--- title: "Crypto Licence in Dubai (VARA)" url: "https://legal.ge/en/service/crypto-blockchain-services-en/crypto-licence-in-dubai-vara-en" field: "Crypto & Blockchain Services" description: "Crypto licence in Dubai (VARA): AED 40 000-100 000 application fees, AED 80 000-200 000 annual, two-stage process. Legal.ge." updated: "2026-10-15" publisher: "legal.ge" --- # Crypto Licence in Dubai (VARA) > Source: legal.ge, https://legal.ge/en/service/crypto-blockchain-services-en/crypto-licence-in-dubai-vara-en 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. ### What are VARA's fees? Per Schedule 2: Advisory and Transfer & Settlement — AED 40 000 application plus AED 80 000 annual; Broker-Dealer, Custody, Exchange, Lending, Management & Investment and Category 1 Issuance — AED 100 000 plus AED 200 000. ### Who regulates Dubai's crypto market? VARA — under Law No. (4) of 2022, over all activity "in or from Dubai", mainland and free zones; the DIFC is excluded (DFSA regime there). ### Can custody be bundled with other activities? No — Custody requires a distinct legal entity and a standalone licence; other activities bundle under one licence. Proprietary trading is an NoC matter entirely — via a separate company. ### Does a VARA licence remove NBG registration? No — Georgia-facing activity still requires National Bank registration under Article 52-5(2)–(3).