Non-passporting licence routeVASP licence / registrationNo passporting

VASP Licence in Dubai

Dubai is a high-reputation VASP route for teams that need VARA-regulated virtual asset activity in or from Dubai and can support local substance, annual supervision and detailed controls.

Processing time
From 6 months
Service price
22 300 EUR
Required share capital
100 000 AED
State fee
100 000 AED
Annual supervision fee
200 000 AED
Banking difficulty
Medium
RegulatorVirtual Assets Regulatory Authority (VARA)
Market access
No passporting

What is a Dubai VASP licence?

A Dubai VASP licence is a VARA-regulated route for virtual asset activities in or from Dubai. It is activity-specific and requires local operating substance, governance, policies, supervision budget and control evidence; it is not EU passporting or a low-documentation offshore setup.

VASP
Jurisdiction
Dubai
Regulator
Virtual Assets Regulatory Authority (VARA)
Regime
VASP
Legal basis
Legal basis: VARA virtual asset regulatory framework for Dubai.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Dubai VARA licenced VASP activities

Map the business model to VARA activity categories before assuming one generic licence covers the project. Exchange, custody, broker-dealer, advisory, lending or transfer-style activity can have different evidence and approval implications.

  • Exchange

    Licensed

    Exchange operations fit within the permitted activities of this route.

  • Custody

    Licensed

    Custody is within scope; review controls requirements.

  • Brokerage

    Licensed

    Brokerage or OTC activity typically fits within scope.

  • Wallet provider

    Licensed

    Exchange operations fit within the permitted activities of this route.

  • EU market

    Not covered

    EU passporting not available from this route.

  • Startups

    Not covered

    High setup complexity means significant budget is needed.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Dubai VASP operating model

A credible VARA file should show the local entity, activity permissions, responsible management, policies, technology controls and annual supervision budget as one operating model.

  • Approval-to-incorporate and licence application planning are separate workstreams.

    Operational control area that should be covered in the applicant's governance and compliance model.

  • Local office, staff, audit and responsible management should be aligned with activity scope.

    Operational control area that should be covered in the applicant's governance and compliance model.

  • AML, custody, cybersecurity, outsourcing and complaints processes need activity-specific evidence.

    Operational control area that should be covered in the applicant's governance and compliance model.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Dubai onshore route vs offshore alternatives

Dubai is stronger than a generic offshore setup where reputation, PSP access and a regulated UAE presence matter, but it brings higher annual supervision, local substance and control obligations.

  • Regulatory reputation

    Onshore (this jurisdiction)

    High

    Offshore comparison

    Lower recognition

  • Banking access

    Onshore (this jurisdiction)

    Challenging

    Offshore comparison

    Often restricted

  • Compliance burden

    Onshore (this jurisdiction)

    High

    Offshore comparison

    Variable

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

When Dubai VASP is not suitable

Dubai VASP is weak where the business needs EU passporting, low-cost launch, minimal documents or no local operating footprint.

  • EU/EEA passporting is required.

  • The project cannot maintain Dubai substance, annual supervision and activity-specific controls.

  • The model is still an MVP without banking, AML, custody and technology evidence.

  • The main objective is a cheap offshore company rather than a regulated VASP route.

Consider instead

  • Malta (MiCA) MICA — EU/EEA passporting for European client base
  • Hong Kong (VATP) VATP — Asia Pacific hub with very high reputation
  • Canada (MSB) MSB — Fastest registration route

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Activity fit for this route

Review which crypto activities fit within the scope of this route.

Exchange
Suitable

Exchange operations fit within the permitted activities of this route.

Custody
Suitable

Custody is within scope; review controls requirements.

Brokerage
Suitable

Brokerage or OTC activity typically fits within scope.

Wallet provider
Suitable

Exchange operations fit within the permitted activities of this route.

EU market
Not suitable

EU passporting not available from this route.

Startups
Not suitable

High setup complexity means significant budget is needed.

Not sure if your model fits? Request a licensing assessment

Business model fit — Dubai

Assess how well this route covers your planned activities.

Fit score

Good fit
4/6
Partial fit
2/6
Poor fit
0/6

Dubai is a strong fit for your activity profile

This route covers your key activities. Proceed with detailed legal review.

Is Dubai VASP authorisation right for your project?

Best for

  • VARA-regulated Dubai virtual asset business

Not suitable for

  • Fast low-documentation setup

Core requirements

Use this section to check the main regulatory and operational requirements before committing to a jurisdiction.

Required share capital100 000 AED
Required
Local staffRequired
Required
Physical officeRequired
Required
AuditRequired
Required

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Local presence and operating setup

Local staff, physical office and audit planning make Dubai a strong but not lightweight route.

Local staff

Required

Required

At least one locally-accountable staff member or director is expected.

Physical office

Required

Required

A genuine office presence is expected, not a nominal registered address.

Audit

Required

Required

External audit is required for ongoing supervision compliance.

Planning notes

  • Plan for a Dubai operating base and accountable management.
  • Budget for annual supervision and maintenance, not only application work.
  • Prepare activity-specific policies and governance before licence application.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Service price (professional fees)Application preparation and professional services.
22 300 EUR EURFixed
State fee
100 000 AEDFrom
Annual supervision feeRecurring annual cost after authorisation.
200 000 AEDFrom
Required share capitalMust be held, not an expenditure.
100 000 AEDFrom
High ongoing cost

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown — Dubai

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Cost itemAmount
Service priceApplication preparation and professional services.€22,300
State fee€100,000
Required share capitalMust be held, not an expenditure.€100,000

Summary

One-off costs
€222,300
Annual (year 1)
€0
Total year 1
€222,300

Adjust to convert to your base currency.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Application process

The sequence below shows the usual project flow. Exact steps depend on the regulator, business model and application scope. Dubai — From 6 months.

Total timelineFrom 6 months

  1. Pre-assessment and scope review

    1–3 weeks

    Define the activity scope, governance model and target markets before formal preparation.

  2. Company setup in Dubai

    2–6 weeks

    Establish legal entity, appoint local staff and set up local operating structure.

  3. Documentation and compliance packBottleneck risk

    3–8 weeks

    Prepare AML/CFT policies, governance documents, controls framework and application materials.

  4. Application submission to Virtual Assets Regulatory Authority

    1–2 weeks

    Submit complete application with all required documentation.

  5. Regulator reviewBottleneck risk

    From 6 months

    Regulator reviews the application. May request clarifications. Incomplete files extend this phase.

    Depends on: File quality and completeness

  6. Authorisation or registration confirmation

    1–4 weeks

    Regulator confirms authorisation or registration. Commence operations.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

What can delay or increase cost

These factors are most likely to affect timelines and budgets for this route.

High setup complexity
High

Setup complexity is rated high for Dubai. Company setup, governance and documentation take longer than average.

Likely impactAdd 4–8 weeks to the preparation phase.
MitigationStart company setup and governance planning immediately after scope confirmation.
High maintenance cost
Medium

Ongoing supervision, audit and compliance costs are above average. Budget for these separately from the application fee.

Likely impactRecurring annual cost significantly above the one-time service price.
MitigationModel annual compliance costs before committing to this route.
Application completeness
Medium

Incomplete files are the most common cause of delay. Regulator queries extend review by weeks or months.

Likely impactEach regulator query adds 2–6 weeks to the review phase.
MitigationUse a structured compliance pack. Review file completeness before submission.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Banking and PSP feasibility

Dubai scores better than many offshore VASP routes for payment provider availability, but banks will still examine activity scope, fiat flows, token policy and AML controls.

Banking difficulty
Medium

Reflects how challenging it is to open and maintain business bank accounts in this jurisdiction.

Good PSP availability
Low

Reflects availability of payment service providers willing to onboard crypto-licensed entities.

A licence or registration does not guarantee bank account or payment provider approval. Banking feasibility should be reviewed before the application strategy is finalized.

Preparation checklist

  • Business model and transaction flow description
  • AML/KYC and sanctions controls
  • Expected fiat currencies and payment corridors
  • Source of funds and source of wealth documentation
  • Custody, token and counterparty policies where relevant

Compliance documentation

Most crypto licensing routes require a documented compliance framework before submission, not only after approval.

  • Required
    AML/CFT policy and risk assessmentDocument your customer risk model and control framework.
  • Required
    Customer due diligence (CDD) procedures
  • Required
    Enhanced due diligence (EDD) proceduresFor high-risk clients and jurisdictions.
  • Required
    Transaction monitoring system and rules
  • Required
    Sanctions screening procedures
  • Required
    Suspicious activity reporting (SAR) process
  • Required
    MLRO / Compliance officer appointmentLocal accountability may be required.
  • Recommended
    Board-approved governance charter
  • Conditional
    Outsourcing policy and monitoringRequired if functions are outsourced.
  • Recommended
    ICT / cybersecurity policy
  • Required
    Complaints handling procedure
  • Required
    Annual external audit engagementRequired for ongoing supervision compliance.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Documents to prepare

Preparing these materials before filing reduces regulator questions and helps with banking or payment provider onboarding.

0 / 12 required
Required
Recommended
Depends on scope

Corporate documents

AML and compliance

Operational

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Regulator profile

Regulatory authority · Dubai

Virtual Assets Regulatory Authority (VARA)

Official regulator website
Regulatory reputation
High

Strong international recognition and established supervision track record.

Setup complexity
High

Reflects documentation depth, governance requirements and expected review friction.

Regulatory risk
Medium

Reflects likelihood of delays, additional information requests or policy uncertainty.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Risk assessment

Main risk dimensions for the Dubai route.

Setup complexity
High

Route risk rating — setup complexity: High.

Maintenance cost
High

Route risk rating — maintenance cost: High. Budget for ongoing compliance, fees and supervision separately.

Regulatory reputation
High

Route risk rating — regulatory reputation: High.

Regulatory risk
Medium

Route risk rating — regulatory risk: Medium. Weak compliance, vague scope or insufficient controls increase review risk.

Mitigation: Prepare an evidence-based compliance file before submission.

Banking difficulty
Medium

Route risk rating — banking difficulty: Medium. Authorisation does not guarantee bank account opening.

Mitigation: Start banking outreach and compliance preparation before the application.

This content is for general orientation only. Crypto regulation changes quickly and the final scope should be confirmed through a jurisdiction-specific legal review before filing or incorporation.

Dubai vs other VASP routes

Compare Dubai with Cayman or BVI for offshore flexibility, Mauritius for regulated offshore substance, and MiCA/CASP for EU access.

Current

Dubai

VASP

Price
22 300 EUR
Timeline
From 6 months
Passporting
No passporting
Banking
Medium
Reputation
High

Malta (MiCA)

MICA

Price
20 700 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
Medium
Reputation
High

+ EU/EEA passporting for European client base

− Requires EU nexus and substance

View route

Hong Kong (VATP)

VATP

Price
25 500 EUR
Timeline
From 6 months
Passporting
No passporting
Banking
High
Reputation
Very high

+ Asia Pacific hub with very high reputation

− Platform-specific licence, high banking friction

View route

Canada (MSB)

MSB

Price
20 600 EUR
Timeline
From 2 months
Passporting
No passporting
Banking
Medium
Reputation
High

+ Fastest registration route

− Registration only, not a full licence

View route

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Dubai vs other VASP jurisdictions

Compare key parameters across VASP-regulated jurisdictions.

Sort by:
DubaiCurrent
Price22 300 EUR
TimelineFrom 6 months
BankingMedium
ReputationHigh
Malta
Price20 700 EUR
TimelineFrom 6 months
BankingMedium
ReputationHigh
Hong Kong
Price25 500 EUR
TimelineFrom 6 months
BankingHigh
ReputationVery high

Check your readiness for Dubai VASP authorisation

Documented AML/CFT policies, risk assessment, compliance officer.

Share capital

100 000 AED minimum capital required.

AML/CFT framework

Documented AML/CFT policies, risk assessment, compliance officer.

Governance structure

Board, management, accountability chain defined.

Banking preparation

Banking strategy and identified partners.

Local substance plan

Local staff and office in Dubai.

Readiness status

Answer the criteria on the left to see your readiness status.

Frequently asked questions

No. VARA permissions are activity-specific. Map the business model to the licenced activities and any conditions.

Usually no. Dubai is better for a regulated UAE presence than for a low-documentation offshore setup.

No. EU/EEA access should be assessed through MiCA/CASP.

Prepare activity scope, local operating setup, policies, governance, AML, technology controls, banking package and annual supervision budget.

The page is not legal advice and should not be relied on as a substitute for advice from qualified counsel in the relevant jurisdiction.

Your dedicated specialists

  • Enrico Kärvinen

    Enrico

  • Rein Tammik

    Rein

  • Jurata Žukaitė

    Jurata

  • Andrej Kazlauskas

    Andrej

  • Marta Värna

    Marta

  • Katrin Lepik

    Katrin

  • Inga Stankavičiūtė

    Inga

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