VARA Lending and Borrowing Services Rulebook

VARA Rulebook of 2025 · Dubai

Official title
Lending and Borrowing Services Rulebook
Instrument
VARA Rulebook of 2025
Issued by
Dubai Virtual Assets Regulatory Authority (VARA)
Jurisdiction
Dubai
Dates
issued 19 May 2025 · in force 19 June 2025
Status
in force (amended)
Topics
Virtual assets · Licensing · Banking & finance
Official source
rulebooks.vara.ae · official text (PDF)
Full text
English official text — 29 rules, 2,861 words, from the official text
Verified
31 October 2026
Print

Activity rulebook for Lending and Borrowing Services: policies, activity-specific and other disclosures, general requirements, client reporting and valuation, record-keeping, risk management and due diligence, and client agreements. Current version effective 19 June 2025 (first version February 2023).

Summary

The Lending and Borrowing Services Rulebook applies to every VASP licensed by VARA to provide Lending and Borrowing Services in Dubai outside the DIFC. Schedule 1 of the VARA Regulations defines the activity as carrying out a contract under which a virtual asset is transferred or lent by lenders to borrowers who commit to return it on request or at the end of the agreed period. The Rulebook applies in addition to the Regulations and the four compulsory Rulebooks, and the version in force took effect on 19 June 2025.

Disclosure is the heaviest part. Besides conflicts, privacy, whistleblowing and complaints policies, the VASP must publish how clients can access and withdraw their assets in volatile markets, how client assets are used and protected from counterparty risk (including whether loans are over-collateralised), the risk of loss, and how liquidity risk is managed. For assets it borrows from clients it must disclose the denomination, rate and nature of interest as an annual percentage yield, whether the figure is an estimate, how often interest accrues and whether it is simple or compound. It must also publish which services are available to which client types, a lending and borrowing asset and liability report updated at least every three months, and its protocol governance arrangements.

The conduct Part requires the VASP to keep enough virtual assets to meet client obligations and enough borrower collateral, and to notify VARA immediately if either may not be met. Clients must know when assets cannot be withdrawn; client assets may be used only on the terms of the Client Agreement and are held for the client unless the agreement says otherwise; and counterparties must be checked regularly for loan purpose, business, financial position and liquidity. Clients receive written statements at least monthly covering balances, transactions, interest and collateral, positions are independently valued, transaction and counterparty records are kept for eight years, and risk management and due diligence are audited by an independent third party. Client Agreements must state loan-to-value ratios, interest terms, rights over collateral, withdrawal rights, default consequences and risk warnings, and obtain the client's consent to the use of its assets.

Under the Company Rulebook, paid-up capital for this activity is the higher of AED 500,000 or 25% of fixed annual overheads; Schedule 2 of the Regulations sets an AED 100,000 application fee and an AED 200,000 annual supervision fee.

Who it applies to

VASPs licensed by VARA for Lending and Borrowing Services in Dubai outside the DIFC, including yield and collateralised lending providers, their Boards and Staff, third parties through which the services are offered, and the lending and borrowing clients and counterparties they deal with.

Contents

English official text in 29 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 I.C.1 — Interest payments to clients
  7. Rule I.D.1 — Lending and Borrowing Services explanation
  8. Rule I.D.2 — Lending and borrowing asset and liability report
  9. Rule I.D.3 — Governance controls
  10. Rule I.D.4 — Third parties
  11. Rule II.A.1 — Liquidity
  12. Rule II.A.2
  13. Rule II.A.3 — Withdrawals
  14. Rule II.A.4 — Collateral
  15. Rule II.A.5
  16. Rule II.A.6 — Counterparty due diligence
  17. Rule II.B.1
  18. Rule II.B.2
  19. Rule II.B.3
  20. Rule II.B.4
  21. Rule II.C.1
  22. Rule II.C.2
  23. Rule II.D.1
  24. Rule II.D.2
  25. Rule II.D.3
  26. Rule II.D.4
  27. Rule II.D.5
  28. Rule II.E.1
  29. Rule II.E.2

Key provisions

Rules I.A.1 and I.A.2Written policies must cover clients' ability to access and withdraw virtual assets, including in periods of extreme volatility, and be reviewed at least yearly.
Rule I.B.1Website statements on conflicts, withdrawal rights in volatile markets, protection and uses of client assets, counterparty risk including over-collateralisation, risk of loss and liquidity risk management.
Rule I.C.1For assets borrowed from clients, disclose interest denomination and choice, rate as an annual percentage yield, whether fixed or variable or estimated, accrual frequency and simple or compound basis.
Rules I.D.1 to I.D.3Publish an explanation of services by client type and any regulatory restrictions, a lending and borrowing asset and liability report updated at least every three months, and protocol governance arrangements.
Rules II.A.1 and II.A.2The VASP must always hold enough virtual assets to meet client obligations and ensure borrowers post agreed collateral, and must notify VARA immediately if either is or may not be met.
Rules II.A.3 to II.A.5Clients must be told when assets cannot be withdrawn; held assets may be used only under the Client Agreement terms and are held on behalf of the client unless the agreement expressly says otherwise.
Rule II.A.6Regular due diligence on clients and counterparties, collecting loan purpose, nature of business, financial situation and liquidity, so client assets are not exposed to undue counterparty risk.
Rules II.B.1 to II.B.4Monthly written statements to clients showing account value, transactions, interest credited or debited and collateral posted, with independent valuation of positions under documented valuation policies.
Rule II.C.1Records of all lending and borrowing transactions, Client Agreements, counterparty agreements, client instructions and counterparty due diligence must be kept for at least eight years.
Rules II.D.1 to II.D.5Before lending or borrowing, assess client and transaction risk and collateral suitability and enforceability; monitor liquidity and market risk; keep collateral adequate; have risk management independently audited.
Rules II.E.1 and II.E.2Client Agreements must set out the assets, loan-to-value ratios, interest terms, rights over collateral, withdrawal and termination rights, default consequences and risk warnings, and obtain consent to the use of client assets.

Obligations and deadlines

  • Publish the lending and borrowing asset and liability report and update it at least every three months.
  • Disclose interest as an annual percentage yield, with its denomination, accrual frequency and simple or compound basis.
  • Notify VARA immediately if virtual assets or borrower collateral may not suffice to meet client obligations.
  • Send each client a written statement at least monthly covering balances, transactions, interest and collateral.
  • Keep transaction records and counterparty due diligence for at least eight years.
  • Have risk management and due diligence audited regularly by an independent third party.
  • Obtain each client's consent in the Client Agreement before using its virtual assets.

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 for violations of Rules, and may lead to enforcement notices, limits on the licensed activity, or suspension or revocation of the Licence.

In practice — how Polaris handles it

Crypto lending, yield and collateralised credit products are where clients most often underestimate the licence. A product that pays a yield on deposited tokens, or lends them on, is likely to fall within the Schedule 1 definition, and promoting it engages the Marketing Regulations' limits on return claims and credit. We help clients test the product against the definition with their licensed advisers, then build the corporate side: the Dubai entity with at least AED 500,000 paid-up capital, the Board and Responsible Individuals, the corporate approvals behind client and counterparty agreements, and a compliance calendar for the quarterly asset and liability report and monthly client statements. Polaris is not licensed by VARA and does not lend, borrow or arrange virtual-asset credit.

History and citations

CitesDubai 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.

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Related Polaris services

Source and verification. This record was written from the official text published at rulebooks.vara.ae, read on 31 October 2026. Quoted from that text: “VASPs shall publish and update at least every three (3) months a lending and borrowing asset and liability report”
Published for general information by Polaris Corporate Services FZ-LLC, a licensed Trust and Corporate Service Provider. It is not legal advice and does not replace the official text, which prevails in case of difference. Arabic is the authoritative language of UAE federal and emirate legislation; English translations are provided by the issuing authorities. Instruments change: check the status and the official source before relying on this page.

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