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How A2CO Supports VARA Licence Applications
A2CO supports crypto businesses with the practical work needed before and during a VARA licence application. Our work is designed to help applicants understand the regulatory perimeter, organise the required information, and prepare a clearer application file.
Our support may include:
- Reviewing the proposed business model against VARA’s regulated VA activities
- Supporting the Initial Disclosure Questionnaire process and related information gathering
- Supporting the preparation of application documentation and responses to regulatory information requests
- Reviewing governance, risk and compliance policies
- Supporting AML and CFT procedure preparation
- Reviewing documentation linked to VARA’s Technology and Information Rulebook
- Supporting fit and proper documentation for beneficial owners, directors, senior management and key personnel
- Assisting token issuers with whitepaper planning and issuance requirement reviews, based on the proposed token structure
- Reviewing marketing materials against VARA related requirements
- Supporting post licencing compliance planning
A2CO’s role is practical, commercial and compliance focused. We help clients prepare, structure and review the materials needed for the VARA process, while working with legal advisers where legal advice or formal legal representation is required.
What Is VARA?
VARA is Dubai’s Virtual Assets Regulatory Authority. It regulates and oversees the provision, use and exchange of virtual assets in and from the Emirate of Dubai. VARA is the sole authority for virtual assets across Dubai’s mainland and free zones, except within the Dubai International Financial Centre.
Crypto businesses that carry out virtual asset activities in or from Dubai may need a VARA licence before they begin operating.when a This includes firms based in Dubai as well as overseas firms that provide regulated virtual asset services from Dubai.
A2CO helps businesses assess whether their activities fall within VARA’s framework and supports them with licence application preparation, regulatory documentation and compliance planning.
VARA Licence Application Process
Stage 1: Initial Disclosure Questionnaire and Approval to Incorporate
New firms applying for a VARA VASP licence follow a two-stage process. The first stage is the application for Approval to Incorporate, known as ATI. The applicant submits an Initial Disclosure Questionnaire through Dubai Economy and Tourism or the relevant Dubai free zone. VARA may also request additional documents, including a business plan and details of beneficial owners and senior management.
If VARA is satisfied at this stage, it may issue an ATI. This allows the applicant to finalise legal incorporation and continue operational setup. It does not allow the firm to carry out virtual asset activities yet.
Stage 2: Full VASP Licence Application
After receiving ATI, the firm may apply for a full VASP licence. At this stage, the applicant prepares and submits the documentation requested by VARA. VARA may provide feedback, request further information, hold meetings or interviews, and require additional submissions before reaching a decision.
VARA may grant a VASP licence once the application has been reviewed. The licence may be subject to operational conditions. VARA may also refuse a licence where the proposed activities fall outside its regulatory perimeter or where the applicant does not meet the required standards.
Stage 1: Initial Disclosure Questionnaire and Approval to Incorporate
New firms applying for a VARA VASP licence follow a two-stage process. The first stage is the application for Approval to Incorporate, known as ATI. The applicant submits an Initial Disclosure Questionnaire through Dubai Economy and Tourism or the relevant Dubai free zone. VARA may also request additional documents, including a business plan and details of beneficial owners and senior management.
If VARA is satisfied at this stage, it may issue an ATI. This allows the applicant to finalise legal incorporation and continue operational setup. It does not allow the firm to carry out virtual asset activities yet.
Stage 2: Full VASP Licence Application
After receiving ATI, the firm may apply for a full VASP licence. At this stage, the applicant prepares and submits the documentation requested by VARA. VARA may provide feedback, request further information, hold meetings or interviews, and require additional submissions before reaching a decision.
VARA may grant a VASP licence once the application has been reviewed. The licence may be subject to operational conditions. VARA may also refuse a licence where the proposed activities fall outside its regulatory perimeter or where the applicant does not meet the required standards.
VARA Regulated Activities
VARA identifies 8 regulated VA activities. Each activity is treated as a discrete licence category and must be applied for explicitly.
A VASP may apply for more than one activity under a single overarching VARA licence, except where specific requirements apply. Custody Services are treated differently. VARA states that, under the current list of activities, Virtual Asset Custody Services must be segregated from other Virtual Asset Services licence categories. A VA Custodian must be established as a distinct legal entity and hold a standalone licence.
The 8 VARA regulated activities are:
- Advisory Services
- Broker Dealer Services
- Custody Services
- Exchange Services
- Lending and Borrowing Services
- Management and Investment Services
- Transfer and Settlement Services
- VA Issuance Category 1
Any entity that carries out one or more of these regulated VA activities in or from Dubai, excluding the DIFC, must hold the appropriate VARA authorisation before starting those activities. This applies whether the entity is a crypto native business or a traditional business entering the virtual assets sector.
VARA Requirements for Token Issuers
VARA treats virtual asset issuance differently depending on the type of Virtual Asset being issued and the structure of the issuance.
Category 1 VA Issuance is one of the 8 VA activities identified by VARA. It applies to the issuance of Fiat Referenced Virtual Assets, Asset Referenced Virtual Assets, and any other Virtual Assets that VARA may determine from time to time. An entity carrying out Category 1 VA Issuance in the Emirate must be licensed by VARA.
Other issuances may fall under Category 2. Under the current VARA VA Issuance Rulebook, Category 2 covers the issuance of a Virtual Asset that is not a Category 1 VA Issuance and is not an Exempt VA. A VARA licence is not required for Category 2 issuance, but all placement or distribution must be carried out through or by a Licensed Distributor.
The Licensed Distributor is responsible for assuring and validating that the issuer complies with the VA Issuance Rulebook. VARA also states that Category 2 Virtual Assets are not deemed to be approved by VARA and must not be presented as such.
Issuers should also consider the wider requirements in the VA Issuance Rulebook. These may include whitepaper and public disclosure requirements, risk disclosure requirements, AML and CFT controls, technical and information security controls, and restrictions on prohibited Virtual Assets.
A2CO can support token issuers with an initial review of the proposed token structure, the likely VARA category, whitepaper planning, documentation requirements, and compliance points before the project moves into licencing, distribution, or regulatory engagement.
Marketing Virtual Assets Under VARA
VARA sets out strict requirements for marketing virtual assets in or targeting UAE to ensure transparency, fairness, and investor protection. All promotional content must be clear, accurate, and not misleading, with prominent risk disclosures highlighting volatility, potential loss of capital, and lack of financial safeguards.
Aggressive or deceptive tactics such as implying guaranteed returns, creating urgency, or trivialising investment decisions are prohibited, and marketing must always be tailored to the appropriate investor audience.
Entities remain fully accountable for their marketing activities, including those conducted through third-party agencies, and are required to maintain records of all materials for at least 8 years, underscoring VARA’s focus on responsible promotion and consumer trust.
Why Work With A2CO
VARA applications require more than a basic form submission. Applicants need to understand the regulated activity, prepare supporting documents and show that their governance, compliance and operational setup can meet regulatory expectations.
A2CO brings together regulatory, compliance, corporate and financial experience to support crypto businesses preparing for VARA engagement. Our team helps clients organise the information, policies and documentation needed for a more structured application process.
Frequently Asked Questions
VARA is Dubai’s Virtual Assets Regulatory Authority. It regulates and oversees the provision, use and exchange of virtual assets in and from the Emirate of Dubai, excluding the DIFC. Its framework covers licensing, supervision, rulebooks and regulatory requirements for virtual asset activities.
New applicants follow a two stage process. Stage 1 involves submitting an Initial Disclosure Questionnaire through Dubai Economy and Tourism or a relevant Dubai free zone, then seeking Approval to Incorporate. Stage 2 involves submitting the full VASP licence application and supporting documentation to VARA.
Any firm seeking to carry on virtual asset activities in or from Dubai, excluding DIFC, must be licensed by VARA before commencing operations. This may include exchanges, broker-dealers, custodians, transfer and settlement providers, management and investment providers, advisory providers, lending and borrowing providers, and certain token issuers.
It depends on the token and the issuance category. VARA lists VA Issuance Category 1 as a licensed activity. VARA also sets prior requirements for Category 2 issuances, including an approval form, a whitepaper and issuer details. A token issuer should review the proposed structure before issuing or distributing a virtual asset in or from Dubai.
Marketing, advertising and promotion of virtual assets are covered under VARA’s regulatory framework. Before promoting a virtual asset product, firms should check whether the activity, audience, message and distribution channel fall within VARA related requirements.
