Yes, provided the structure complies with VARA requirements and aligns with applicable real estate ownership mechanics — including Dubai Land Department registration and SPV or direct ownership structures that support the token-holder interest. The legal framework for real estate tokenisation in Dubai is developing, with VARA providing the primary regulatory framework for tokenised instruments classified as Virtual Assets. Projects that are structured correctly — with proper ARVA classification, VARA licensing, and DLD integration — can launch compliantly in the Dubai market.

If you are facilitating transactions in Virtual Assets, you may require a VARA Broker-Dealer licence depending on your role. Distribution of tokenised real estate interests — whether through a platform, a distribution desk, or a network of introducing agents — typically constitutes a regulated VA Activity where the distributor is receiving orders, routing them, or standing between investors and execution. The specific licensing requirement depends on the nature of the distribution role: execution-only, non-advisory placement, or advisory-led distribution each have different licensing implications under VARA’s framework.

Misclassification. A poorly structured model may be treated by VARA as a security, fund interest, or unlicensed investment product — rather than the ARVA classification the project intends. VARA assesses classification on the basis of economic substance, not the labels applied in the documentation. A token that is described as an ARVA but functions economically as a collective investment scheme — through pooling, active management discretion, or investor profit-sharing — will be assessed on what it does, not what it is called. Misclassification creates immediate regulatory exposure and typically requires expensive restructuring.

Yes, but your broker-dealer model must preserve functional separation and avoid shadow issuer risk. Where a broker-dealer relies on a third party for token issuance, the contractual and operational arrangement must ensure that the broker-dealer does not exercise effective control over the token structure, pricing, or economic terms in a way that makes it the functional issuer. Shadow issuer risk arises where the role separation described in the contracts does not reflect the operational reality — and VARA assesses the substance of role separation, not just its contractual description.

A compliant model typically uses a transparent capital-stack methodology rather than speculative or yield-based pricing. The token price is derived from the acquisition cost, development cost, and transaction costs of the underlying property — underpinned by an independent property valuation — rather than from projected rental income, capital appreciation expectations, or any form of implied yield. Pricing that embeds investment return expectations, or that is set at a premium to the underlying asset value without transparent disclosure, creates reclassification risk and potential investor protection concerns.