Virtual Assets Issuance (Category 2) —Under VARA
Issue non-FRVA/ARVA tokens in Dubai without a VARA Licence—through a Licensed Distributor and with full Whitepaper & risk disclosures.
WHAT THIS ROUTE COVERS
Category 2 = VA issuances that are not (i) Category 1 (e.g., FRVAs/ARVAs or other types designated by VARA) and not (ii) an Exempt VA (e.g., non-transferable or redeemable closed-loop).
Note: Placement/distribution must be Done by a Licensed Distributor.
- No Licence required for the Issuer (if Part I.E conditions are met), but the Licensed Distributor assumes responsibility to assure and validate the Issuer’s compliance with the Rulebook.
- Prohibited VAs: Anonymity-Enhanced Cryptocurrencies are prohibited.
WHAT YOU CAN DO
UNDER CATEGORY 2 (WITH A LICENSED DISTRIBUTOR)
Primary sale or allocation
Primary sale or allocation of Category-2 tokens (e.g., access/utility/governance tokens that are not FRVA/ARVA/Exempt).
Airdrops/allowlists
Airdrops/allowlists and employee/community distributions conducted via, or by, the Licensed Distributor.
Secondary-market admission
Secondary-market admission via third-party venues subject to venue rules and your Whitepaper disclosures.
Ongoing updates
Ongoing updates to tokenomics/rights only after Whitepaper & Risk Statement are updated and notified.
If your token changes such that it now falls into Category 1 (e.g., becomes FRVA/ARVA) or no longer fits Category-2, you must meet the higher category’s requirements before the change takes effect.
MANDATORY DISCLOSURES
(APPLY TO ALL NON-EXEMPT ISSUERS)
|
Whitepaper |
Before any offer/marketing; keep historic versions and mark update dates; retain records ≥ 8 years after circulation ends. |
|
Risk Disclosure Statement |
(Clear, non-technical); keep current; retain ≥ 8 years. (III.C.1–3). |
|
Core content (Schedule 1) |
Covers: Issuer identity & fitness, project plan & milestones, issuance schedule & allocations, owners’ rights/obligations (transferability, redemption, insolvency, complaints), technology/DLT & environmental impact, Licensed Distributor details, and terms of any initial offer (targets, allocations, reimbursements). |
GENERAL RULES YOU MUST MEET
(EVEN FOR CATEGORY-2)
|
Integrity, diligence, resources, clear disclosures, legal compliance, environmental responsibility. |
|
Marketing in Dubai must comply with VARA Marketing Regulations. |
HOW
CRYPTOVERSE LEGAL HELPS
Category-2 scoping memo
Token mapping vs. Category 1/Exempt; “change-of-category” triggers.
Whitepaper & Risk Statement build
Clause-by-clause against Schedule 1 with versioning/retention controls.
Distributor engagement
Appoint/contract a Licensed Distributor; duties split; assurance evidence.
Market-conduct & marketing clearance
Dubai-compliant campaign assets and disclaimers.
Ongoing update governance
Change log, notice process, archival (8-year rule).
OUR PROCESS
(FAST & REGULATOR-READY)
Perimeter check
Category-2 confirmed; prohibited-VA screen.
Distributor selection
Mandate, SLA, assurance responsibilities.
Whitepaper & risks
Schedule-1 build; legal/tech/rights; complaints & dispute resolution.
Offer mechanics
Allocations, reimbursements, secondary admission notes.
Marketing clearance
VARA Marketing Regs mapping; artifact archive.
Go-live pack
Disclosures online; evidence binder; update notice scripts.
FAQs
No, provided all placement/distribution is through/by a Licensed Distributor.
The Issuer must meet Part II and Part III (whitepaper/risks); the Licensed Distributor must assure/validate issuer compliance while distributing.
Yes, but update the Whitepaper/Risk Statement and, if the change shifts category, meet higher-category requirements before the change.
No—issuing AECs and all related VA Activities are prohibited in Dubai.