Obtaining a VASP license in Dubai

In the United Arab Emirates, namely in Dubai, you can obtain a license to provide services related to cryptocurrency: a Virtual Asset Service Provider (VASP) license, which is issued by the Virtual Asset Regulatory Authority (VARA). This license can be obtained anywhere in Dubai, in the Free Zones, except for the Dubai International Financial Center (DIFC). Obtaining this license ensures the legality of your activities in Dubai, strengthens customer confidence in you and opens up access to potential business expansion in the future.

Dubai is one of the main economic centers of the Middle East. It is known as a major trade, financial and tourist center, as well as a place with a favorable business environment and many free economic zones that attract international investments.

This license will interest you if you plan to operate with cryptocurrency, as well as if you plan to enter the Middle East or the international market.

Activity list and issued license

The VASP license itself allows you to engage in a specific type of activity, and one company can obtain several VASP licenses at once and, accordingly, engage in several types of activities simultaneously. At the moment, 36 companies have already received a VASP license, of which 13 companies received 17 licenses in 2025.

When obtaining licenses for several types of activities, it is not necessary to go through all the steps taken for each license. VARA has foreseen this and simplified the procedure for obtaining licenses for companies that already have at least one active VASP license.

The most popular activities are broker-dealer services (24 isuued licenses), management and investment services (10 issued licenses), and exchange services (7 issued licenses).

The full list of activities and the number of issued licenses is attached below:

Name of activity	Number of issued licenses
Broker-dealer services	24
Management and investment services	10
Exchange services	7
Exchange services, including derivatives exchange	4
Lending and borrowing services	4
Custody services, including custodial staking	3
Custody services	2
Advisory services	2
Issuance	1
TOTAL:	57

Is it possible to work with a VASP in Dubai without a license?

In Dubai and the UAE, it is prohibited to provide VASP-related services without a relevant license. Providing such services without a license may result in fines, revocation of other existing licenses, or even criminal penalties.

However, there is an alternative option for obtaining permission to conduct your business without obtaining a license - in-principle approval. In-principle approval allows companies operating globally to obtain permission to conduct their activities in a special manner. This procedure differs from the general one, but still obliges the company to take certain actions to obtain the relevant permission.

Currently, 5 companies have in-principle approval. Under in-principal approval next licenses have been issued:

Name of activity	Number of issued licenses
Broker-dealer services	2
Exchange services	2
Custody services	1
TOTAL:	5

What requirements are set by the regulator?

Our team has analyzed the legislation related to VASP in Dubai in terms of requirements for organizations wishing to obtain a VASP license and identified the following general requirements:

Minimum Capital	Varies depending on the chosen type/types of activity from AED 100,000 (approximately USD 27,000) to AED 1,500,000 (approximately USD 408,000). However, on average, the minimum authorized capital is approximately AED 400,000-600,000 (approximately USD 109,000-163,000).
Minimum Capital	In case the company will conduct several types of activities, the amount of the minimum authorized capital is subject to change.
Employees	The company must have at least 2 directors, both of whom must be UAE residents. The company must have a Compliance Officer who meets the requirements of UAE legislation. An independent auditor (third party) must be appointed by the company to audit the company's financial statements.
Legal structure	Registration of a legal entity in Dubai on any of its territories (mainland or free zone, with the exception of DIFC). The company must have a legal address (real office) in Dubai.
Cost of applying for a license and annual license fees	Depending on the type of license, the cost of filing is AED 40,000 (approximately USD 10,900) or, for the vast majority of licenses, AED 100,000 (approximately USD 27,000). At the same time, the cost of the annual license fee is double the amount of the filing cost: AED 80,000 (approximately USD 21,800) and AED 200,000 (approximately USD 54,500), respectively.
Cost of applying for a license and annual license fees	If the company will conduct several types of activities, the cost of filing for a license is the cost of filing for one license (the most expensive) and 50% of the cost of filing for all the others. At the same time, the cost of annual license fees is paid in full for each type of activity.

Process of obtaining

Preparatory stage.

Assessment of compliance with VARA requirements;
Company registration;
Contribution to the authorized capital;
Hiring local employees, who must be in the company;
Document preparation.

Collecting, drafting and certifying all necessary documents;
Checking for compliance with VARA standards and requirements;
Filling out and submitting the application;
Review of the application.

Time frame: the entire process can take from 3 to 4 months, however, VARA can extend the time frame for various clarifications and updates of information at its discretion;
Communication with VARA, providing additional information upon request.
Issuance of a license.

Start of business and compliance with current VARA requirements.

Required documents

Corporate documents.
- Certificate of entity incorporation;
- List of ultimate beneficial owners (UBO);
- Source of funds evidence (SOF);
- Organisational structure;
- Business plan;
Compliance documents.
- AML/CFT policy and procedures;
- Current AML/CFT program status;
- Anti-bribery and corruption (ABC) policy and procedures (ABC);
- Conflicts of interest policy;
- Terms and conditions (also referred to as Terms of Service, Terms of Use, etc.) on client agreements;
- Privacy policy;
- Marketing policy and plan;

Other documents maybe be required upon the government agency's request.

License issuance time-frame

Our Team was also able to determine the approximate time frame for obtaining a VASP license, provided that the process begins only with your desire.

Preparation of documents (both for company registration and for the license itself): 1-2 months;
Company registration, opening an account, contributing the authorized capital: 1-2 months;
Review of the application and obtaining a license: up to 4 months by default and up to 2-3 months in case of responses to inquiries, updating information, various clarifications.

What recommendations can be offered?

First of all, it is important to determine for yourself whether you really want to obtain this license in this jurisdiction. Then determine which time frame is optimal for you, and which are extreme. After that, you will need to familiarize yourself with local legislation and begin the preparation process, or trust lawyers who are already familiar with this area and continue with them.

Separately, we would like to note that when obtaining this license, it is recommended to contact lawyers, since incorrect execution of documents at any stage may result in refusal to register a legal entity or refusal to issue a license. To successfully complete all stages, it is important to seek help from professionals. Law&Trust lawyers will help you obtain a license, prepare documents and are ready to fully support the entire process, helping you even after you receive the license.

Our Team was also able to determine the approximate time frame for obtaining a VASP license, provided that the process begins only with your desire.

Preparation of documents (both for company registration and for the license itself): 1-2 months;
Company registration, opening an account, contributing the authorized capital: 1-2 months;
Review of the application and obtaining a license: up to 4 months by default and up to 2-3 months in case of responses to inquiries, updating information, various clarifications.

F.A.Q.

What is the tax rate in Dubai?

Corporate Income Tax (CIT) is 9%, however if your income is not above 375 000 AED (102 000 USD), then CIT rate is 0%

How many directors should a company have to obtain this license?

Two directors. Both must be residents.

Is it possible not to pay the minimum authorized capital until the license is obtained?

No, the minimum share capital must be paid before applying for a license. Proof of payment must be attached to the application.

What happens if I apply for a VASP license for a company registered in the DIFC?

The regulator will refuse to accept your application for consideration, the entire process of collecting documents will only be an unnecessary waste of your resources.