VARA Market Conduct Rulebook

Compulsory rulebook on marketing, written client agreements, complaints handling, investor classification (retail, qualified and institutional), public disclosures, market transparency, trading for own account and VA standards. Current version effective 19 June 2025 (earlier versions February and October 2023).

Summary

The Market Conduct Rulebook is the fourth compulsory VARA Rulebook and applies to every VASP licensed by VARA in Dubai outside the DIFC. It governs how a VASP deals with clients and the market: marketing, client agreements, complaints, investor classification, public disclosures, insider lists, staff dealing, proprietary trading and the standards a VASP applies before supporting a virtual asset. The version in force took effect on 19 June 2025.

Every VASP must comply with the VARA Marketing Regulations. It must have a written Client Agreement with each client, accepted before any service is provided, fair, clear and not misleading, with any change notified at least 30 calendar days in advance. The agreement must identify the VASP and its group, the services and all fees, the governing law and third-party providers, say when assets leave the VASP's control, and state that client money and client virtual assets remain the client's property and have no deposit protection.

Complaints must be acknowledged within one week and resolved within four weeks, or within eight weeks in extraordinary circumstances with a status update by week four; handling must be free of charge and the procedure published on the VASP's website. Part IV sets three investor classes. A Qualified Investor is an individual with relevant knowledge and either net assets of at least AED 3,500,000 (excluding the primary residence and counting only 50% of virtual assets) or annual income of AED 700,000 or more, or a legal entity with net assets of AED 3,500,000 whose directors have relevant knowledge. Institutional Investors include regulated financial entities, VASPs, governments, central banks and multilateral agencies; everyone else is a Retail Investor. A VASP may deal only with the classes VARA permits.

VASPs must publish their licence number, licensed activities, Responsible Individuals and a risk disclosure statement on their website in machine-readable form. They must keep insider lists for at least eight years, require Board members and staff to obtain approval for personal virtual asset positions, outside shareholdings and directorships, and collect declarations every six months. Part VII prohibits a VASP from actively investing its own or its group's portfolio, except for prudent management of net liquid assets and treasury. Part VIII requires published VA Standards and due diligence before a VASP supports any virtual asset.

Who it applies to

Every VASP licensed by VARA in Dubai outside the DIFC, its Board members and Staff, group entities that invest their own portfolio, advisers and service providers with access to inside information, and the retail, qualified and institutional clients the VASP serves.

Contents

English official text in 53 rules. Open the full text or jump to a provision:

1. Rule I.A.1
2. Rule II.A.1
3. Rule II.A.2
4. Rule II.A.3
5. Rule II.A.4
6. Rule II.A.5
7. Rule II.A.6
8. Rule II.A.7
9. Rule II.A.8
10. Rule II.A.9
11. Rule II.B.1
12. Rule II.B.2
13. Rule II.B.3
14. Rule III.A.1 — Complaints handling
15. Rule III.A.2
16. Rule III.A.3
17. Rule III.A.4
18. Rule III.A.5
19. Rule III.B.1
20. Rule III.B.2
21. Rule III.B.3
22. Rule IV.A.1 — General provision
23. Rule IV.A.2 — Retail Investor
24. Rule IV.A.3 — Qualified Investor
25. Rule IV.A.4 — Institutional Investor
26. Rule V.A.1
27. Rule V.A.2
28. Rule V.A.3
29. Rule V.B.1
30. Rule VI.A.1
31. Rule VI.A.2
32. Rule VI.A.3
33. Rule VI.A.4
34. Rule VI.A.5
35. Rule VI.B.1
36. Rule VI.B.2
37. Rule VI.B.3
38. Rule VI.B.4
39. Rule VI.B.5
40. Rule VII.A.1
41. Rule VII.A.2
42. Rule VII.A.3
43. Rule VII.B.1
44. Rule VII.B.2
45. Rule VIII.A.1
46. Rule VIII.A.2
47. Rule VIII.A.3
48. Rule VIII.A.4
49. Rule VIII.B.1
50. Rule VIII.B.2
51. Rule VIII.B.3
52. Rule VIII.B.4
53. Rule VIII.B.5

Key provisions

Obligations and deadlines

• Obtain each client's acceptance of a written Client Agreement before providing any VA Activity.
• Give clients at least 30 calendar days' notice of any change to the Client Agreement.
• Acknowledge complaints within one week and resolve them within four weeks, or eight in extraordinary circumstances.
• Classify every client as Retail, Qualified or Institutional and deal only with the classes VARA permits.
• Publish licence number, licensed activities, Responsible Individuals and risk disclosures on the website in machine-readable form.
• Keep insider lists up to date and retain them for at least eight years.
• Collect declarations of Board and staff virtual asset positions, shareholdings and directorships at least every six months.
• Publish VA Standards and complete due diligence before supporting any virtual asset.

Penalties

Schedule 3 of the VARA Regulations groups breaches of the Market Conduct Rulebook with Market Offences: indicative fines of up to the higher of AED 50,000,000, 15% of annual revenue or 300% of profits gained or losses avoided for a corporate Entity, and up to the higher of AED 20,000,000 or 200% of profits gained or losses avoided for an individual. Breaches can also lead to enforcement notices and suspension or revocation of the Licence under Part IX of the Regulations.

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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