Establishing a Virtual Asset Service Provider (VASP) in Dubai in 2026

1. Regulated Virtual Asset Activities

Businesses engaging in virtual asset-related activities within or from the Emirate of Dubai are required to apply for and maintain a license under VARA. This licensing obligation applies equally to existing operations and to entities planning to enter the market. VARA has defined a clear regulatory perimeter, setting out a comprehensive list of activities that fall under its supervision. Each activity is subject to specific compliance requirements to ensure transparency, consumer protection, and responsible innovation in the virtual asset ecosystem. 

Any VASP or traditional economy entity seeking to offer regulated virtual asset activities must apply for and receive a licence from VARA before beginning operations in or from the Emirate of Dubai. This applies whether the services are offered to customers located in Dubai or to global customers, where such activity is permissible. 

The regulated activities include:

• Advisory Services
  • Offering, providing, or agreeing to provide a personal recommendation to a client, either upon its request or on the initiative of the entity providing the recommendation, in respect of one or more actions or transactions relating to any virtual assets.
• Broker-Dealer Services
  • Arranging orders for the purchase and sale of virtual assets between two entities.
  • Soliciting or accepting orders for virtual assets and accepting fiat currency, or other virtual assets for such orders.
  • Facilitating the matching of transactions in virtual assets between buyers and sellers.
  • Entering into virtual asset transactions as a dealer on behalf of the entity for its own account.
  • Making a market in virtual assets using client assets.
  • Providing placement, distribution or other issuance-related services to clients issuing virtual assets.
• Category 1 Virtual Asset Licence
  • VARA’S current framework recognises Category 1 VA Issuance as a regulated virtual activity. No entity in the Emirate may carry out Category 1 VA issuance unless it is authorised and licensed by VARA for that issuance.
  • This may include certain forms of virtual asset issuance that require VARA approval and licensing under the VA Issuance Rulebook, including issuances subject to additional whitepaper, disclosure, reserve, governance, and supervision requirements.
• Custody Services
  • Safekeeping virtual assets for or on behalf of another entity and acting only on verified instructions from or on behalf of such entity.
• Exchange Services
  • Conducting an exchange, trade or conversion between virtual assets and fiat currency.
  • Conducting an exchange, trade or conversion between one or more virtual assets.
  • Matching orders between buyers and sellers and conducting an exchange, trade or conversion between:
    • virtual assets and fiat currency, or
    • one or more virtual assets.
  • Maintaining an order book in furtherance of the above-mentioned exchange services.
• Lending and Borrowing Services
  • Carrying out a contract under which a virtual asset shall be transferred or lent from one or more parties, the lenders, to one or more other parties, the borrowers, where the borrowers shall commit to return the same, at the request of the lenders, at any time during or at the end of the period agreed upon.
• Virtual Asset Management and Investment Services
  • Acting on behalf of an entity as an agent, fiduciary, or otherwise taking responsibility for the management, administration, or disposition of that entity’s virtual assets.
• Virtual Asset Transfer and Settlement Services
  • The transmission or transfer, and/or settlement of virtual assets from one entity to another entity or from another entity to another virtual asset wallet, address, or location.

VARA reserves the authority to issue a license permitting a VASP to engage in one or multiple virtual asset activities that align with the licensing application details provided.

VASPs licensed to undertake multiple activities must meet the requirements for each licensed activity in full and maintain ongoing compliance at all times.

2. Regulatory fees, licence extension and capital requirements

To secure a VASP license from VARA, applicants must pay a licensing application fee, which becomes payable upon submitting the application. If the applicant seeks approval to conduct multiple virtual asset activities, a separate license extension fee applies for each additional activity included in the application. 

In addition to the initial application and extension fees, all licensed VASPs are obligated to pay an annual supervision fee to VARA. This supervisory fee is charged per licensed activity and supports the ongoing regulatory oversight of each service offered under the license: 

*In all cases the license extension fee is 50% of lower license application fee 

VARA may also impose additional supervision fees or other fees depending on the risk profile of the VASP, including the nature, scale and complexity of the business, market share, client base, compliance history and the level of regulatory oversight required.

Where a VASP is licensed to conduct multiple virtual asset activities, it must uphold the designated amount of paid-up capital for each of the activities authorised to provide:

Separate registration and renewal fees are applicable for establishing and maintaining a legal entity in the mainland or within one of Dubai’s free zones, excluding the Dubai International Financial Centre (DIFC).

Contact us at info@salvusfunds.com if you are interested in establishing a VASP in Dubai under VARA or engaging in virtual asset activities in the United Arab Emirates.

3. The VARA two-stage application procedure

The overall timeline for completing the VASP licensing process, from the initial engagement with VARA to the commencement of business operations, depends heavily on the nature of the virtual asset activities and products selected by the applicant. Factors such as the complexity of the intended business model and the applicant’s preparedness to meet VARA’s regulatory expectations play a critical role in determining how quickly the process moves forward.

For 2026, applicants should note that VARA’s VASP licensing process is completed in two key stages:

Stage 1: Approval to Incorporate / Approval to Establish

The first stage involves applying for an Approval to Incorporate, also referred to as ATI. This allows the applicant to establish the legal entity and begin operational setup. At this stage, applicants typically submit an Initial Disclosure Questionnaire, business plan, ownership and beneficial ownership information, senior management details, and other initial documents through DET or the relevant Free Zone Authority.

The applicant will also generally be required to pay an initial portion of the application fee. However, receiving an Approval to Incorporate does not allow the applicant to conduct virtual asset activities or service clients.

Stage 2: Full VASP Licence

The second stage involves submitting the full VASP license application to VARA. This includes detailed compliance, governance, technology, risk management, AML/CFT, financial, operational and business documentation. VARA may request additional information, hold meetings or interviews, and require revisions before granting the licence.

Only after receiving the full VASP License may the applicant commence regulated virtual asset activities in or from Dubai.

4. Important Restriction: No Operations before Full Licensing

An In-Principle Approval, Approval to Incorporate, or similar conditional approval is not a licence to operate. Applicants holding an IPA are strictly prohibited from initiating operations, conducting any virtual asset activities, or servicing clients until they have obtained their full VASP licence from VARA.

This point is especially important for applicants preparing marketing materials, onboarding clients, launching platforms, raising funds, or entering into commercial arrangements before the full licence is issued.

5. How SALVUS can assist your VARA application

The Crypto Assets Licensing team at SALVUS is composed of industry experts with deep experience in fintech project structuring and regulatory licensing. Leveraging strong project management capabilities, we guide you in identifying the most suitable virtual asset activities that align with your business goals and operational model. 

We coordinate directly with regulatory bodies on your behalf and work closely with your internal team to compile and submit all necessary documentation for a complete and compliant application. Our core aim is to help you meet VARA’s regulatory standards while ensuring optimal use of your time and financial resources. 

Contact us at info@salvusfunds.com if you are interested in establishing a VASP in Dubai under VARA or engaging in virtual asset activities in the United Arab Emirates.

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The information provided in this article is for general information purposes only. You should always seek professional advice suitable to your needs.