DFSA Fees for Crypto Businesses in the DIFC

Why fees matter before you write a single line of code

Whether you’re launching a crypto exchange, custody platform, tokenised securities venue, or an advisory/asset-management proposition in the Dubai International Financial Centre (DIFC), the DFSA’s fee schedule is part of the business model. Application fees affect runway and sequencing; annual fees scale with authorisations and – if you run an ATS for Crypto Tokens – even with trading volume. Miss a deadline and late charges accrue automatically. Plan for fees as deliberately as you plan for engineering sprints.

This guide unpacks the fee “stack” that crypto operators encounter in the DIFC, from initial licensing to token recognition and ongoing obligations.

1) Paying fees: currency, method, and the cost of being late

• Currency & method. Fees under FER must be paid in USD by bank transfer to the DFSA’s account.
• Late payments. If you miss the due date, the DFSA levies the greater of USD 1,000 or 3% of the fee due, plus 1% for each calendar month (or part) outstanding, without limiting any other regulatory action it may take.

Operational tip: Bake FER due dates into your treasury calendar and set dual approvals for wire transfers.

2) Initial licence application fees (what it costs to get authorised)

When you file for a DFSA Licence, you pay the highest base fee associated with the Financial Services you’re applying for, plus certain add-ons where relevant. Representative extract (not exhaustive):

• Dealing in Investments as Principal: USD 40,000
• Dealing in Investments as Agent: USD 25,000
• Providing Custody: USD 25,000
• Managing Assets: USD 25,000
• Providing Money Services (if it issues Stored Value): USD 25,000
• Arranging Deals / Advising on Financial Products / Arranging Custody / Arranging Credit & Advising on Credit: USD 15,000 each.

ATS and Exchange extras at application

• Operating an ATS that will trade Security Tokens not admitted to an AMI/other Regulated Exchange or Crypto Tokens: USD 150,000; USD 65,000 in other cases. If the ATS will trade Investment Tokens or Crypto Tokens and have Direct Access Members, add USD 10,000.
  
• Operating an Exchange (AMI) or Operating a Clearing House when applying as an AMI: USD 150,000 for each authorisation; additional USD 150,000 if you also seek the endorsement to maintain an Official List of Securities.

Retail, client assets, and other endorsements at application

Common endorsements that crypto business models frequently need:

• Retail Client endorsement: USD 20,000
• Holding or controlling Client Assets: USD 5,000
• Trade Repository: USD 15,000
• Use of a Fund Platform: USD 20,000.

3) Varying your licence to add Crypto Tokens later (the “upgrade” path)

Already licensed but want to add Crypto Tokens to your permission set? The DFSA charges a specific variation fee keyed to the underlying Financial Service you are extending to cover Crypto Tokens:

• Operate a Clearing House or ATS: USD 40,000
• Deal as Principal or Provide Custody: USD 20,000
• Deal as Agent, Manage Assets, or Manage a CIS: USD 10,000
• Advise on Financial Products or Arrange Deals in Investments: USD 5,000.

If you are changing the scope of your Licence and no specific fee applies, the default scope change fee is USD 10,000 (USD 500 if you’re only removing an authorisation/endorsement/product).

Design choice: Some firms defer Crypto Token permissions to a second phase to manage initial costs and programme risk; the variation tariff above gives you the cash impact of that decision.

4) Recognised Crypto Tokens: application, transfer, and removal fees

In the DFSA regime, a Recognised Crypto Token is one on the DFSA’s Initial List or recognised on application (GEN 3A). The Fees Module sets the following token-specific charges:

• Application to recognise a Crypto Token: USD 5,000 per token.
• Transfer of a recognition to another token (e.g., due to protocol migration): USD 2,000.
• Removal of a recognition: USD 1,000.

Why it matters: If your product suite depends on multiple base-layer or stablecoin rails, budget for recognition fees (and the operational work to maintain recognition status).

5) Annual fees for Authorised Firms (including crypto-specific uplifts)

Once authorised, Authorised Firms pay an annual fee that combines:

• a base component driven by the Financial Service(s) on your Licence, and
• additional components where the Licence relates to Crypto Tokens (notably for ATS).

The big one: ATSs that trade Crypto Tokens

If your Licence covers Operating an ATS that trades Crypto Tokens, your annual fee is tiered to average daily trading volume (ADTV) in the previous calendar year (measured through end-November):

• ADTV < USD 50m: USD 150,000
• USD 50m ≤ ADTV < USD 100m: USD 300,000
• USD 100m ≤ ADTV < USD 200m: USD 500,000
• ADTV ≥ USD 200m: USD 800,000.

ADTV is calculated as total trading value through end-November divided by trading days through end-November.

Where the ATS has Direct Access Members (and trades Investment Tokens or Crypto Tokens), add USD 10,000 to the annual fee.

AMIs (Exchanges) operating for Crypto Tokens

An Authorised Market Institution that operates an Exchange for Crypto Tokens pays the crypto-specific annual fee under the relevant AMI provisions (instead of the standard USD 100,000 for non-crypto Exchanges).

Structural note: Under GEN, an OTF cannot be operated for Crypto Tokens; a crypto trading venue in the DIFC must be an MTF-style ATS or an Exchange. This shapes both your permission architecture and your fee exposure.

6) Filing fees for Security Token offers on an ATS

If you are filing a Prospectus/other document with the DFSA, standard filing fees apply by document type (e.g., USD 35,000 for an equity Prospectus, USD 10,000 for non-equity).

Crypto-specific add-on: If the Prospectus/other document relates to Security Tokens that are to be admitted to trading on an ATS and are not already admitted on an AMI or other Regulated Exchange, you must pay an additional USD 2,500.

Supplementary complexity fee: The DFSA may levy a supplementary fee if approval is likely to cause substantial additional costs (e.g., due to complexity), typically discussed with the issuer upfront pursuant to FER 1.2.7.

7) Real-world budgeting scenarios

Scenario A – Agency broker + custody for Crypto Tokens (professional clients only)

• Base application fees: Dealing as Agent (USD 25k) + Providing Custody (USD 25k).
• If you add Crypto Tokens from day one via scope design, no variation fee. If you phase it, the variation to include Crypto Tokens later costs USD 10k (Agent) + USD 20k (Custody).
• Retail add-on (if pursuing retail at launch or later): USD 20k endorsement fee (application) or per FER 2.2.5 when sought post-authorisation.

Scenario B – Crypto ATS (MTF) with Direct Access Members

• Application: Operating an ATS for Crypto Tokens = USD 150k, plus USD 10k for Direct Access Members.
• Annual: Tiered by ADTV (USD 150k → USD 800k), plus USD 10k for Direct Access Members.
• If you started with a non-crypto ATS and later, add Crypto Tokens, variation fee = USD 40k.

Scenario C – Tokenised securities issuance on an ATS

• Filing a Prospectus for Security Tokens to be admitted on an ATS (not already admitted on an AMI/Regulated Exchange): standard filing fee (per document type) + USD 2,500 crypto add-on.

Scenario D – Multi-token product suite

• Each Recognised Crypto Token you need that’s not on the Initial List: USD 5,000 per recognition; USD 2,000 to transfer recognition; USD 1,000 to remove recognition.

8) Governance and conduct overlays (why fees are not your only gate)

Although this article focuses on money, your licence and fee profile sit atop GEN/COB obligations that are especially relevant to crypto:

• Crypto Token perimeter & recognition. GEN chapter 3A defines key terms (e.g., “Recognised Crypto Token”, “Privacy Token”, “Algorithmic Token”) and confirms that general prohibitions (Regulatory Law Article 41B) and financial promotions rules apply to Crypto Tokens. That perimeter analysis determines whether you even need recognition and which conduct rules fire.
  
• ATS structure. As noted, OTFs cannot be operated for Crypto Tokens – crypto venues in the DIFC are MTFs (ATS) or Exchanges, and the choice affects your authorisations and fee exposure.
  
• Retail Client endorsement standards. If you pursue retail, GEN prescribes additional systems and controls expected when dealing with Retail Clients (and more exacting expectations where “Restricted Speculative Investments” are involved). Factor both the USD 20,000 endorsement fee and the operational uplift into your plan.

9) Managing fee risk: three planning moves we recommend

1. Sequence your permissions. If go-to-market relies first on institutional flows, launch with professional-only permissions and add Retail later once product-market-fit warrants the extra USD 20,000 endorsement and compliance infrastructure.
   
2. Model ATS volumes conservatively. The jump from USD 150k to USD 800k in annual ATS fees as ADTV increases is material. Tie your fee forecast to realistic order-book depth and market-maker SLAs, not optimistic pitch-deck curves.
   
3. Operationalise token recognition. Treat Recognised Crypto Token applications as their own workstream (technical due diligence, legal memo, risk analysis) and budget the USD 5,000 fee and potential transfers/removals across your supported assets.

10) What happens if you get timing wrong?

Besides late-fee accruals (the greater of USD 1,000 or 3%, plus 1% per month), non-payment is a Rule breach and the DFSA may escalate (including steps to withdraw authorisation/recognition). This is not just an accounting nuisance; it can become a strategic risk quickly.

11) Quick checklist (crypto-focused)

• Are you operating an ATS or Exchange for Crypto Tokens? If yes, budget application and annual fees keyed to crypto trading and ADTV tiers, plus USD 10,000 if you will have Direct Access Members.
• Do you require token recognition? Plan for USD 5,000 per token (with transfer/removal fees if your stack evolves).
• Is Retail in scope? Add USD 20,000 (endorsement) plus compliance uplift.
• Will you file a Security Token Prospectus for ATS admission? Add USD 2,500 to the document’s standard filing fee.
• Are you phasing Crypto Token permissions? If yes, include the variation fee (USD 40k / 20k / 10k / 5k by service) in your roadmap.

The DFSA’s fee architecture rewards clarity of scope and disciplined sequencing. The biggest “swing factors” for crypto operators are (i) whether you operate an ATS or Exchange for Crypto Tokens and at what volumes, (ii) how many Crypto Tokens you need recognised, and (iii) whether and when you go retail. Tie these decisions to a fee model you revisit quarterly and you’ll de-risk surprises before they hit your P&L.

Disclaimer: 

This summary is for information only, reflects FER/VER33/07-25 and related GEN provisions as cited, and is not a substitute for tailored legal advice. Always consult the DFSA Rulebook and engage counsel on your specific facts and permissions.

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