VARA Rulebook of 2025 · Dubai
Activity rulebook for VA Transfer and Settlement Services: policies and disclosures, general requirements, property interests and protection of client virtual assets, authorisation and responsibility for transfers, and settlement and default rules. Current version effective 19 June 2025 (first version June 2023).
The VA Transfer and Settlement Services Rulebook applies to every VASP licensed by VARA to provide VA Transfer and Settlement Services in Dubai outside the DIFC: the transmission, transfer or settlement of virtual assets from one Entity to another, or to another wallet, address or location, as Schedule 1 of the VARA Regulations defines it. It applies in addition to the Regulations and the four compulsory Rulebooks; the version in force took effect on 19 June 2025.
The policies Part requires written procedures for rectifying non-executed, defective or incomplete transfers, including refunds, and for the Default Rules, reviewed at least yearly, together with website disclosures on conflicts, privacy and complaints policies, referral arrangements and any third party holding the VASP's assets.
Part II links the activity to the wider payments framework. The VASP must comply with any CBUAE requirements on payments and remittances that apply to it, with the law of every jurisdiction its transfers touch, and with the AML/CFT rules in the Compliance and Risk Management Rulebook, including the Travel Rule. It may not sell, lend, rehypothecate, pledge, convert or otherwise use client virtual assets except with the client's explicit prior consent. If a transfer is unauthorised or not carried out as instructed, for any reason, the VASP must refund the client or restore the account within 24 hours of becoming aware and is liable for the client's direct loss; the sending VASP is liable for correct delivery to the recipient. Client instructions and receipts are kept for eight years.
Before contracting, the VASP must disclose the irreversibility of transfers, timing of finality on the ledger, technical risks, its fee schedule, execution times, stop and revocation rights, liability for mistaken transfers and error-resolution rights. For Retail Investors, unilateral changes need 60 calendar days' notice with a free right to terminate, the client may terminate at any time subject to a notice period of no more than 30 calendar days, and the VASP needs 60 calendar days' notice to terminate. Disclosures cannot be used to exclude liability. Any conversion during a transfer must go through a VARA-licensed exchange or a VARA-approved provider outside the Emirate. Receipts are issued when a transfer is initiated and when it is finalised, services must align with international standards for financial market infrastructures, and legally enforceable Default Rules must be tested at least annually.
Under the Company Rulebook, paid-up capital is the higher of AED 500,000 or 25% of fixed annual overheads; Schedule 2 of the Regulations sets an AED 40,000 application fee and an AED 80,000 annual supervision fee.
VASPs licensed by VARA for VA Transfer and Settlement Services in Dubai outside the DIFC, including remittance and settlement providers moving virtual assets for others and custodians granted this licence, together with their senders, recipients and recipient VASPs.
English official text in 29 rules. Open the full text or jump to a provision:
| Rules I.A.1 and I.A.2 | Written procedures for rectifying non-executed, defective or incomplete transfers, including refunds, and for the Default Rules, with effectiveness reviewed at least yearly. |
| Rules II.A.1 to II.A.3 | The VASP must comply with applicable CBUAE payment and remittance requirements, with the law of every jurisdiction its transfers involve, and with the AML/CFT and Travel Rule requirements of the Compliance and Risk Management Rulebook. |
| Rules II.B.1 and II.B.2 | Client virtual assets may not be sold, lent, rehypothecated, pledged, converted or encumbered for a transfer without the client's explicit consent, obtained before services start. |
| Rules II.C.1 to II.C.3 | Transfers must be authorised and follow client instructions; an unauthorised or wrongly executed transfer must be refunded or restored within 24 hours, and the sending VASP is liable for correct delivery. |
| Rule II.C.5 | Records of all client instructions must be maintained for eight years. |
| Rules II.D.1 to II.D.3 | Before contracting, disclose irreversibility, finality and technical risks, fees, execution times, stop and revocation rights, liability and error resolution; Retail Investors get 60 days' notice of changes; disclosures cannot exclude liability. |
| Rule II.E.1 | Any exchange or conversion in the course of a transfer must use a VARA-licensed Exchange Services VASP or a VARA-approved provider outside the Emirate, with the transfer VASP remaining responsible for completion. |
| Rules II.F.1 to II.F.3 | Receipts must be issued immediately when a transfer is initiated and when it is finalised, with amounts, fees, conversions, references and refund and liability statements, and kept for eight years. |
| Rules II.G.1 and II.G.2 | The VASP must demonstrate alignment with internationally accepted standards for financial market infrastructures and have arrangements securing timely discharge of settlement obligations. |
| Rules II.H.1 to II.H.4 | Legally enforceable Default Rules must cover close-out, application of proceeds, default funds, segregation and portability, loss allocation and suspension of defaulting clients, and be reviewed and tested at least annually. |
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 (AML/CFT breaches, including Travel Rule failures, are fined under local and federal law), and may lead to suspension or revocation of the Licence. Rule II.C.2 also makes the VASP directly liable to the client for loss caused by an unauthorised or wrongly executed transfer.
Payment, remittance and treasury clients that move virtual assets for third parties ask us first whether they need this licence, Custody or Broker-Dealer, and whether a Central Bank route applies instead. We walk through the Schedule 1 definitions and the Central Bank carve-outs in the VARA Regulations with them and their licensed advisers, then form the Dubai entity, plan the AED 500,000 minimum paid-up capital and VARA fees, and set up the group so any conversion leg runs through a separately licensed exchange as Rule II.E.1 requires. We keep corporate records, UBO filings and the AML framework aligned with the Travel Rule obligations. Polaris is not licensed by VARA and does not transfer or settle virtual assets.
| Cites | Dubai 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.
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 co…
VARA Company Rulebook
Compulsory rulebook for every VASP: company and ownership structure, Board, Responsible Individuals and senior management, fit and proper tests, outsourcing, ESG disclosu…
VARA Compliance and Risk Management Rulebook
Compulsory rulebook covering compliance management, regulatory reporting and notifications, tax reporting, AML/CFT controls including the MLRO, client due diligence, FATF…
VARA Market Conduct Rulebook
Compulsory rulebook on marketing, written client agreements, complaints handling, investor classification (retail, qualified and institutional), public disclosures, marke…
VARA Custody Services Rulebook
Activity rulebook for Custody Services: additional Board requirements, policies and disclosures, VA storage and custody rules, staking from custody services and collatera…
VARA Exchange Services Rulebook
Activity rulebook for Exchange Services: additional Board requirements, policies and disclosures, trading venue participants, market surveillance, trading systems continu…
Central Bank Law 2025
The current Central Bank statute, in force from 16 September 2025: it governs the Central Bank's objectives and governance, makes the Central Bank the licensing authority…
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