VARA Crypto License Capital Calculator
Select License Types
Choose one or more VARA license categories to calculate total capital requirements.
Capital Requirement Summary
Selected services and their combined capital requirements:
Total Minimum Paid-Up Capital Required: AED 0
Application Fee Range: AED 40,000 - AED 100,000
Annual Supervision Fee Range: AED 80,000 - AED 200,000
Important Notes
- Capital is cumulative across all selected services.
- Each license requires a separate application and fee payment.
- Multi-service firms must meet the highest capital requirement for any individual service.
- Application fees vary based on the number and type of services requested.
- Annual supervision fees are determined by the scope of operations and risk profile.
Dubai is fast becoming the world’s crypto hub, and the Virtual Assets Regulatory Authority (VARA) is the engine driving that change. If you’re planning to launch a crypto exchange, custody platform, or any virtual‑asset service in the emirate, you need to know exactly what VARA expects.
Quick Takeaways
- Six license categories cover everything from exchanges to token issuance.
- Paid‑up capital ranges from AED100,000 to AED5million per service, with cumulative totals for multi‑service firms.
- Application fees start at AED40,000; annual supervision fees can top AED200,000.
- Strict AML/CFT requirements align with FATF standards.
- Privacy‑focused tokens like Monero and Zcash are prohibited.
What Is VARA and Why Does It Matter?
Established in 2022, VARA is Dubai’s dedicated regulator for virtual assets. Unlike the Dubai International Financial Centre (DIFC), which falls under the Dubai Financial Services Authority (DFSA), VARA has exclusive jurisdiction over all Virtual Asset Service Providers (VASPs) operating in the emirate. Its mandate is simple: give crypto firms a clear, modern legal framework that meets international best practices while keeping Dubai attractive for global investors.
License Categories - Which One Do You Need?
VARA recognizes six core service types. You can apply for a single license or combine several, but each service adds its own capital and compliance load.
| Service Category | License Code | Minimum Paid‑up Capital (AED) |
|---|---|---|
| Exchange Services | EX | 5,000,000 |
| Broker‑Dealer (Fiat‑to‑VA) | BD‑F | 1,000,000 |
| Broker‑Dealer (VA‑to‑VA) | BD‑V | 2,000,000 |
| Custody Services | CU | 4,000,000 |
| Wallet Provision | WA | 100,000 |
| Token Issuance - Category1 | TI‑1 | 1,500,000 |
| Token Issuance - Category2 | TI‑2 | 500,000 |
For example, a firm that wants to run an exchange (AED5M), offer custody (AED4M), and act as a broker‑dealer (AED1M) must hold at least AED10million in paid‑up capital.
Step‑by‑Step Application Process
- Incorporate in Dubai. Your company must be a locally registered legal entity (LLC, Free Zone Company, etc.).
- Prepare fit‑and‑proper documentation for directors, senior managers, and the designated compliance officer. VARA checks personal integrity, financial standing, and relevant experience.
- Draft a detailed business plan covering target markets, risk‑management framework, technology stack, and projected financials.
- Implement AML/CFT systems that can automate KYC, source‑of‑funds verification, and real‑time transaction monitoring.
- Submit the digital application via VARA’s online portal. Upload the business plan, corporate documents, AML policies, and a proof of paid‑up capital.
- Pay the applicable fees:
- Application fee: AED40,000-AED100,000 (depends on service mix).
- Annual supervision fee: AED80,000-AED200,000.
- Undergo VARA’s technical and legal review. Expect follow‑up requests for clarifications, especially around cybersecurity and insurance coverage.
- Once approved, receive the VARA license and begin operations under continuous supervisory oversight.
Although the portal is digital‑first, the review can take 4-8weeks for straightforward cases and up to 12weeks for multi‑service applications.
Operational & Compliance Must‑Haves
Getting the license is only half the battle. VARA imposes a robust set of ongoing obligations:
- Cybersecurity: Deploy encryption, multi‑factor authentication, and regular penetration testing. External audits must meet ISO27001 or equivalent.
- Insurance: Secure coverage for cyber‑risk, professional liability, and client‑asset protection (minimum AED5million for custodians).
- Record‑keeping: Maintain transaction logs, client communications, and AML reports for at least five years. Data must be stored on servers located in the UAE or approved jurisdictions.
- AML/CFT: Follow FATF recommendations-automated sanction screening, ongoing transaction monitoring, and a dedicated reporting channel for suspicious activity.
- Corporate Governance: Quarterly board meetings, annual compliance reviews, and a documented escalation process for regulatory breaches.
Failure to meet any of these can trigger fines, suspension, or outright revocation of the license.
Key Restrictions You Can’t Ignore
VARA’s Administrative Order 2023/2024 introduced hard rules that catch many newcomers off guard:
- Privacy‑focused tokens (e.g., Monero, Zcash) are outright prohibited.
- All marketing material must be pre‑approved by VARA. No “guaranteed returns” language is allowed.
- DeFi protocols that enable anonymous borrowing or lending without a registered VASP are not permitted.
- Closed‑loop utility tokens can operate without a full license only if they stay within a single ecosystem and are monitored by VARA.
These restrictions aim to protect investors and keep Dubai’s reputation as a transparent financial center.
How VARA Stacks Up Against Other UAE Regulators
Choosing between VARA, DFSA (DIFC), and the Financial Services Regulatory Authority (FSRA) in ADGM depends on your business model.
- VARA: Covers the widest range of crypto activities, offers a single‑window licensing process, and benefits from Dubai’s tax‑efficient environment.
- DFSA: Ideal for firms that need the global credibility of the DIFC free zone, especially those offering mixed financial services (e.g., crypto‑funds with traditional assets).
- FSRA (ADGM): Provides a more conservative approach with strong emphasis on custodial services and institutional clients.
Most crypto‑first startups pick VARA because it’s the most purpose‑built regulator for digital assets, while larger, diversified financial groups may gravitate toward DFSA for its broader financial‑services umbrella.
Next Steps & Common Pitfalls
Ready to apply? Here’s a cheat‑sheet to keep you on track:
- Hire a local legal counsel who knows VARA’s nuances-early engagement saves weeks of back‑and‑forth.
- Invest in a compliant AML platform before you file; retro‑fitting later is costly.
- Run a cyber‑risk assessment and obtain the required insurance coverage early.
- Prepare a sandbox demo of your technology for VARA reviewers. A working prototype beats a long PDF.
- Keep a “regulatory calendar” - annual supervision fees, audit deadlines, and marketing‑approval timelines are strict.
Typical mistakes include under‑estimating capital requirements, overlooking the need for local incorporation, and launching marketing campaigns before obtaining VARA’s sign‑off.
Frequently Asked Questions
Do I need a VARA license if I only hold NFTs for personal use?
Personal, non‑commercial ownership of NFTs does not require a VARA license. However, any platform that facilitates buying, selling, or minting NFTs for third parties must be licensed.
Can a company hold both a VARA license and a DFSA license?
Yes, but the entity must be separate in each jurisdiction, with distinct legal structures and compliance programs. Dual licensing is common for firms that want to serve both Dubai‑wide and DIFC clients.
What is the timeline for getting a VARA license?
Simple applications (single service) usually take 4-6weeks. Multi‑service or DeFi‑related requests can stretch to 10-12weeks, depending on how quickly you respond to VARA’s queries.
Are there any tax advantages for VARA‑licensed firms?
Dubai imposes zero corporate tax on most virtual‑asset activities, and there is no VAT on the sale of crypto tokens. However, foreign‑source income may be subject to tax in the home jurisdiction, so consult a tax advisor.
What happens if I violate VARA’s advertising restrictions?
VARA can issue a cease‑and‑desist, impose fines up to AED500,000, or suspend the license pending remediation. Early correction and a formal apology usually mitigate the penalty.
Fionnbharr Davies
If you're eyeing a VARA license, start by mapping your service suite to the capital matrix-exchange, custody, broker‑dealer, wallet, or token issuance. The capital thresholds are cumulative, so a multi‑service firm must meet the highest individual requirement. Align your business plan with the AML/CFT framework early; VARA checks fit‑and‑proper criteria for directors and compliance officers. Remember to factor in the application and annual supervision fees, which can add up quickly. A solid governance structure will smooth the review process, and keeping records for five years is mandatory.