Dubai Law No. 4 of 2022 · Dubai
Establishes the Dubai Virtual Assets Regulatory Authority (VARA) as a public corporation affiliated with the Dubai World Trade Centre Authority and empowers it to license, regulate and supervise virtual asset activities and service providers across all zones of the Emirate, including special development zones and free zones, but excluding the DIFC. Effective on publication in the Official Gazette.
Law No. 4 of 2022 is the instrument that created the Dubai Virtual Assets Regulatory Authority (VARA) and made a VARA permit a condition of carrying on any virtual asset activity in the Emirate. It was issued by the Ruler of Dubai on 28 February 2022 and, under Article 28, came into force on the day of its publication in the Official Gazette. It remains in force.
Article 3 applies the law to virtual asset services provided in all zones across the Emirate, including special development zones and free zones such as DMCC and Meydan, but excludes the Dubai International Financial Centre, which keeps its own DFSA regime. Article 2 defines a virtual asset as a digital representation of value that can be traded, transferred or used for payment or investment, and defines virtual tokens, virtual asset platforms, wallets and distributed ledger technology.
Articles 4 to 14 establish VARA as a public corporation with legal personality and financial and administrative autonomy, affiliated with the Dubai World Trade Centre Authority. Article 6 makes it the Emirate's competent regulator: it sets policy, licenses and supervises service providers, classifies virtual assets, regulates platforms and wallets, and under Article 6(13) coordinates with the Central Bank of the UAE on matters of protection and financial stability. Article 13 bars VARA itself from owning or issuing virtual assets.
The operative rule for business is Article 15: no person may conduct a regulated activity in the Emirate without first obtaining a permit from VARA, and an applicant must establish a business with a recognised legal form and obtain VARA approval before the commercial licence issues. Article 16(a) lists the seven permit activities: operating and managing platforms, exchange between virtual assets and fiat currency, exchange between virtual assets, transfer services, safekeeping, management or control of virtual assets, wallet services, and offering and trading virtual tokens. Article 17 voids any transfer of a permit made without VARA approval. Article 18 lets VARA suspend permit issuance, suspend a provider's activity in exceptional cases or halt dealings in a particular asset in the public interest.
Article 19 lets the Board set fees and Article 20 lets it set violations and fines by resolution; in addition to a fine VARA may suspend a permit for up to six months or revoke it and coordinate with the commercial licensing authority to cancel the provider's commercial licence. Article 21 gives designated staff inspection powers and Article 22 provides a written grievance to the Director General within 30 days, decided within 15 days by a committee whose decision is final. Article 27 repeals conflicting provisions of other legislation to the extent of the conflict. Federal virtual asset regulation under Cabinet Resolution No. 111 of 2022 and the AML law apply alongside this law.
Any person conducting a virtual asset activity in the Emirate of Dubai, whether from the mainland, a special development zone or a free zone such as DMCC, Meydan or Dubai South; virtual asset platforms, exchanges, custodians, wallet providers and token issuers. Businesses inside the DIFC are excluded and fall under the DFSA instead.
English official text in 28 articles. Open the full text or jump to a provision:
| Article 2 | Defines a virtual asset as a digital representation of value that can be traded, transferred or used for payment or investment, and defines virtual tokens, platforms, wallets, beneficiaries and distributed ledger technology. |
| Article 3 | Applies the law to virtual asset services in all zones across the Emirate, including special development zones and free zones, but excludes the Dubai International Financial Centre. |
| Article 4 | Establishes VARA as a public corporation with legal personality and financial and administrative autonomy, affiliated with the Dubai World Trade Centre Authority. |
| Article 6 | Makes VARA the Emirate's competent regulator: policy, licensing and supervision of providers, classification of virtual assets, rules for platforms and wallets, public awareness, fee collection and coordination with the Central Bank of the UAE on protection and stability. |
| Article 15 | No person may conduct a regulated activity in the Emirate without a VARA permit; the applicant must set up a business with a recognised legal form and obtain VARA approval before the commercial licence is issued. |
| Article 16 | Lists the seven permit activities: platform operation, exchange between virtual assets and fiat currency, exchange between virtual assets, transfers, safekeeping and control, wallet services, and offering and trading virtual tokens; VARA may add activities and publish a prohibited list. |
| Article 17 | A permit may not be assigned or transferred without VARA's approval; a transfer made without approval is void. |
| Article 18 | VARA may suspend the issue of permits, suspend a provider's activities in exceptional cases, or halt dealings in a particular virtual asset where the public interest requires. |
| Article 20 | The Board sets violations and fines by resolution; in addition to a fine VARA may suspend a permit for up to six months or revoke it and coordinate with the commercial licensing authority to cancel the commercial licence. |
| Article 22 | A person affected by a VARA decision may file a written grievance with the Director General within 30 days; a committee decides within 15 days and its decision is final. |
| Article 28 | The law came into force on the day of its publication in the Official Gazette, having been issued on 28 February 2022. |
Article 20 leaves the schedule of violations and fines to Board resolutions. In addition to a fine, VARA may suspend a permit for a period not exceeding six months, or revoke it and coordinate with the competent commercial licensing authority to cancel the provider's commercial licence. Amounts owed to VARA are collected as government debts (Article 14).
When a client wants to run an exchange, custody, brokerage or token business from DMCC, Meydan, Dubai South or the Dubai mainland, we plan the incorporation around Article 15: the company is formed first, VARA's approval is obtained, and only then does the trade licence for the regulated activity issue. We check the proposed activity against the Article 16 list, because a business that only builds software or advises without touching client assets may fall outside it, while anything involving exchange, transfer, custody or wallets does not. We also keep DIFC-based proposals separate, since Article 3 carves the DIFC out and the DFSA regime applies there. On the compliance side, a VARA licensee is a virtual asset service provider under the federal AML law, so our onboarding, goAML and sanctions screening procedures apply to it from day one.
| Cites | Dubai Economic Activities Law · DIFC Law 2021 |
| Cited by | IFZA Terms and Conditions |
“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.
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