VARA APPLICATION PROCEDURE, STAGES & DOCUMENTATION
Two stages, one standard: Initial Disclosure → Approval to Incorporate (ATI) → full Market Product (FMP) Licence, with a defined document pack across governance, risk & compliance, technology, and (where applicable) VA-specific annexes.
We prepare, quality-assure, and sequence your full submission: IDQ, ATI pack, licence documents, interviews, fee timing, and any conditions to go-live.
WHO MUST APPLY
Any firm intending to carry out Virtual Asset (VA) Activities in or from Dubai (excluding DIFC) must be licensed by VARA before commencing operations. Submissions can be made via Dubai Economy & Tourism (DET) for the mainland or via a Dubai Free Zone (FZ) for free-zone entities.
THE TWO-STAGE PROCESS
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Submit an Initial Disclosure Questionnaire (IDQ) to DET or your chosen Free Zone. |
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Provide additional disclosures on owners, senior management, and the business plan as requested. |
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Pay the initial application fee (commonly ~50% of the licence application fee to begin the review). |
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Pay the initial application fee (commonly ~50% of the licence application fee to begin the review). |
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Receive ATI to incorporate, hire, and set up operations (office, core staff, systems). |
Important: You are not yet permitted to conduct VA activities at ATI. VARA may decline to issue ATI if the firm is outside the regulatory perimeter or below required standards.
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Prepare and submit the full documentation set per VARA’s guidance issued with ATI. |
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Engage with VARA feedback (meetings, interviews, clarifications, and any supplemental evidence). |
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Pay the remaining application licence fees and your first year’s supervision fee(s). |
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Receive the VASP Licence: it may include operational conditions you must satisfy before or after go-live. |
EXISTING FIRMS (LEGACY VA OPERATORS) — TRANSITIONAL PATHWAY
- VARA has provided a Legacy Operating Permit (LOP) / No-Objection Certificate (NOC) route for firms active prior to Feb-2023, initiated via the Initial Disclosure Questionnaire (IDQ) and Application Acknowledgment Notice (AAN).
- The LOP is typically 12 months, designed to smooth transition to the full regime with discounted fees and reduced capital where applicable — provided baseline requirements are met.
- Missed AAN? VARA advises immediate LOP application to avoid potential disciplinary outcomes.
WHAT YOU MUST FILE — DOCUMENTATION BY CATEGORY
A. Corporate Structure & Governance
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Certificate of incorporation |
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UBO list (ultimate beneficial owners) |
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Fit & Proper confirmations (key persons) |
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Source of funds evidence |
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Organisational structure (Governance map) |
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Governance framework (Board/committees/charters) |
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Local entity website (regulatory imprint) |
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Key personnel: job descriptions, CVs, passport copies |
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Regulatory Business Plan (RBP) |
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Financial projections |
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Group-level & entity-level financial statements |
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Proof of paid-up capital |
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Available capital locked-up (where required) |
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Reserve account report |
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Insurance certificates |
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Succession plan |
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Wind-down plan |
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Close links / associated entities analysis |
B. Risk & Compliance
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Enterprise Risk Management (ERM) framework & methodology |
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Latest enterprise risk assessment |
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Trades execution & settlement policy (where applicable) |
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Compliance manual |
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Compliance monitoring programme (testing calendar) |
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Group compliance breaches register (if any) |
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AML/CFT policy & procedures |
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Current AML/CFT programme status (metrics, tooling) |
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Anti-Bribery & Corruption (ABC) policy & procedures |
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Outsourcing policy |
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Executed outsourcing agreements (material/non-material) |
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Conflicts of interest policy & register |
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Insider lists (template / live register) |
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Customer journey workflows (onboarding, disclosures, exits) |
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Terms & Conditions / client Agreements |
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Privacy policy |
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Marketing policy & plan |
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Sample marketing materials (compliant risk lines/labels) |
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New product approval policy |
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Market conduct policy |
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VA listing policy (where applicable) |
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VA assets analysis (due-diligence criteria) |
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Records management policy |
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Funds managed (Asset Managers only) |
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Assets exposure (Asset Managers only) |
C. Technology (T&I Rulebook alignment)
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Technology infrastructure design (target architecture) |
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Technology risk assessment framework & methodology |
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Business Continuity & IT Disaster Recovery Plan (BCDR) |
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Key & wallet management policy (if applicable) |
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UAE public keys & wallet addresses (for certain activities) |
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Information security policy (CISO-owned) |
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Penetration test results / attestation (and smart-contract audits, as relevant) |
D. Other (activity-specific)
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Virtual Asset whitepaper (where required for issuance or listings) |
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Proprietary trading supporting information (certain activities) |
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DeFi activities supporting information (where applicable) |
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VA payments supporting information (where applicable) |
THE RULEBOOKS YOU MUST MEET
All applicants must comply with the four Compulsory Rulebooks:
Company Rulebook
Company Rulebook (governance, prudentials, material change, wind-down)
Amounts
Compliance & Risk Management (CMS/CO, AML/CFT, Client Money/VAs, AB&C, Sponsored VASPs)
Update bands
Technology & Information (CISO, cyber, BCDR, keys/wallets, TLPT, privacy, confidentiality)
Update bands
Market Conduct (marketing linkage, client agreements, complaints, investor classes, public disclosures, transparency, own-account trading, VA standards)
Plus, comply with the activity-specific rulebooks for the licence(s) you seek (Advisory, Broker-Dealer, Custody, Exchange, Lending & Borrowing, VMIS, Transfer & Settlement, VA Issuance Category-1).
FEES, CAPITAL & SUPERVISION (AT A GLANCE)
- Application & Extension Fees due at submission; Annual Supervision Fees payable in advance per activity.
- Paid-Up Capital and Net Liquid Assets must meet Company Rulebook thresholds; Reserves = 100% of Client VAs (same asset), with periodic audits.
See the page on Supervision & Authorisation Fees, Capital Requirements Under VARA.
What CRYPTOVERSE Legal delivers
Preparation & sequencing
Preparation & sequencing: IDQ and ATI packs; interview prep; Q&A responses.
Document drafting
Document drafting: RBP, policies (AML/CFT, ABC, Market Conduct, privacy), T&I artefacts (CISO policies, BCDR, key/wallet controls), client agreements.
Evidence & testing
Evidence & testing: compliance monitoring calendar, VA/PT & smart-contract audits, PoR and reconciliations, disclosure web copy.
Fee & capital modelling
Fee & capital modelling: Application/Extension/Annual supervision, PUC/NLA/Reserves mapping.
Go-live conditions
Go-live conditions: remediation trackers, attestations, and board MI to close licence conditions quickly.
FAQs
Yes. ATI is the gateway to formal incorporation and operational setup; the full licence submission follows.
No. You may not conduct VA activities until VARA issues the VASP Licence (and any conditions are satisfied).
Yes. The Legacy Operating Permit/NOC pathway supports firms active before Feb-2023 to transition with time-bound conditions.
No. Some items (e.g., whitepaper, DeFi/payment annexes, wallet address lists) are activity-specific. We tailor your pack accordingly.