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 distribution services for Category 2 VA issuances. Current version effective 19 June 2025 (first version February 2023).

Summary

The Broker-Dealer Services Rulebook applies to every VASP licensed by VARA to provide Broker-Dealer Services in Dubai outside the DIFC, in addition to the VARA Regulations and the four compulsory Rulebooks. Schedule 1 of the Regulations defines the activity broadly: arranging, soliciting or accepting orders, matching buyers and sellers, dealing on own account, market making with client assets, and placement or distribution services for issuers. The version in force took effect on 19 June 2025.

The policies Part requires written policies on preventing Market Offences, order execution and routing, and clients' ability to withdraw their virtual assets in volatile periods, reviewed at least yearly. Website disclosures include, for each virtual asset offered, its symbol, issue date, market capitalisation, circulating supply, smart-contract audit status and price history, how quoted prices are set, and the identity of any liquidity source receiving 20% or more of client orders.

Part II imposes a best execution duty: reasonable diligence to obtain the most favourable price under prevailing conditions, with narrow exceptions for quotes requested by another VARA-licensed VASP or by qualified or institutional investors where the VASP does not deal as principal. Fees retained must be disclosed before execution and in the trade confirmation, third-party benefits for execution are prohibited, and routed or internalised order flow must be reviewed at least quarterly. A broker-dealer may deal as principal subject to best execution, but may use client money or client virtual assets only as the Compliance and Risk Management Rulebook permits, and may add Advisory Services if it meets that Rulebook and its capital requirement.

Part III permits margin trading only where VARA expressly authorises it in the Licence, with suitability checks, segregated margin accounts, no use of one client's funds for another, monthly statements, early-warning and margin-call notices, credit to a single client capped at one tenth of total margin funding, and collateral limited to the financed asset, fiat or VARA-approved USD or AED referenced virtual assets.

Part IV governs Licensed Distribution Services, the route for Category 2 issuances under the VA Issuance Rulebook. The distributor must ensure the quality of each issuer and virtual asset, check the whitepaper, risk disclosures and smart-contract audits, and file them with VARA; distribution may start only after a 15 Working Day submission period passes without comment or objection, which is not VARA approval. Paid-up capital under the Company Rulebook is the higher of AED 600,000 or 25% of fixed annual overheads, or AED 400,000 or 15% where a licensed custodian is used.

Who it applies to

VASPs licensed by VARA for Broker-Dealer Services in Dubai outside the DIFC, including OTC dealers, order arrangers, market makers and Licensed Distributors placing virtual assets for issuers, together with their clients, margin-trading customers and the issuers they distribute for.

Contents

English official text in 56 rules. Open the full text or jump to a provision:

1. Rule I.A.1
2. Rule I.A.2
3. Rule I.B.1
4. Rule I.B.2 — Other disclosable matters
5. Rule I.B.3
6. Rule II.A.1
7. Rule II.A.2
8. Rule II.A.3
9. Rule II.A.4
10. Rule II.A.5
11. Rule II.A.6
12. Rule II.A.7
13. Rule II.A.8
14. Rule II.A.9
15. Rule II.A.10
16. Rule II.A.11
17. Rule II.A.12
18. Rule II.A.13
19. Rule II.A.14
20. Rule II.A.15
21. Rule II.A.16
22. Rule II.B.1
23. Rule II.B.2
24. Rule II.C.1
25. Rule III.A.1
26. Rule III.A.2
27. Rule III.A.3
28. Rule III.B.1
29. Rule III.B.2
30. Rule III.B.3
31. Rule III.C.1
32. Rule III.D.1
33. Rule III.D.2
34. Rule III.D.3
35. Rule III.E.1
36. Rule III.E.2
37. Rule IV.A.1
38. Rule IV.A.2
39. Rule IV.A.3
40. Rule IV.B.1 — Responsibility
41. Rule IV.B.2
42. Rule IV.B.3 — Due diligence and assessment of Virtual Assets
43. Rule IV.B.4 — Due diligence and assessment of Issuer
44. Rule IV.B.5 — Disclaimer
45. Rule IV.C.1 — Written agreements
46. Rule IV.C.2 — Conflicts of interest
47. Rule IV.D.1
48. Rule IV.D.2
49. Rule IV.D.3
50. Rule IV.D.4
51. Rule IV.D.5
52. Rule IV.D.6
53. Rule IV.D.7
54. Rule IV.E.1 — Monitoring
55. Rule IV.E.2
56. Rule IV.E.3

Key provisions

Obligations and deadlines

• Review broker-dealer policies and procedures at least once a year.
• Disclose retained fees before execution and in each trade confirmation.
• Review execution quality of routed or internalised order flow at least quarterly.
• Obtain express VARA authorisation in the Licence before offering margin trading.
• Send margin clients written statements at least monthly and warn them before maintenance margin is breached.
• File distribution documents with VARA and wait out the 15 Working Day submission period before placing any virtual asset.
• Suspend distribution immediately if a distributed virtual asset or issuer no longer meets the quality requirements.

Penalties

The Rulebook sets no fines of its own. Breaches are enforced under Part IX of the VARA Regulations, with indicative fines under Schedule 3; breaches involving Market Offences carry up to the higher of AED 50,000,000, 15% of annual revenue or 300% of profits gained for a corporate Entity. VARA may also order a VASP to suspend margin trading, close client positions, raise margin requirements, or suspend or cease distribution for specified assets, issuers or clients.

History and citations

“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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