VARA License Cost in Dubai: Fees, Capital & Process

A VARA crypto license in Dubai costs AED 100,000 in application fees plus AED 200,000 per year in supervision fees for a high-band activity, totalling AED 300,000 in official VARA fees in Year 1. On top of that you fund activity-specific paid-up capital and cover incorporation, office and professional costs. This page owns the hard numbers.

The Virtual Assets Regulatory Authority (VARA) is the Dubai virtual-asset regulator that licenses VASPs across Dubai mainland and the free zones, with the DIFC carved out. For the full background on what VARA is, the eight licensed activities and the wider UAE regulator map, see our complete VARA license guide for Dubai. Here we stay on the figures: the VARA Rulebook Schedule 2 fee table, per-activity paid-up capital, the two-stage process, the timeline and a clearly-labelled total cost.

By Magnus Müller · Reviewed by Magnus Müller · Last updated: 2026-06-14

VARA License Cost at a Glance (2026)

VARA prices its licences per virtual-asset activity, splitting them into a high band and a lower band. The single most budget-relevant figure is the Year-1 cost of a high-band activity such as an exchange, broker-dealer or custody licence: AED 100,000 in application fees plus AED 200,000 in first-year supervision, equal to AED 300,000 in official VARA fees, with AED 200,000 per year recurring thereafter, per Schedule 2 of the Virtual Assets and Related Activities Regulations 2023.

The headline figure: high-band vs lower-band activities

High-band activities (Exchange, Broker-Dealer, Custody, Lending and Borrowing, Management and Investment, Category 1 VA Issuance) carry an AED 100,000 application fee and AED 200,000 annual supervision fee, so AED 300,000 in VARA fees in Year 1. Lower-band activities (Advisory, Transfer and Settlement) carry AED 40,000 plus AED 80,000, so AED 120,000 in Year 1, per Schedule 2.

What "cost" includes (and what it does not)

"VARA license cost" can mean three different things, and budgeting goes wrong when they are mixed. The application fee alone is the smallest layer. The Year-1 VARA total adds the first-year supervision fee. The all-in setup cost then adds funded paid-up capital plus third-party items such as incorporation, office lease, legal, audit and AML tooling. This page keeps official VARA fees (sourced) strictly separate from third-party costs (which vary by setup), and itemises both in the [Total Cost section](#total-cost-to-get-a-vara-license-in-dubai-illustrative) below.

VARA Fee Schedule by Activity (Schedule 2)

The full fee table below comes verbatim from VARA Rulebook Schedule 2, using its own column headers: Licence Application Fee, Licence Extension Fee and Annual Supervision Fee. All amounts are in AED. The eight activities are named only here; their definitions live on the complete VARA license guide for Dubai.

Application, extension and supervision fees explained

The three fee types behave differently. The Licence Application Fee is one-off, charged for the regulated activity applied for, and in the two-stage process around 50% is paid at Approval-to-Incorporate and the remaining 50% at the full licence stage, per VARA's Licence Applications page. The Licence Extension Fee is charged per additional VA activity when one entity licenses more than one. The Annual Supervision Fee is recurring, due in advance and paid again each year, per Schedule 2.

High-band vs lower-band activities

Six activities sit in the high band at 100,000 / 200,000 / 200,000: Broker-Dealer, Category 1 VA Issuance, Custody, Exchange, Lending and Borrowing, and VA Management and Investment. Two activities sit in the lower band at 40,000 / 80,000 / 80,000: Advisory Services and VA Transfer and Settlement Services, per Schedule 2. The band an applicant lands in is therefore the first lever on total cost, well before capital and third-party setup are added.

Correcting a common error: the extension fee is AED 200,000, not AED 100,000

A frequent error, repeated by older cost summaries, states the per-additional-activity extension fee for high-band activities as AED 100,000. Schedule 2 shows it is AED 200,000 for those high-band activities and AED 80,000 for Transfer and Settlement, per VARA Rulebook Schedule 2. For Advisory the extension is 50% of the lower applicable fee. Use the sourced figure when budgeting multi-activity licences. [VERIFY: confirm this is the extension column, not the supervision column, on a clean re-fetch of Schedule 2.]

How VARA Fees Are Calculated for Multiple Activities

If one entity licenses more than one activity, VARA charges the full application and supervision fees for the base activity, then a Licence Extension Fee for each additional activity, plus that additional activity's own annual supervision fee. The extension fee is AED 200,000 for high-band activities, AED 80,000 for Transfer and Settlement, and 50% of the lower fee for Advisory, per Schedule 2.

Worked example: exchange plus custody

Take a firm licensing Exchange Services and Custody Services. The base Exchange activity is AED 100,000 application plus AED 200,000 Year-1 supervision. Custody is added via an AED 200,000 Licence Extension Fee plus its own AED 200,000 annual supervision fee. So the official VARA fees in Year 1 work out to AED 100,000 + AED 200,000 (Exchange) + AED 200,000 + AED 200,000 (added Custody), totalling AED 700,000 in VARA fees in Year 1. All four figures come from Schedule 2; the arithmetic is ours, and funded capital plus third-party costs are extra.

VARA Paid-Up Capital Requirements by Activity

Beyond fees, a VASP must fund paid-up capital, and this is activity-dependent. Per the VARA Company Rulebook, Part VI, Section B (Paid-Up Capital), dated 19 May 2025, the requirement is not a single flat number but a "higher of" test, with additional Net Liquid Assets and Insurance obligations layered on top.

The "higher of" rule: fixed minimum vs 25% of overheads

The rule is that a VASP must at all times hold paid-up capital equal to the higher of two amounts: a fixed AED minimum set for the activity, or 25% of the firm's fixed annual overheads, per the Company Rulebook Part VI.B. A lower 15% factor applies to certain custody-approved arrangements. In practice, lean firms with low overheads sit on the fixed minimum, while larger operators with heavy running costs are driven by the 25% overheads test.

Per-activity capital table

The indicative per-activity minimums below are presented as ranges where the rulebook contains sub-tiers, alongside the "higher of" mechanism, per Part VI.B. Treat them as the fixed-minimum leg of the test, not a guaranteed final figure.

[VERIFY: exact per-activity capital tiers. Source 4 returned ranges for Broker-Dealer (400k–600k), Exchange (800k–1.5m) and Management/Investment (280k–500k); pull the exact Part VI.B table before publishing single hard figures.]

Net Liquid Assets and insurance (also required)

Paid-up capital is not the whole prudential picture. The Company Rulebook Part VI also imposes Net Liquid Assets requirements and Insurance requirements, which a VASP must satisfy alongside the paid-up capital test. These add to the funded capital a firm must hold, so they belong in any honest cost model even though their exact formulas are confirmed below as still pending. [VERIFY: Net Liquid Assets formula and Insurance minimums under Part VI not yet extracted; keep descriptive, no invented numbers.]

The Two-Stage VARA Licensing Process

VARA runs a two-stage path for new firms: Approval to Incorporate (ATI), then the Full VASP Licence. A firm cannot carry on virtual-asset activities until the full licence is granted, per VARA's Licence Applications page. Around 50% of the application fee is paid at ATI, with the remainder plus the first year's supervision fee due at the full-licence stage.

Stage 1, Approval to Incorporate (ATI)

Stage 1 begins with an Initial Disclosure Questionnaire (IDQ) submitted to the Department of Economy and Tourism (DET) for mainland firms, or to the relevant Free Zone authority, with a business plan, beneficial-owner (UBO) details and senior-management information, per VARA. The firm pays roughly 50% of the Licence Application Fee and receives the ATI, which lets it finalise incorporation and operational setup. VARA is explicit that at this point the firm is not permitted to carry on virtual-asset activities.

Stage 2, Full VASP Licence

Stage 2 requires the full documentation set, plus engagement with VARA through meetings, interviews and requests for additional materials, per VARA's Licence Applications page. The firm pays the remaining portion of the application fee together with the first year's Annual Supervision Fee, then receives the VASP Licence, which may carry operational conditions or permissions. Only at this point can the licensed activities begin.

Mainland (DET) vs Free Zone incorporation

VARA's fees are identical whether a firm incorporates on the mainland or in a free zone. The difference is the incorporation registrar: the DET for mainland firms versus a free-zone registrar such as DMCC or DWTC. The DIFC is outside VARA's perimeter and is regulated separately. A VARA licence may also require federal approval before full market operations: this overlay (the SCA was replaced by the federal Capital Markets Authority in January 2026) is covered on the complete VARA license guide for Dubai. [VERIFY: confirm no zone-specific VARA surcharge; confirm post-2026 CMA approval mechanism before stating as settled.]

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Documents Required for a VARA License Application

VARA's documentation requirements fall into three broad categories, and its published list is non-exhaustive, per VARA's Licence Applications page. Preparing all three in parallel, rather than sequentially, is what keeps the two-stage timeline on track.

Corporate structure and governance documents

This category covers incorporation certificates, the UBO list, CVs of directors and Responsible Individuals, the business plan and financial statements, per VARA. These establish who controls and runs the entity and underpin the senior-management information first supplied with the IDQ at Stage 1.

Risk, compliance and AML/CFT documents

VARA expects AML/CFT policies, a compliance framework and a risk-management framework, per VARA. Building these to a defensible standard is where most applications consume time, so we cover the full document set in our AML/CFT compliance framework guide.

Technology and cybersecurity documentation

VARA also requires technology and cybersecurity documentation describing the systems, controls and resilience behind the proposed activities, per VARA. For exchange and custody applicants this category is heavy, since it must evidence custody architecture, key management and operational security suitable for the high-band activity being licensed.

How Long Does a VARA License Take?

VARA does not publish a fixed statutory clock; it defines the stage gating from ATI to Full VASP Licence but not a guaranteed duration, per VARA's Licence Applications page. Advisers commonly indicate roughly 4–7 months end to end, with up to about 12 months allowed between Initial Approval and submitting for the full licence, per secondary adviser guidance. Treat these as indicative, not a VARA commitment.

What drives the timeline

Duration is driven by the completeness of the IDQ and the document pack, the VARA interviews and technical evaluation, and any site inspection, per VARA. The single biggest accelerator within an applicant's control is submitting a complete, internally consistent pack at each stage, since back-and-forth requests for additional materials are what stretch the indicative 4–7 month band.

Total Cost to Get a VARA License in Dubai (Illustrative)

The figures below are an illustrative estimate built from the primary fee schedule. They are not a VARA-published "total." We itemise them so official VARA fees stay visibly separate from funded capital and third-party costs that vary by setup.

Official VARA fees, Year 1 (itemised)

For a single high-band activity, the Year-1 official fees are AED 100,000 application plus AED 200,000 supervision, equal to AED 300,000, with AED 200,000 per year recurring, per Schedule 2. For a single lower-band activity (Advisory or Transfer and Settlement) the Year-1 official fees are AED 40,000 plus AED 80,000, equal to AED 120,000, with AED 80,000 per year recurring. Each additional activity adds its Licence Extension Fee plus that activity's supervision fee.

Capital you must fund

Separate from fees, the firm must fund paid-up capital at the higher of the fixed AED minimum or 25% of fixed annual overheads, per Part VI.B. As a funded amount this ranges from around AED 100,000 for Advisory up to AED 800,000–1,500,000 for an Exchange licence, before Net Liquid Assets and Insurance requirements are added. This capital is held, not spent, but it is real cash that must be committed.

Third-party and setup costs (varies / on quote)

Several real costs sit outside VARA's fee schedule entirely and vary by setup: company incorporation and the mainland or free-zone licence, a physical Dubai office lease, legal and advisory fees, audit, and AML systems and tooling. Minor ancillary VARA charges (covered below) also apply. We do not publish figures for these third-party items because they depend on the specific structure; they are best handled on quote. For a cross-jurisdiction view, see how Dubai sits against other markets in our compare crypto license costs by country guide, and weigh building versus a ready-made crypto license.

Ancillary Fees and the Legacy Operating Permit

Beyond the headline fees and capital, VARA levies a set of smaller ancillary charges, and a discounted legacy route exists for firms that were operating before VARA's regime took effect.

Other VARA charges

Per VARA's "Clarification and Further Information on Fees", ancillary charges include a regulatory-perimeter legal review fee of up to AED 4,000; a VA Issuance whitepaper submission fee of AED 5,000 plus a detailed review of up to AED 50,000 (so up to about AED 55,000 combined); a proprietary-trading annual NOC fee of AED 1,000; a licence update or amendment fee of AED 500 per request; and a licence withdrawal (wind-down) fee of AED 10,000. These are modest next to the core fees but should still appear in a complete budget.

Legacy Operating Permit (pre-February 2023 operators)

Firms that were operating before February 2023 may apply for a Legacy Operating Permit, which offers up to a 50% discount on licensing fees and carries a 12-month validity, per VARA. This route is narrow, since it depends on demonstrable pre-regime activity, but for eligible operators it materially reduces the Year-1 fee load. New entrants do not qualify and pay the full Schedule 2 fees.

From Our Practice

In our advisory work on Gulf and global VASP applications, the cost overruns we see are almost never the VARA fees themselves, which are fixed and knowable from Schedule 2. They come from the items around them: capital funded later than planned, an AML and risk document pack that needs rebuilding to pass review, or a multi-activity licence whose extension fees were budgeted at the wrong figure. Modelling the full picture, fees plus funded capital plus third-party setup, before submitting the IDQ is what keeps a Dubai engagement predictable. We treat the official-versus-third-party boundary on this page as the same discipline we apply to client budgets.