ADGM FSRA and DIFC DFSA crypto licensing advisory

An ADGM crypto licence is a Financial Services Permission from the FSRA in Abu Dhabi, approved to use Virtual Assets in any of seven VA Regulated Activities: Dealing in Investments as Principal or Agent, Advising on Investments or Credit, Arranging Deals in Investments, Managing Assets, Providing Custody and Operating a Multilateral Trading Facility. A DIFC crypto token licence is a DFSA Licence whose authorisation covers Crypto Tokens across the nine applicable Financial Services, from dealing as principal to operating an MTF. Infinilex runs either application end to end.

A VARA licence covers neither zone: VARA licenses Dubai outside the DIFC, and its September 2024 framework with the SCA excludes the DIFC and does not reach ADGM. Which regime fits your product: VARA vs ADGM vs DIFC.

Schedule A: how the FSRA and the DFSA regulate crypto activity

Schedule A · FSRA (ADGM) and DFSA (DIFC) crypto regimes compared, as at 25 September 2026
Dimension	ADGM: FSRA	DIFC: DFSA
Regulator and seat	FSRA, Abu Dhabi; permissions under the Financial Services and Markets Regulations 2015.	DFSA, Dubai; Crypto Token rules in GEN chapter 3A of the DFSA Rulebook.
Perimeter	Seven VA Regulated Activities; Virtual Assets treated as commodities; ICOs sit outside the framework.	Nine Financial Services; no service related to a Utility Token or NFT except a custody firm holding them (GEN 3A.2.4).
Token approval model	Firm-led since June 2025: the firm assesses each token against COBS 17.2.2, notifies the FSRA no later than five Business Days before use and publishes its list. Fiat-Referenced Tokens sit under separate FRT rules, amended 31 October 2025 with effect from 1 January 2026.	Firm-led since 12 January 2026: the firm concludes on reasonable grounds that a non-fiat token is suitable (GEN 3A.2.1(2)(a)), publishes its list and files a monthly return (GEN 3A.2.1A). Fiat Crypto Tokens need the DFSA to be satisfied; its Policy Statement lists those assessed.
Capital basis	PRU Chapter 3. Custody: higher of USD 250,000 or six months’ Annual Audited Expenditure. MTF: six months’ operational expenses plus a buffer of up to six more unless the FSRA directs otherwise, in fiat.	By prudential category under the DFSA PIB module; the amount turns on the category the DFSA assigns to the firm.
Review cycle	Continuous monitoring (COBS 17.2.6); at least annual third-party verification of core systems; annual cyber security review for MTFs and custodians (COBS 17.5).	Continuous monitoring and regular review of each token (GEN 3A.2.1A; DFSA guidance expects at least six-monthly); monthly Crypto Token information return.
AML law	Federal Decree by Law No. 10 of 2025, effective 14 October 2025; FSRA AML Rulebook in full.	Federal Decree by Law No. 10 of 2025; DFSA AML module (VER30/04-26).
Prohibited tokens	Privacy Tokens and Algorithmic Stablecoins; the FSRA may order a firm to cease activity in any token (FSMR sections 5A and 5B).	Privacy Tokens and Privacy Devices (GEN 3A.2.2), Algorithmic Tokens (GEN 3A.2.3); Utility Tokens and NFTs outside custody.

Sources, read 25 September 2026: FSRA Virtual Asset guidance, 10 June 2025; ADGM Notices of Publication; DFSA Rulebook GEN 3A.2.1, 3A.2.1A, 3A.2.2, 3A.2.4; CBUAE Rulebook. Dirham stablecoins on the mainland: where to issue a stablecoin.

What ADGM and DIFC crypto licensing advisory covers

Activity and perimeter mapping. What you run, mapped to the seven FSRA activities or the nine DFSA Financial Services, and only those: over-scoping raises capital and fees.
Entity and corridor structuring. In ADGM a financial (Category A) entity applies to the FSRA before the Registration Authority incorporates it, and it has to sit correctly against your group: for India-linked founders, the ODI classification, Form FC and the Annual Performance Report through our FEMA, ODI and LRS practice; for a Delaware parent, the US leg.
The readiness gap assessment. Our UAE VASP licensing-readiness checklist run against COBS Chapter 17 or GEN chapter 3A: substance, capital, the Compliance Officer and MLRO, banking, technology and the dossier.
The application and evidence pack. For the FSRA, the Virtual Asset Application Form, launch plan and Approved Person forms; for the DFSA, the Licence application under FER 2.1 or the variation under FER 2.2.6, with Authorised Individual forms and the Retail Client endorsement where retail is in scope.
The token suitability framework. We build the COBS 17.2.2 or GEN 3A.2.1(3) methodology, the evidence file behind each token, the published list, the notification and return routines and the re-review calendar.
AML, technology governance and supervision. The AML programme under the FSRA AML Rulebook or the DFSA AML module, the COBS 17.5 controls on wallets, keys and flow of funds, and the MTF and custody segregation the FSRA expects.

How the FSRA and DFSA applications run, stage by stage

The FSRA sets out five stages in its June 2025 guidance; neither regulator publishes a duration.

Due diligence and discussions with the FSRA. In-person meetings and technology demonstrations before filing.
Formal application. The Virtual Asset Application Form, supporting documents and launch plan; review starts once form, plan and fees are all received.
In-Principle Approval. Granted only to an applicant able to meet all applicable Rules; the FSRA expects an IPA to give banks comfort.
Final approval, the FSP. Conditional on operational testing and, where applicable, third-party verification of systems.
Operational launch testing. An MTF or custodian goes live only after testing to the FSRA’s satisfaction.

In the DIFC, crypto is written into the Licence: what searchers call a DFSA crypto token endorsement is, in the rulebook, an authorisation on the Licence that covers Crypto Tokens.

Scoping. Which of the nine Financial Services you need (dealing as principal or agent, arranging deals, managing assets, advising on financial products, providing custody, arranging custody, operating a clearing house and operating an MTF), whether the authorisation must cover Crypto Tokens, and whether Retail Clients are in scope.
Application. A new Licence under FER 2.1 or a variation under FER 2.2.6, with the Authorised Individuals, business plan, financial model and policy set.
The token suitability framework. The GEN 3A.2.1(3) assessment of each token, documented with objective evidence as the DFSA Supervisory Guidelines require.
Supervision. The re-review the DFSA guidance expects at least six-monthly, the monthly return, and the duty to be able to demonstrate your grounds to the DFSA’s satisfaction (GEN 3A.2.1A(c)).

What the FSRA and the DFSA charge, in brief

The FSRA adds one Virtual Asset fee to the fees for each underlying Regulated Activity, USD 20,000 at application and USD 15,000 a year (FEES 3.17.1(a), 3.17.2(a)), and an MTF also pays a monthly trading levy (FEES 3.18). The DFSA prices the Licence itself: USD 40,000, 25,000 or 15,000 for a new Licence by highest Financial Service (FER 2.1.1), USD 40,000 down to USD 5,000 to vary an authorisation to include Crypto Tokens (FER 2.2.6), USD 150,000 for an ATS trading Crypto Tokens (FER 2.1.5), and annual Financial Service fees of USD 70,000, 35,000 or 20,000 where the authorisation covers Crypto Tokens, plus an expenditure component and USD 4,000 for each additional Financial Service (FER 3.2.1). Figures as at 25 September 2026 from the FSRA guidance and the DFSA Fees Module, FER VER35/04-26. VARA’s fees are on VARA licence cost, capital and timeline.

How an ADGM or DIFC licensing engagement is staged

Fixed-scope stages, mapped on a free discovery call. Stage one is the activity map and gap assessment against COBS 17 or GEN 3A, with the entity and corridor plan; it stands on its own before you commit to filing. Stage two is the application: the dossier, the token suitability framework and the regulator queries. Stage three, optional, is the first supervisory year on a monthly retainer. Plan and cost are agreed first: how engagements work.

Who signs what on ADGM and DIFC licensing work

Infinilex is a consultancy: we run the analysis, build the dossier and hold the evidence file. The ADGM and DIFC legs are signed by Infinilex counsel qualified for that regulator; the India leg by Infinilex counsel enrolled as advocates in India, or by Infinilex’s company secretary or chartered accountant where a statute names that professional; a US leg by Infinilex counsel admitted in the US. Statutory signatories stay as the rules name them: the applicant’s directors sign the FSRA and DFSA application forms and the Approved Person and Authorised Individual forms; the company or its directors sign Form FC and the APR, and the authorised dealer bank reports to the RBI.

Frequently asked questions

Does a VARA licence cover ADGM or the DIFC?

No. VARA licenses Dubai outside the DIFC, and its 5 September 2024 framework with the SCA, which registers a VARA licensee by default with the SCA for the wider UAE, excludes the DIFC and does not reach ADGM. ADGM needs its own FSRA Financial Services Permission and the DIFC its own DFSA Licence. A VARA licence gives no standing in either financial free zone, and an FSRA or DFSA permission gives none in Dubai outside the DIFC.

What changed on 12 January 2026 in the DIFC?

Token approval moved to the firm. GEN Rule 3A.2.1(2), in force from 12 January 2026, permits a Financial Service, Financial Promotion or Offer relating to a non-fiat Crypto Token only where the firm has itself concluded on reasonable grounds that the token is suitable. New Rule 3A.2.1A adds a published list, continuous monitoring with regular review (the DFSA guidance expects at least every six months), immediate cessation if a token stops being suitable, and a monthly Crypto Token information return. Fiat Crypto Tokens still need the DFSA to be satisfied.

What did the FSRA change in June 2025?

The ADGM Board enacted the Financial Services and Markets (Amendment No. 1) Regulations 2025 on 4 June 2025, and on 10 June 2025 the FSRA published amended COBS, FUNDS, PRU and FEES rulebooks with new Virtual Asset guidance. Accepting a token is now the firm's job: it assesses each token against COBS 17.2.2, notifies the FSRA no later than five Business Days before use and publishes its list. Tokens approved under the old FSRA-led process keep their status.

Can I list any token on an ADGM or DIFC platform?

No. In ADGM every token must pass your own COBS 17.2.2 assessment, with monitoring the FSRA says native blockchain explorers generally do not satisfy; Privacy Tokens and Algorithmic Stablecoins are prohibited. In the DIFC every non-fiat Crypto Token must pass your GEN 3A.2.1 suitability assessment; Privacy Tokens, Privacy Devices and Algorithmic Tokens are prohibited, and only a custody firm may hold Utility Tokens or NFTs. The FSRA can also order a firm to cease activity in a specific token.

Next step

Tell us what you are building in Abu Dhabi or the DIFC.

Send a one-paragraph description of the product and where your users sit. We will say which FSRA activities or DFSA Financial Services it maps to, before you spend anything.

Book a discovery call The Web3 practice

ADGM and DIFC crypto licensing, run end to end.