Dubai is the premium non-European destination for a crypto business: the Virtual Assets Regulatory Authority (VARA) operates under Law No. (4) of 2022, runs eight licensed activities and — what makes this page especially valuable — publishes its complete official fee table in AED, in Schedule 2 of its own rulebooks. Every amount here comes from that table.
A note on terminology discipline: the correct formulation is "a VARA licence plus a commercial licence from DET (mainland) or a Dubai free zone". Specific zone names (DMCC, DDA, DIC and others) are market practice, not an official licence type — this page mentions them only in that capacity. The DIFC is a separate regime (the DFSA) and is outside our scope here.
Jurisdiction and Law: "In or From Dubai"
Dubai Law No. (4) of 2022 designated VARA as the regulator for the virtual asset sector; its competence covers all virtual asset activity "in or from Dubai" — on the mainland and in the free zones alike. The DIFC stands outside that boundary: there, supervision belongs to the DFSA, a separate regulatory world. A licence is required before operating — including for serving global customers, where permissible. The current version of VARA's Virtual Assets and Related Activities Regulations has been effective since 19 June 2025.
Eight Activities and the Structural Rules
VARA's licensed-activities list: Advisory Services; Broker-Dealer Services; Custody Services; Exchange Services; Lending & Borrowing Services; Management & Investment Services; Transfer & Settlement Services; and VA Issuance Category 1. Two special categories sit alongside: Proprietary Trading is a No Objection Certificate (NoC via the commercial licensor), not a licence — and licensed VASPs cannot prop-trade: that requires a separate company; VA Issuance Category 2 follows the approval-plus-whitepaper route. Anonymity-enhanced tokens are prohibited.
The structural rules: several activities can bundle under one licence — except Custody, which requires a distinct legal entity and a standalone licence. Four compulsory rulebooks (Company; Compliance & Risk Management; Technology & Information; Market Conduct) bind every licensee, with activity-specific rulebooks on top. Capital requirements sit in Part IV of the Company Rulebook — confirm the amounts in VARA's current text before budgeting.
Fees in AED: the Official Schedule 2 Table
The Schedule 2 table divides into two rows:
- Advisory Services and Transfer & Settlement Services — licence application fee AED 40 000, annual supervision fee AED 80 000;
- Broker-Dealer, Custody, Exchange, Lending & Borrowing, Management & Investment, Category 1 Issuance — application fee AED 100 000, annual supervision fee AED 200 000.
The same schedule's side rules: extending a licence (adding an activity) costs 50% of the lower of the applicable application fees; supervision is paid per activity, in advance; VARA may adjust by risk profile and charge separately for issuer approvals and whitepapers. The Stage 1 (ATI) initial payment is "typically 50%" of the licence application fee, with the remainder plus the first year's supervision due at Stage 2. The arithmetic for a single Broker-Dealer licence: AED 100 000 + AED 200 000 — roughly AED 300 000 in year one, before free-zone or mainland setup costs. For pre-February-2023 operators there is a legacy track: a 12-month Legacy Operating Permit with a fee discount of up to 50% and reduced capital.
The Two-Stage Process and the Document Stack
Stage 1: the Initial Disclosure Questionnaire (IDQ) goes to Dubai Economy & Tourism (DET) for the mainland, or to the chosen Dubai free zone, with the business plan, UBO and senior-management details and the initial fees — the outcome is the Approval to Incorporate (ATI), under which no virtual asset activity may yet be conducted. Stage 2: full documentation per the post-ATI guidance, interviews and clarifications, and the remaining fees — the outcome is the VASP licence, possibly with conditions.
The document stack: certificate of incorporation, UBO list, fit-and-proper materials, source of funds, governance, the Regulatory Business Plan, financial projections and statements, proof of paid-up/locked capital and a reserve account, insurance, succession and wind-down plans, close-links analysis — and, on top, the risk, compliance and technology categories.
The Georgian Layer: What Applies at Home Despite a VARA Licence
A VARA licence is valid within Dubai and the UAE — it carries no European passport, and it rewrites no Georgian law. The organic law on the National Bank of Georgia (No 101044): Article 52-5(2) — a VASP registers with the National Bank; Article 52-5(3) — unregistered provision is impermissible; Article 52-5(4) — only the virtual asset service and auxiliary activity; Article 39-1 — a virtual asset is not legal tender; Article 48 — supervision belongs to the National Bank.
The AML law (No 4690334): Article 3(1) makes VASPs accountable persons; Article 4 assigns AML supervision to the National Bank; Article 11(1) sets the crypto KYC trigger at USD 1 000 / EUR 1 000 / GEL 3 000; Article 17¹ is the Travel Rule, its accompanying-information content defined by a National Bank act (Article 52-5(1) of the organic law). Dubai status does not exempt Georgia-facing activity from NBG registration.
Frequently Asked Questions
How much does a VARA licence cost?
Per Schedule 2: advisory and transfer/settlement activities — AED 40 000 plus AED 80 000 annually; the other six — AED 100 000 plus AED 200 000. A single Broker-Dealer licence's first year is therefore roughly AED 300 000 on those two lines, before company setup costs.
Can proprietary trading be bundled with the licence?
No — Proprietary Trading is the subject of a No Objection Certificate and needs a separate company; a licensed VASP cannot prop-trade.
Does this route work for the DIFC?
No — the DIFC sits outside VARA's competence: the regulator there is the DFSA under a separate rulebook. The VARA route covers the mainland (via DET) and Dubai's free zones.
Does a VARA licence change Georgian requirements?
No — Georgia-facing services still require National Bank registration under Article 52-5(2); the USD 1 000 / EUR 1 000 / GEL 3 000 KYC trigger and the Travel Rule remain part of the Georgian layer.
How We Help on Legal.ge
Legal.ge starts the Dubai route from the Schedule 2 table: we fix your activity set and compute the exact AED budget (application + annual + the "typically 50%" ATI initial payment), then file the IDQ with DET or the chosen free zone, build the company, and carry the full document stack from ATI to VASP licence — with the custody-standalone rule and the NoC boundary priced in. In parallel we build the Georgian ring — National Bank registration and AML compliance — because Dubai status opens no Georgian market. Contact us to start the Dubai route from your activity list.