VARA Regulations

Core VARA framework: no Entity may carry out a VA Activity in Dubai outside DIFC without a VARA Licence; sets issuance, AML, marketing, market-offence, supervision and confidentiality rules, with schedules of VA Activities, licence and supervision fees, fines and definitions. Current version effective 19 June 2025 (earlier versions: February, June and September 2023, October 2024).

Summary

The Virtual Assets and Related Activities Regulations 2023 are VARA's core instrument under Dubai Law No. 4 of 2022. They apply to all virtual assets and VA Activities in the Emirate, defined as every zone of Dubai, including special development zones and free zones, but excluding the DIFC. The version in force took effect on 19 June 2025.

Regulation III.A.1 sets the general prohibition: no Entity may carry out a VA Activity by way of business in the Emirate, or purport to do so, unless it is licensed by VARA for that activity, an employee acting for a licensed employer, or an Exempt Entity. Regulation III.A.2 lists the tests for 'by way of business' (holding out, regularity and scale, a commercial element), and Regulation III.A.3 bars anyone from presenting itself as a VASP or Exempt Entity without that status. Part IV requires a separate VARA Licence for each VA Activity before it is conducted, exempts lawyers, accountants and licensed consultants acting wholly incidentally to their practice, and obliges any Entity investing USD 250,000,000 or more of its own portfolio in virtual assets within a rolling 30-day period to register with VARA no later than three Working Days after reaching that volume. Schedule 1 defines the regulated activities: Advisory, Broker-Dealer, Custody, Exchange, Lending and Borrowing, VA Management and Investment, and VA Transfer and Settlement Services, with Category 1 VA Issuance.

Part V makes four Rulebooks compulsory for every VASP (Company; Compliance and Risk Management; Technology and Information; Market Conduct) and adds the activity Rulebook for each licensed activity. Part II requires issuers to follow the VA Issuance Rulebook and prohibits Anonymity-Enhanced Cryptocurrencies. Part VI designates VARA as AML/CFT supervisory authority for VASPs in the Emirate; its text still cites Federal Decree-Law No. 20 of 2018, since replaced by Federal Decree-Law No. 10 of 2025. Part VII applies the 2024 Marketing Regulations to all Entities, Part VIII defines insider dealing, unlawful disclosure and market manipulation as Market Offences, and Part X makes all dealings with VARA confidential.

Schedule 2 sets licence application fees of AED 40,000 (Advisory; VA Transfer and Settlement) or AED 100,000 (other activities), 50% of the lower application fee for each additional activity, and annual supervision fees of AED 80,000 or AED 200,000 per activity, payable before the activity starts. Under Regulation IX.A.3, VASPs and Issuers stay subject to the regime for ten years after they cease to be regulated.

Who it applies to

Every legal entity or individual carrying on, or purporting to carry on, a VA Activity or issuing a virtual asset in Dubai outside the DIFC, including the free zones; licensed VASPs and their Responsible Individuals; Exempt Entities; large proprietary traders; service providers VARA designates as critical; and anyone marketing virtual assets into the UAE.

Contents

English official text in 101 regulations. Open the full text or jump to a provision:

1. Regulation I.A.1 — VARA jurisdiction
2. Regulation I.A.2 — VARA powers and functions
3. Regulation I.A.3 — Power to amend Regulations
4. Regulation I.B.1 — General power to issue Rules, Directives and Guidance
5. Regulation I.B.2 — Rules
6. Regulation I.B.3 — Directives
7. Regulation I.B.4 — Guidance
8. Regulation I.B.5 — Modification or waiver of Regulations, Rules, Directives and/or Guidance
9. Regulation I.B.6 — General powers
10. Regulation II.A.1 — General requirement
11. Regulation II.B.1
12. Regulation II.B.2
13. Regulation II.C.1
14. Regulation III.A.1 — General prohibition
15. Regulation III.A.2 — “By way of business” requirement
16. Regulation III.A.3 — False claims of VASP or Exempt Entity status
17. Regulation III.A.4 — UAE Central Bank
18. Regulation IV.A.1 — Requirement to hold a Licence
19. Regulation IV.A.2 — Licensing process
20. Regulation IV.A.3 — Requirement to meet licensing conditions
21. Regulation IV.A.4 — Activities outside of the Emirate
22. Regulation IV.A.5 — Professional Exemption
23. Regulation IV.A.6 — Exempt Entities
24. Regulation IV.A.7 — Mandatory registration for large proprietary traders
25. Regulation IV.A.8 — Voluntary registration for other market participants
26. Regulation IV.A.9 — Critical and systemically important service providers
27. Regulation IV.A.10
28. Regulation IV.A.11
29. Regulation IV.B.1 — Granting of Licences
30. Regulation IV.B.2 — Variation, suspension or revocation of Licences
31. Regulation IV.B.3 — Imposition of further requirements by VARA
32. Regulation IV.B.4 — Authorisation and supervision fees
33. Regulation V.1 — Rulebooks
34. Regulation V.2 — VA Activity specific Rulebooks
35. Regulation VI.A.1
36. Regulation VI.A.2
37. Regulation VI.A.3
38. Regulation VI.A.4
39. Regulation VI.A.5
40. Regulation VI.B.1
41. Regulation VII.A.1
42. Regulation VIII.A.1
43. Regulation VIII.A.2
44. Regulation VIII.A.3
45. Regulation VIII.A.4
46. Regulation VIII.B.1
47. Regulation VIII.B.2
48. Regulation VIII.B.3
49. Regulation VIII.C.1
50. Regulation VIII.C.2
51. Regulation VIII.C.3
52. Regulation VIII.D.1
53. Regulation VIII.D.2
54. Regulation VIII.E.1
55. Regulation VIII.F.1
56. Regulation VIII.F.2
57. Regulation VIII.F.3
58. Regulation VIII.G.1
59. Regulation VIII.G.2
60. Regulation VIII.G.3
61. Regulation VIII.G.4
62. Regulation VIII.G.5
63. Regulation VIII.G.6
64. Regulation VIII.G.7
65. Regulation VIII.H.1
66. Regulation VIII.H.2
67. Regulation VIII.H.3
68. Regulation VIII.I.1
69. Regulation VIII.J.1
70. Regulation VIII.J.2
71. Regulation VIII.J.3
72. Regulation VIII.J.4
73. Regulation IX.A.1
74. Regulation IX.A.2
75. Regulation IX.A.3
76. Regulation IX.B.1
77. Regulation IX.B.2
78. Regulation IX.B.3
79. Regulation IX.B.4
80. Regulation IX.B.5
81. Regulation IX.B.6
82. Regulation IX.B.7
83. Regulation IX.C.1
84. Regulation IX.C.2
85. Regulation IX.C.3
86. Regulation IX.C.4
87. Regulation IX.C.5
88. Regulation IX.C.6 — Grievances
89. Regulation X.A.1
90. Regulation X.A.2
91. Regulation 1
92. Regulation 2
93. Regulation 3
94. Regulation 4
95. Regulation 5
96. Regulation 6
97. Regulation 1
98. Regulation 2
99. Regulation 3
100. Regulation 4
101. Regulation 5

Key provisions

Obligations and deadlines

• Obtain a VARA Licence for each VA Activity before carrying it out anywhere in Dubai outside the DIFC.
• Register with VARA within three Working Days of investing USD 250,000,000 of own portfolio in virtual assets in any rolling 30-day period.
• Exempt Entities must notify VARA and obtain a no-objection confirmation before carrying out any VA Activity.
• Pay the Licence Application Fee on submission and the Annual Supervision Fee for each activity before conducting it.
• Comply at all times with the four compulsory Rulebooks and with each activity Rulebook that matches the Licence.
• Produce information and documents to VARA within the period set in its notice and assist any examination, including of affiliates.
• Keep all communications and dealings with VARA confidential unless VARA consents or the information is already public.

Penalties

Regulation IX.C.2 allows reprimands, enforcement and cease-and-desist notices, limiting, suspending or revoking a Licence (and commercial licences in coordination with the competent authority), mandatory public statements, fines and extra supervision; fines can be imposed directly on Responsible Individuals (IX.C.3), and periodic penalties for continuing breaches (IX.C.5). Schedule 3 sets indicative fines: AML/CFT and KYC breaches are fined under local and federal law; breaches of the Compliance and Risk Management or Market Conduct Rulebooks and 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, and AED 20,000,000 or 200% for an individual. Unpaid fines accrue a further 1% per month, compounded.

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.

Related instruments

Related Polaris services

• Corporate Structuring & Group Design
• Free Zone Company Formation UAE
• Mainland Company Formation UAE
• AML Compliance UAE — goAML, KYC