VARA VA Issuance Guidance

Non-binding VARA guidance, dated 9 April 2026, explaining the VA Issuance Rulebook rule by rule, including issuance categories, licensed distributors, whitepapers, risk disclosures and asset-referenced virtual assets, with illustrative examples and whitepaper requirements.

Summary

This is VARA's non-binding guidance on the Virtual Asset Issuance Rulebook, dated 9 April 2026. It explains the Rulebook rule by rule in 35 numbered topics and adds fictional worked examples. It does not replace the Regulations, the Rulebooks or independent legal advice.

On scope, it confirms that issuers can be natural or legal persons, and that any direct or indirect commercial element makes an issuance one made in the course of a business even if the asset is not sold for money; only issuances solely for personal or non-commercial use fall outside. It explains the categories. Category 1, currently fiat-referenced and asset-referenced virtual assets, needs a VARA licence and makes the issuer a VASP bound by the four compulsory Rulebooks. Category 2 is the residual category, with placement and distribution only through a Licensed Distributor, which is a VASP licensed for Broker-Dealer Services. Exempt VAs are limited to non-transferable assets, such as commemorative items not sold by the issuer, and redeemable closed-loop assets, such as loyalty points and discount schemes that cannot be traded. If a change to an asset would move it into another category, the issuer must meet the new category's requirements before the change takes effect.

The guidance explains that an asset-referenced virtual asset includes any token representing ownership of, or a right to income from, a real-world asset, and that real-world assets include securities under the UAE Capital Markets Authority's rules, real estate, precious metals, and contractual or intellectual property rights. It describes what a legal opinion required by VARA from such an issuer should cover, and gives examples of whitepaper clauses that breach the Rulebook, including disclaimers of liability for errors and statements that no reliance should be placed on the whitepaper. A worked example follows a Licensed Distributor through due diligence, filing with VARA and the 15 Working Day submission period, which is not VARA approval.

Who it applies to

Issuers of virtual assets in Dubai outside the DIFC, including foundations and non-profit bodies, issuers of fiat-referenced and asset-referenced tokens, Licensed Distributors and their advisers, as an explanation of how VARA applies the VA Issuance Rulebook; it binds no one by itself.

Contents

English official text in 35 sections. Open the full text or jump to a provision:

1. Section I.1 — VA Issuance Rulebook Reference: I.A.1
2. Section I.2 — VA Issuance Rulebook Reference: I.A.2
3. Section I.3 — VA Issuance Rulebook Reference: I.C.1
4. Section I.4 — VA Issuance Rulebook Reference: I.C.1; Category 1
5. Section I.5 — VA Issuance Rulebook Reference: I.C.1; Category 2
6. Section I.6 — VA Issuance Rulebook Reference: I.C.1; Exempt VAs
7. Section I.7 — VA Issuance Rulebook Reference: I.C.3
8. Section I.8 — VA Issuance Rulebook Reference: I.E.1
9. Section I.9 — VA Issuance Rulebook Reference: I.E.3
10. Section I.10 — VA Issuance Rulebook Reference: III.B.1
11. Section I.11 — VA Issuance Rulebook Reference: III.B.3
12. Section I.12 — VA Issuance Rulebook Reference: III.B.5
13. Section I.13 — VA Issuance Rulebook Reference: III.B.6
14. Section I.14 — VA Issuance Rulebook Reference: III.C.1
15. Section I.15 — VA Issuance Rulebook Reference: III.C.2
16. Section I.16 — VA Issuance Rulebook Reference: Schedule 1; A.3
17. Section I.17 — VA Issuance Rulebook Reference: Schedule 1; B.A.vi
18. Section I.18 — VA Issuance Rulebook Reference: Schedule 1; B.A.viii
19. Section I.19 — VA Issuance Rulebook Reference: Schedule 1; B.A.ix
20. Section I.20 — VA Issuance Rulebook Reference: Schedule 2; “Asset Referenced Virtual Asset" or “ARVA"
21. Section I.21 — VA Issuance Rulebook Reference: Schedule 2; “Fiat-Referenced Virtual Asset" or “FRVA"
22. Section I.22 — VA Issuance Rulebook Reference: Schedule 2; “Income"
23. Section I.23 — VA Issuance Rulebook Reference: Schedule 2; “Non-Transferable Virtual Asset"
24. Section I.24 — VA Issuance Rulebook Reference: Schedule 2; “Redeemable Closed-Loop Virtual Asset"
25. Section I.25 — VA Issuance Rulebook Reference: Schedule 2; “RWA"
26. Section I.26 — VA Issuance Rulebook Reference: Annex 2; I.A.3
27. Section I.27 — VA Issuance Rulebook Reference: Annex 2; I.A.4
28. Section I.28 — VA Issuance Rulebook Reference: Annex 2; III.C.1
29. Section I.29 — VA Issuance Rulebook Reference: Annex 2; II.A.1
30. Section I.30 — VA Issuance Rulebook Reference: Annex 2; II.B.1 and II.B.2
31. Section I.31 — VA Issuance Rulebook Reference: Annex 2; III.B.1
32. Section I.32 — VA Issuance Rulebook Reference: Annex 2; III.B.2
33. Section I.33 — VA Issuance Rulebook Reference: Annex 2; III.C.3
34. Section I.34 — VA Issuance Rulebook Reference: Annex 2; III.C.4
35. Section I.35 — VA Issuance Rulebook Reference: Annex 2; III.E.1

Key provisions

History and citations

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