensed crypto firm?

Yes, if the company is incorporated in a Dubai free zone that permits 100 % foreign ownership. The entity then applies for VARA licensing.

Are privacy coins like Monero allowed under VARA?

No. Administrative Order 2023/2024 bans privacy‑focused tokens, including Monero and Zcash, due to money‑laundering concerns.

How long does the VARA licensing process usually take?

For a complete, well‑prepared application, expect 4-8 weeks from submission to approval. Delays happen if additional information is requested.

What are the marketing restrictions for VARA‑licensed tokens?

All promotional material must be cleared by VARA before public release. Advertisements without approval can attract fines up to AED 500,000.