VARA licence cost, capital and timeline in Dubai, 2026

As at 6 October 2026, a VARA licence in Dubai costs AED 40,000 to AED 100,000 in application fees for the first activity, 50% of the lower application fee per additional activity, and AED 80,000 to AED 200,000 a year in supervision fees per activity, under Schedule 2 of the Regulations 2023. Company Rulebook paid-up capital runs from AED 100,000 for advisory to the higher of AED 1,500,000 or 25% of fixed annual overheads for an exchange without a VARA-licensed custodian. Licensing is two stages, with no published duration.

In rupees, at the FBIL reference rate of INR 26.2145 per dirham for 5 October 2026, as archived in the Reserve Bank of India reference rate archive (select AED and that date), the application fee is about Rs 10.5 lakh (AED 40,000) or Rs 26.2 lakh (AED 100,000), the annual supervision fee about Rs 21 lakh (AED 80,000) or Rs 52.4 lakh (AED 200,000) per activity, and paid-up capital from about Rs 26.2 lakh for advisory (AED 100,000) to about Rs 3.93 crore for an exchange without a VARA-licensed custodian (AED 1,500,000), before the overheads test. The Central Bank of the UAE’s exchange-rate table for the same day shows AED 0.038137 per rupee, which is INR 26.22. These are one day’s rates, rounded: price the remittance at the rate on the day the trust account is funded.

How long does it take? Two stages: an Approval to Incorporate, which lets you form the Dubai company but not trade, then the VASP licence application, with feedback rounds and interviews before the licence issues. VARA publishes no duration for either stage on its process page or its FAQ, both checked on 6 October 2026. The dated third-party estimates run from four to eight months end to end; they are set out stage by stage below, and they are not Infinilex figures.

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Fees and capital by activity

Table 1 · VARA fees and paid-up capital per activity, as at 6 October 2026
VA activity	Licence application fee	Annual supervision fee	Paid-up capital: higher of the AED floor or % of fixed annual overheads (Company Rulebook VI.B)	Structural note
Advisory Services	AED 40,000	AED 80,000	AED 100,000, flat	No private-office requirement in VARA’s FAQ; physical presence in Dubai still required
Broker-Dealer Services	AED 100,000	AED 200,000	AED 400,000 or 15% with a VARA-licensed custodian; otherwise AED 600,000 or 25%	Private office required
Custody Services	AED 100,000	AED 200,000	AED 600,000 or 25%	Separate legal entity, standalone licence
Exchange Services	AED 100,000	AED 200,000	AED 800,000 or 15% with a VARA-licensed custodian; otherwise AED 1,500,000 or 25%	Private office required
Lending and Borrowing Services	AED 100,000	AED 200,000	AED 500,000 or 25%	Private office required
VA Management and Investment Services	AED 100,000	AED 200,000	AED 280,000 or 15% with a VARA-licensed custodian; otherwise AED 500,000 or 25%	Private office required
VA Transfer and Settlement Services	AED 40,000	AED 80,000	AED 500,000 or 25%	Private office required
Category 1 VA Issuance	AED 100,000	AED 200,000	As specified in the VA Issuance Rulebook or its Annex	Category 2 issuance needs no licence and no prior VARA approval; a Licensed Distributor places it and files with VARA

Fees: Schedule 2 of the VARA Regulations 2023, consolidated version effective 19 June 2025. Capital: Company Rulebook, Part VI.B, version dated 2 June 2023. Extension fee per additional activity: 50% of the lower application fee. VARA’s fees are separate from the commercial licensor’s.

Application fee, extension fee and supervision fee: when each falls due

Schedule 2 sets three fees per activity: an application fee for one regulated activity, an extension fee for each additional activity, and an annual supervision fee for every activity licensed. The application fee is paid once and the extension fee for each addition; both are due at submission, and VARA does not process the application until it has them. The supervision fee is paid in advance of conducting each activity and again at each 12-month renewal, notified 90 days ahead.

The extension fee is a formula, not a figure. On Infinilex’s reading, an applicant filing for Exchange and Broker-Dealer Services together would pay AED 100,000 for the first activity and AED 50,000 for the second, then AED 200,000 a year in supervision fees for each: our arithmetic on the published formula, not a number in the schedule.

VARA’s process page splits the application fee across its two stages: typically 50% to start the review at the Approval to Incorporate stage, and the balance plus the first year’s supervision fee before the VASP Licence issues. Application fees are non-refundable under Regulation IV.B.4: if the application is denied or withdrawn, nothing comes back. VARA may also impose additional supervision fees, or modify its fees, on a VASP’s risk profile, business-model complexity and compliance history.

VARA paid-up capital requirements per activity, and whether the capital is locked

Rule VI.B.1 requires VASPs to hold paid-up capital at all times in the amounts set per activity: for every activity except advisory, the higher of a dirham floor or a percentage of fixed annual overheads; for broker-dealer, exchange and management and investment, both the floor and the percentage are lower where the firm uses a VARA-licensed custodian or an arrangement VARA approved during licensing. Advisory is the exception at a flat AED 100,000. A firm licensed for several activities holds the capital for each, calculated on that activity’s overheads alone, and reconciles it monthly.

Is the money locked? Rule VI.B.3 answers it: paid-up capital must at all times sit in a trust account with a UAE-licensed bank with VARA named as beneficiary, or in a surety bond from a UAE-authorised surety company with no end date and VARA as beneficiary, or in any other manner VARA specifies on grant. VARA’s application document list has a line for proof of paid-up capital and another for available capital locked up. It is not runway.

Rule VI.C adds net liquid assets, liquid assets in surplus over current liabilities, of at least 1.2 times monthly operating expenses, reconciled daily, reported monthly, and held only in cash, cash equivalents or VARA-approved USD or AED referencing virtual assets. Insurance and reserve assets sit alongside. Under Rule VI.F, a VASP that cannot maintain any of them must notify VARA immediately and update daily until fixed, and VARA may require additional capital based on the size, scope and complexity of the business.

The timeline: two stages and no published clock

VARA’s process page describes licensing for a new firm in two stages. Stage 1 is the Approval to Incorporate: the applicant submits an Initial Disclosure Questionnaire through the commercial licensor, Dubai Economy and Tourism for the mainland or a Dubai free zone other than the DIFC, with a business plan and ownership details, pays the initial fee, and receives the ATI, which lets it incorporate and set up but not carry on virtual asset activities. Stage 2 is the VASP Licence application: the documentation, feedback that may include meetings, interviews and further documents, payment of the remaining application fee and the first year’s supervision fee, and a licence that may carry operational conditions. Under Regulation IV.B.1, VARA may also grant a narrower or wider activity description than applied for, or a licence for a specified time only.

What VARA does not publish is how long either stage takes. There is no indicative duration on its process page or FAQ. The UAE VASP licensing checklist says what can be said: the licensing period takes months, and you keep runway for it before revenue. The variables that stretch it are in the requirements: preferably an LLC or free-zone company, and never a sole proprietorship; two Responsible Individuals, each a full-time employee, fit and proper, and a UAE resident or passport holder; a private office in Dubai for every activity other than Advisory; compliance with four compulsory rulebooks (Company; Compliance and Risk Management; Technology and Information; Market Conduct) plus one per activity; and an evidence list that runs from proof of paid-up capital, insurance certificates and a reserve account report to a regulatory business plan, a UBO list and a wind-down plan. File clean after a gap analysis rather than round-trip corrections; banking is often the slowest step of all.

Stage by stage: what VARA publishes, and what it does not

Table 2 · The VARA licensing path by stage, from VARA’s process page and FAQ, as at 6 October 2026
Stage	What happens	Money due	Duration VARA publishes
Before filing	Choose the activities you run and no more. Pick the legal form (an LLC or free-zone company, not a sole proprietorship) and the commercial licensor: Dubai Economy and Tourism for the mainland, or a Dubai free zone other than the DIFC. Where founders sit in India, settle the FEMA route for the capital before anything is wired.	Nothing to VARA. Licensor and adviser costs only.	None. VARA’s process has not started.
Stage 1: Approval to Incorporate	Initial Disclosure Questionnaire through the licensor, with the business plan, beneficial owners and senior management. VARA may refuse where the activity sits outside its perimeter. The ATI lets you incorporate and set up, not carry on virtual asset activity.	Typically 50% of the licence application fee, so AED 20,000 or AED 50,000 for a first activity on our arithmetic. Non-refundable.	None published.
Between the stages	Incorporate. Lease a private office for every activity other than Advisory. Hire two Responsible Individuals, each a full-time employee and a UAE resident or passport holder. Open the bank account. Fund the paid-up capital into a trust account or surety bond with VARA as beneficiary. Arrange insurance and the reserve account.	Office, salaries, licensor fees and the capital itself. Nothing further to VARA.	None. Banking is usually the slowest step.
Stage 2: VASP licence application	Submit the documentation to VARA’s guidance. Expect meetings, interviews and further requests. The licence may issue with operational conditions, and may be narrower, wider or time-limited (Regulation IV.B.1).	The balance of the application fee, the extension fee for each additional activity, and the first year’s supervision fee for every activity.	None published.
After grant	Operate within any conditions. Reconcile paid-up capital monthly and the net liquid asset test daily. Renew every 12 months, with the supervision fee notified 90 days ahead.	The supervision fee per activity each year; AED 500 per licence update; AED 10,000 to withdraw.	The 12-month supervision cycle with 90 days’ notice: the one clock VARA publishes.

Stages and fee split: VARA’s licence applications page; office and Responsible Individual rules: VARA’s FAQ; both checked on 6 October 2026 and neither states a timeframe. Capital holding: Company Rulebook VI.B.3. Fee timing: Schedule 2. Update and withdrawal fees: VARA’s fee clarification of 22 June 2023.

What others estimate, and why none of it is a promise

Two dated examples, quoted so the spread is visible. Gofaizen & Sherle’s crypto licence index, last updated 18 September 2026, says a crypto licence in Dubai “is issued within 6-8 months upon submission of a full set of documents”, while the same firm’s UAE page, updated 16 June 2026, gives project time frames of four to six months. Shuraa Business Setup’s Dubai crypto licence guide, updated 21 January 2026, says the process “typically takes 4 to 8 months” and that regulatory approval “usually takes four to six weeks” once the file is complete. These are those publishers’ estimates for Dubai crypto licences generally. They are not VARA’s figures and they are not Infinilex figures. Infinilex quotes no duration, because the variables that decide it are yours: how clean the file is at submission, how soon two Responsible Individuals are in seat, and how long the bank takes.

The smaller fees founders forget

VARA’s fee clarification of 22 June 2023 added figures that are not in Schedule 2: a licence update fee of AED 500 per request, a withdrawal fee of AED 10,000, a proprietary-trader no-objection certificate at AED 1,000 a year, whitepaper review at AED 5,000 plus up to AED 50,000, and perimeter confirmation at up to AED 4,000, all as at that date and set out in the FAQ below.

Three structural rules on VARA’s licensed activities page matter more than any single fee. A VASP can hold multiple activities under one licence, except custody, which must be a separate entity with a standalone licence. A licensed VASP may not trade its own book under its activity licence: proprietary trading needs a separate company and a VARA no-objection certificate. And a VASP licensed for several activities must meet the requirements for each in full, so apply for exactly the activities you run: over-scoping raises capital and compliance cost at every line. To see which activities current licensees actually hold, read the VARA register explained.

What this means for an India-linked founder

VARA is the sole virtual asset regulator across Dubai’s mainland and free zones outside the DIFC, and it licenses Dubai legal entities, so a foreign company needs one before it can apply. That is why getting a VARA licence is a structuring exercise first and an application second. Where the founders sit in India, the money that capitalises the Dubai entity is an outbound investment under FEMA, and the ODI route (and whether an individual can use LRS at all for a regulated entity) has to be settled before the trust account is funded; ODI and LRS compliance is that work. The free zone is a separate decision with its own costs; DMCC, ADGM and IFZA from India covers it. A DMCC or IFZA commercial licence is not the VARA licence these fees buy; crypto licence in Dubai and the UAE separates the two.

The cost of not licensing is visible in VARA’s June 2026 notices against Peken Global Limited (KuCoin) and MX Global LTD (MEXC); why banks and counterparties in Dubai ask for the licence before they connect you is covered on the VARA licensing service page. If the token is dirham-referenced, VARA is not your regulator: AED payment tokens belong to the Central Bank of the UAE. And if Abu Dhabi’s ADGM or the DIFC fits your clients better, VARA vs ADGM vs DIFC shows where each starts and stops.

Frequently asked questions

How much does a VARA licence cost in 2026?

As at 6 October 2026, Schedule 2 of the VARA Regulations 2023 sets a licence application fee of AED 40,000 for Advisory and VA Transfer and Settlement Services, and AED 100,000 for Broker-Dealer, Custody, Exchange, Lending and Borrowing, VA Management and Investment and Category 1 VA Issuance. Annual supervision fees are AED 80,000 for the first two and AED 200,000 for each of the others, paid in advance per activity. Each additional activity on the same licence carries an extension fee of 50% of the lower application fee, and application fees are non-refundable.

Is the VARA paid-up capital locked?

In substance, yes. Rule VI.B.3 of the Company Rulebook requires paid-up capital to be held at all times in a trust account with a UAE-licensed bank with VARA named as beneficiary, or in a surety bond from a UAE-authorised surety company with no end date and VARA as beneficiary, or in another manner VARA specifies on grant, reconciled monthly. Rule VI.C adds net liquid assets of at least 1.2 times monthly operating expenses, reconciled daily and held in cash, cash equivalents or VARA-approved USD or AED referencing virtual assets. It is committed capital, not working capital.

How long does VARA licensing take?

VARA publishes no duration. Its process page describes two stages, an Approval to Incorporate followed by the VASP Licence application, with feedback rounds and interviews in the second stage, but no indicative weeks or months for either. Anyone quoting a fixed number of months is estimating, not citing. What consumes the time is visible in the requirements: the entity must exist first, two Responsible Individuals, each a full-time employee and a UAE resident or UAE passport holder, must be in place, most activities need a private office, and proof of paid-up capital, insurance and a reserve account go in the evidence pack. Budget runway for months, before revenue.

Does the VARA fee differ for custody?

Custody Services carries the same VARA fees as Broker-Dealer, Exchange and the other AED 100,000 activities: an application fee of AED 100,000 and an annual supervision fee of AED 200,000, with paid-up capital of the higher of AED 600,000 or 25% of fixed annual overheads. What differs is the structure. VARA's licensed activities page states that Custody Services is the only activity that must be segregated: a VA custodian must be a distinct legal entity with a standalone licence, so custody cannot ride on an exchange or broker-dealer licence as an extension. It needs its own company, application fee, capital and Responsible Individuals.

What does VARA charge to amend or withdraw a licence?

In its fee clarification of 22 June 2023, VARA set a licence update fee of AED 500 per request for amendments to licence details, and a licence withdrawal fee of AED 10,000 for a VASP winding down its Dubai virtual asset operations. The same notice set an annual no-objection certificate fee of AED 1,000 for proprietary traders, whitepaper fees of AED 5,000 plus up to AED 50,000 for detailed review, and a legal review fee of up to AED 4,000 for written confirmation on whether an activity sits inside VARA's perimeter. All as at 22 June 2023.

How much is a VARA licence in Indian rupees?

At the FBIL reference rate of INR 26.2145 per dirham for 5 October 2026, as archived in the Reserve Bank of India reference rate archive, the AED 40,000 application fee is about Rs 10.5 lakh and the AED 100,000 fee about Rs 26.2 lakh; the annual supervision fee is about Rs 21 lakh (AED 80,000) or Rs 52.4 lakh (AED 200,000) per activity; and paid-up capital runs from about Rs 26.2 lakh for advisory to about Rs 3.93 crore for an exchange without a VARA-licensed custodian, before the test against 25% of fixed annual overheads. The Central Bank of the UAE table for the same day gives AED 0.038137 per rupee, or INR 26.22 per dirham. These are one day's rates, rounded: use the rate on the day you fund the trust account.

What does a VARA licence cost in total in the first year?

On Infinilex's arithmetic from the published figures, not a number VARA states: an advisory firm pays AED 120,000 to VARA in year one (the AED 40,000 application fee plus the AED 80,000 supervision fee) and locks AED 100,000 of paid-up capital, so AED 220,000, about Rs 57.7 lakh at the 5 October 2026 FBIL rate, before office, salaries, insurance and the commercial licensor. An exchange without a VARA-licensed custodian pays AED 300,000 in VARA fees (AED 100,000 plus AED 200,000) and locks the higher of AED 1,500,000 or 25% of fixed annual overheads, so at least AED 1.8 million, about Rs 4.72 crore, on the same basis. Adding broker-dealer to that exchange adds an AED 50,000 extension fee, AED 200,000 a year in supervision fee and its own capital line. Infinilex's fees are not in these figures.

Does anyone publish an estimated VARA timeline?

VARA does not. Third parties do, with wide spreads, and none of them bind the regulator. Gofaizen and Sherle's crypto licence index, updated 18 September 2026, says a Dubai crypto licence is issued within six to eight months of a full set of documents, while the same firm's UAE page, updated 16 June 2026, gives project time frames of four to six months. Shuraa Business Setup's Dubai guide, updated 21 January 2026, says four to eight months end to end, with regulatory approval of four to six weeks once the file is complete. These are those publishers' estimates for Dubai crypto licences generally, not VARA's figures and not Infinilex's. The stages themselves are fixed: Approval to Incorporate, then the VASP licence application, with the entity, office, two Responsible Individuals, bank account and funded capital in place between them.

Who at Infinilex works on a VARA application, and who signs?

Infinilex maps the activity set to exactly what you run, works out the paid-up capital and net liquid assets that follow from your overheads, settles the India-side FEMA and ODI route for the money before the trust account is funded, and builds the evidence pack for both stages with the commercial licensor. Our in-house chartered accountant and company secretary set up the monthly capital reconciliation and the filings that follow grant. Infinilex counsel qualified in India, the UAE and the US sign opinions for those jurisdictions; for the EU and any other jurisdiction Infinilex scopes and coordinates the local counsel who sign. Email is answered within one working day.

Next step

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VARA licence cost, capital and timeline in 2026: fees and paid-up capital per activity, from the rulebooks