VARA licence cost, capital and timeline in 2026: fees and paid-up capital per activity, from the rulebooks
As at 12 September 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.
Fees and capital by activity
| 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 is an approval form, not a licence |
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.
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.
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.
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 12 September 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.
Budgeting a VARA application?
Tell us which activities you actually run, where the founders and capital sit, and your monthly overheads. We will map the activity set, the capital that follows, and the India-side FEMA route for the money, before you pay a non-refundable fee.
Further reading
VARA licensing · VARA vs ADGM vs DIFC · The UAE VASP licensing checklist · MiCA vs VARA · DMCC vs ADGM vs IFZA from India · FEMA, ODI and LRS compliance · Crypto licence requirements by country
This article is general information for founders, not legal advice on your specific activities or structure. Schedule 2 and Company Rulebook figures are stated as at 12 September 2026 from the current consolidated rulebooks; the fee clarification figures are as at 22 June 2023. VARA may modify fees and capital case by case, nothing here predicts whether or when a licence will be granted, and commercial licensor, office and banking costs are excluded. Check the numbers against the live rulebooks and your own overheads before you rely on them.