VARA Rulebook of 2025 · Dubai
Activity rulebook for VASPs licensed to give Advisory Services: policies, procedures and public disclosures, client suitability, staff competency, verification of client information and advisory methodology. Applies in addition to the Regulations and compulsory rulebooks. Current version effective 19 June 2025.
The Advisory Services Rulebook applies to every VASP licensed by VARA to carry out Advisory Services in Dubai outside the DIFC, in addition to the VARA Regulations and the four compulsory Rulebooks. Advisory Services, as defined in Schedule 1 of the Regulations, means offering, providing or agreeing to provide a personal recommendation to a client on transactions relating to virtual assets. The version in force took effect on 19 June 2025. Where a VASP holds licences for other activities, the activity Rulebooks apply cumulatively.
The policies Part requires written policies on how the VASP keeps its advice independent and how it ensures staff competence, reviewed at least yearly. The VASP must publish on its website the actual or potential conflicts of interest and how they are managed, its data privacy, whistleblowing and complaints policies, any referral or introduction arrangements with other Entities and the benefits it receives from them, whether third parties hold its accounts, funds or virtual assets, and, as far as law permits, past convictions or prosecutions of Board members or Senior Management.
Part II is the conduct core. Advice must be given in good faith, be suitable for and in the best interest of each client, and take account of the client's knowledge and experience, investment objectives (risk tolerance, time horizon, venues) and financial circumstances, including the ability to bear sudden losses. Client information must be collected, kept accurate and retained for at least eight years, and each piece of advice must explain why it suits the client by reference to those factors. VASPs must eliminate conscious bias and take reasonable steps against unconscious bias. Staff must be competent, judged by qualifications, virtual-asset sector and investment-advice experience, and knowledge of the VARA framework. Statements, promises and forecasts must be verified against reliable sources and must not be misleading, and the advisory methodology must consider a range of virtual assets diverse enough to meet the client's objectives.
Under Schedule 2 of the Regulations the licence application fee for Advisory Services is AED 40,000 and the annual supervision fee AED 80,000, and the Company Rulebook sets paid-up capital of AED 100,000 for this activity.
VASPs licensed by VARA to give Advisory Services (personal recommendations on virtual asset transactions) in Dubai outside the DIFC, their Board, Senior Management and advisory Staff, and the clients who receive their advice.
English official text in 14 rules. Open the full text or jump to a provision:
| Rule I.A.1 | VASPs giving Advisory Services must have written policies and procedures on how they ensure the independent basis of their advice and the competence of all Staff who advise. |
| Rule I.A.2 | The effectiveness of advisory policies and procedures must be assessed and reviewed at least yearly, with measures taken to address any deficiencies. |
| Rule I.B.1 | Website disclosure of conflicts of interest and their management, data privacy, whistleblowing and complaints policies, referral arrangements and benefits received, and any third party holding the VASP's accounts, funds or virtual assets. |
| Rule I.B.2 | So far as law permits, VASPs must publish past convictions or prosecutions of members of their Senior Management or Board, in the UAE or elsewhere. |
| Rule II.A.2 | Advice must be in good faith, suitable and in each client's best interest, considering knowledge and experience, investment objectives including risk tolerance and time horizon, and financial circumstances including ability to bear losses. |
| Rules II.A.3 and II.A.4 | Client information for the suitability assessment must be collected, kept accurate and retained for at least eight years, and every piece of advice must explain why it suits the client. |
| Rule II.A.5 | VASPs must eliminate conscious bias and take all reasonable steps to eliminate non-conscious bias, so that clients are not discriminated against on grounds not in their best interest. |
| Rule II.B.1 | Advisory Staff must be knowledgeable, competent and trained, judged by qualifications, virtual-asset sector experience, experience of regulated investment advice, understanding of the VARA framework and industry standards. |
| Rules II.C.1 and II.C.2 | Advice must not contain statements, promises or forecasts known or suspected to be misleading, and factual information must be verified against reliable sources before it is used. |
| Rule II.D.1 | In advising, VASPs must assess a range of virtual assets available to the client that is diverse enough to meet the client's investment objectives. |
The Rulebook sets no penalties of its own. Breaches are enforced under Part IX of the VARA Regulations, with indicative fines under Schedule 3 for violations of Rules, and may lead to limitation, suspension or revocation of the Advisory Services licence.
Clients who want to advise on virtual assets from Dubai often start by asking whether they need a licence at all. We take them through the Schedule 1 definition, a personal recommendation to a client, and the professional exemption in the Regulations, which covers only lawyers, accountants and licensed consultants whose virtual-asset work is wholly incidental to their practice. Where a licence is needed, we form and administer the entity, plan the AED 100,000 paid-up capital and the VARA fees, and prepare the Board and governance documents, while the suitability framework and staff-competency evidence are built with the client's licensed compliance advisers. Polaris is not licensed by VARA and does not give virtual-asset investment advice.
| Cites | Dubai Virtual Assets Law (VARA) |
“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.
VARA Regulations
Core VARA framework: no Entity may carry out a VA Activity in Dubai outside DIFC without a VARA Licence; sets issuance, AML, marketing, market-offence, supervision and co…
VARA Company Rulebook
Compulsory rulebook for every VASP: company and ownership structure, Board, Responsible Individuals and senior management, fit and proper tests, outsourcing, ESG disclosu…
VARA Market Conduct Rulebook
Compulsory rulebook on marketing, written client agreements, complaints handling, investor classification (retail, qualified and institutional), public disclosures, marke…
VARA Compliance and Risk Management Rulebook
Compulsory rulebook covering compliance management, regulatory reporting and notifications, tax reporting, AML/CFT controls including the MLRO, client due diligence, FATF…
VARA VA Management and Investment Services Rulebook
Activity rulebook for VA Management and Investment Services: policies and disclosures, client suitability, staff competency, verification of information, impermissible ac…
VARA Broker-Dealer Services Rulebook
Activity rulebook for Broker-Dealer Services: policies and disclosures, best execution, dealing as principal, advisory services, margin trading rules and licensed distrib…
Whether you are establishing a new venture, restructuring an existing enterprise, or exploring residency pathways — we are here to advise.
Arrange a Consultation →