VARA Marketing Guidance

Non-binding VARA guidance explaining key terms of the Marketing Regulations topic by topic, with illustrative examples and case studies on non-compliant adverts, events and trade shows, journalistic and educational content, influencers, incentives and token promotion.

Summary

This is VARA's non-binding guidance, dated 31 August 2024, on the Regulations on the Marketing of Virtual Assets and Related Activities 2024. It explains key phrases topic by topic and gives fictional worked examples. It is indicative only: it does not replace the Marketing Regulations or independent legal advice, and the binding rules and fines remain those in the Regulations.

The first Part, Guidance by Topic, takes thirteen phrases in turn. Marketing is read broadly, considering content, audience, channel, commercial purpose and intent. Marketing is in or targeting the UAE if any element of the campaign is in the UAE, and VARA treats GCC-wide campaigns, AED pricing, Emirati dialect, UAE or Dubai imagery, UAE celebrities, UAE-focused channels and the absence of geo-blocking as indicators; campaigns are judged as a whole, and targeting the UAE is treated as targeting Dubai. Whether marketing is fair, clear and not misleading is judged by its overall impression. Incentives include sign-up bonuses, referral rewards and gifts; they must not create urgency or overshadow risk warnings, and any bonus must show the charges that apply after it ends. A prominent disclaimer must be unmissable: legible, proportionate, close to the main content and visible or audible long enough. Sponsored content cannot qualify as educational, and communications accessible to 50 or more people are never purely personal or private.

Part II applies these readings to cases: non-compliant adverts; events and trade shows, where unlicensed exhibitors may show only their name, logo and activities with a not-licensed disclaimer and may not onboard UAE residents; journalistic and educational content; influencers, who must label each sponsored post clearly (a bio statement or '#spon' is not enough) and confirm the VASP is licensed; referral and incentive schemes, which need VARA approval; and token promotion, where factual pages with disclaimers are acceptable but posts hinting at price rises or inviting trading are not.

Who it applies to

Anyone subject to the VARA Marketing Regulations, including VASPs, unlicensed foreign firms, token issuers, marketing agencies, influencers, journalists, educators, platforms and event organisers, as an explanation of how VARA reads those Regulations; it binds no one by itself.

Contents

English official text in 13 sections. Open the full text or jump to a provision:

1. Section I.1 — “advertisement, inducement, solicitation, offer or promotion”
2. Section I.2 — “in or targeting the UAE”
3. Section I.3 — “fair, clear and not misleading”
4. Section I.4 — “clearly identifiable as marketing or promotional in nature”
5. Section I.5 — “clear and prominent indication that such content was posted, publicised or otherwise presented as part of a remunerated arrangement”
6. Section I.6 — “monetary or non-monetary incentive”
7. Section I.7 — “prominent disclaimer”
8. Section I.8 — “prior consent or expression of interest”
9. Section I.9 — “in its capacity as a journalist”
10. Section I.10 — “overall purpose”
11. Section I.11 — “nature of the author Entity’s interest”
12. Section I.12 — “educational content”
13. Section I.13 — “purely personal or private communications”

Key provisions

History and citations

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