Dubai New Virtual Asset Law: Opportunities and Challenges for Businesses by VARA

• Dubai has now established one of the most structured frameworks for virtual assets through Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai and the regulations developed by the Virtual Assets Regulatory Authority (VARA). If you plan to go through Dubai company registration for a cryptocurrency exchange, custody, brokerage, tokenization, or other virtual assets business, then you need to understand that incorporation alone does not permit you to conduct regulated virtual asset activities.  

• This framework has created opportunities for businesses looking for a regulated base in Dubai, along with introducing licensing, capital, compliance, technology, AML and governance obligations. As of 2026, VARA has continued to update its rulebooks, making regulatory monitoring an important part of operating a virtual asset business in Dubai. 

What is the Dubai New Virtual Asset Law? 

• The Dubai New Virtual Asset Law is Law No. (4) of 2022, Regulating Virtual Assets in the Emirate of Dubai, which has established the new legal framework for regulating virtual assets and has created the VARA as the dedicated virtual asset regulator in Dubai. This law applies across all the mainland and free zones of Dubai, but excludes the Dubai International Financial Centre (DIFC). This law is further supported by the Virtual Assets and Related Activities Regulations 2023, VARA rulebooks, marketing regulations, and federal AML/CFT requirements.  

• Practical takeaway: If your business is conducting regulated virtual asset activities in or from Dubai, you should determine the applicable VARA license before beginning your operations.  

Which government authorities regulate virtual assets in Dubai and the UAE? 

• VARA is the main authority for virtual assets in Dubai outside of the DIFC, while the federal UAE laws and other competent authorities may also apply based on your business activities. VARA regulates virtual assets across the mainland and free zones in Dubai, whereas the DIFC has a separate regulatory framework.  

• The broader UAE virtual asset regulations also consist of AML/CFT legislation. The current rulebook of VARA references Federal Decree-Law No. (10) of 2025, about anti-money laundering, combating the financing of terrorism and proliferation, together with the Cabinet Resolution No. (134) of 2025.  

• Practical takeaway: You should evaluate both the VARA requirements and applicable federal obligations instead of treating a VARA license as your only compliance requirement. 

Which businesses need a VARA license in Dubai? 

• You generally need a VARA license before conducting regulated virtual asset activities in or from Dubai, excluding DIFC. VARA currently identifies eight regulated activities: advisory services, broker-dealer services, custody services, exchange services, lending and borrowing services, management and investment services, transfer and settlement services, and Category 1 virtual asset issuance.  

• A business may apply for multiple activities under one overarching license, subject to VARA’s rules and specific requirements for certain custody activities. VARA also states that no virtual asset activity should automatically be assumed to be outside its regulatory perimeter.  

• Practical takeaway: Before establishing your company, you should map your actual business model, products and services against VARA’s regulated activities. 

What are the main opportunities under Dubai crypto regulations? 

• The framework can provide your business with greater regulatory clarity, market credibility, and access to Dubai’s growing digital-asset ecosystem. VARA’s public register demonstrates that licensed firms are operating across activities including brokerage, exchange, advisory, custody, and investment management.  

• VARA’s framework is also designed to accommodate innovation. Its licensed-activity structure is described as flexible and evolutionary, allowing the regulatory perimeter to develop as the sector changes.  

• For your business, potential advantages include: 

• Operating within a dedicated virtual asset regulatory framework.  

• Greater confidence for institutional and professional counterparties.  

• Opportunities in exchange, brokerage, custody and tokenization.  

• Access to Dubai’s established financial and technology ecosystem.  

• A clearer compliance framework for expanding your virtual asset operations.  

• Practical takeaway: Regulatory compliance can become a commercial advantage if you use it to demonstrate transparency, governance, and operational credibility. 

What are the main challenges under the Dubai cryptocurrency law? 

• The principal challenge is that regulatory approval requires considerably more than company incorporation. You need to demonstrate appropriate governance, financial resources, risk management, compliance systems, technology controls, and qualified personnel.  

• VARA’s requirements can also increase your operating costs. In addition, regulatory updates require you to continuously monitor changes rather than treating licensing as a one-time exercise. For example, VARA issued updated activity-based rulebooks in May 2025, with full compliance required by 19 June 2025.  

• VARA has also demonstrated active enforcement. In October 2025, it announced penalties against 19 firms for unlicensed virtual asset activities and marketing violations, with fines ranging from AED 100,000 to AED 600,000.  

• Practical takeaway: Operating without the correct approval can create financial, legal, and reputational exposure. 

Why should you choose Tetra Consultants? 

• Setting up a virtual asset business in Dubai requires you to coordinate company incorporation, regulatory licensing, corporate structuring, and ongoing compliance. Tetra Consultants can support your business throughout this process by helping you understand the applicable requirements and prepare the relevant regulatory procedures. 

• Our team can help you in selecting the appropriate Dubai mainland and free zone structure on the basis of your activities.  

• Our team can help you in preparing and coordinating your VASP license application.  

• Our experts will assist you in creating business plans, corporate documents, and other required application materials. 

Conclusion  

• The Dubai New Virtual Asset Law provides your business with a structured regulatory environment for operating in the virtual asset sector. Through Law No. (4) of 2022, VARA regulations and federal AML/CFT requirements, Dubai has created a framework that supports innovation while imposing significant licensing, capital, governance and compliance obligations.  

• If you plan to establish a cryptocurrency exchange, brokerage, custody provider, investment business or tokenization venture, you should identify the correct regulatory activity, establish the appropriate corporate structure and prepare your compliance framework before beginning operations. 

• To get Dubai VARA License, contact us, and our team will get back to you in 24 hours. 

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