“DMCC Crypto Licence”: Why Founders Get It Wrong and What You Actually Need
Last updated: 2 November 2026
Key takeaways:
- There is no single DMCC licence that lets you run a crypto business: a DMCC commercial licence does not, by itself, authorise a regulated virtual asset activity.
- VARA regulates virtual asset activities across Dubai’s mainland and free zones, except the DIFC. Being in DMCC does not take a company outside VARA’s reach.
- A DMCC licence alone covers only non-regulated activities such as crypto software development and consultancy. Even trading with own funds needs a VARA NOC.
- A company that provides any of VARA’s eight licensed activities to others needs a DMCC licence and a VARA licence for each activity.
- The DMCC Crypto Centre is an ecosystem, not a regulator. Membership is a commercial advantage, not a regulatory permission.
“We need a DMCC crypto licence” is one of the most common requests we receive. The phrase is understandable: DMCC is Dubai’s best-known home for crypto companies, and service providers advertise “crypto licences” there. But there is no such thing as a single DMCC licence that lets you run a crypto business. DMCC says so itself: holding a DMCC commercial licence does not, by itself, authorise a company to conduct a regulated virtual asset activity.
Two authorities, two different licences
A crypto company in DMCC deals with two bodies. DMCC provides the commercial framework: incorporation, the commercial licence, office space and visas. The Virtual Assets Regulatory Authority (VARA) regulates virtual asset activities across Dubai’s mainland and free zones, with the exception of the Dubai International Financial Centre. The legal basis is Dubai Law No. 4 of 2022, which provides that no person may conduct a virtual asset activity in Dubai without a permit from VARA. Being in a free zone does not take a company outside VARA’s reach.
What a DMCC licence alone covers
According to DMCC, its standard licence covers non-regulated activities such as crypto software development, consultancy and trading, and an additional licence from VARA is required for regulated virtual asset activities. The word “trading” here causes much of the confusion. Even a company that trades only its own funds, without clients, needs a No Objection Certificate (NOC) from VARA, and must register with VARA if its 30-day trading volume exceeds the threshold. So in practice, a DMCC licence alone is enough only for technology and advisory businesses that do not touch virtual asset services.
Even then, DMCC describes one more step: blockchain companies that do not provide virtual asset services are not required to hold a VARA licence, but obtain a one-time NOC from VARA after their commercial licence is issued.
This is a different document from the NOC for proprietary trading, which must be held at all times and, under VARA’s 2023 fee guidance, costs AED 1,000 a year.
The NFT row surprises many founders. VARA states that entities holding NFT marketplace commercial licences in free zones must obtain a VA Exchange licence and/or a VA Broker-Dealer licence.
How licensing works for a crypto service provider in DMCC
The process runs through DMCC but ends with VARA. The applicant submits VARA’s Initial Disclosure Questionnaire on VARA Connect, VARA’s online portal, pays the initial fees and receives VARA’s Approval to Incorporate. At this point, the company still cannot carry on virtual asset activities. DMCC then issues the commercial licence, and the company applies to VARA for its licence. Regulated activities can begin only once VARA has issued it.
What the DMCC Crypto Centre is, and is not
The DMCC Crypto Centre, launched in May 2021, is an ecosystem for crypto and blockchain businesses, not a regulator. It offers licensing support, office space, visas, access to accelerators and investors, and DMCC reports more than 800 crypto member companies by the end of 2025. Membership in the Centre is a commercial advantage, not a regulatory permission.
One more source of confusion is history. DMCC’s 2021 materials referred to regulation by the federal Securities and Commodities Authority, because VARA did not yet exist. Since 2022, VARA has been the regulator for virtual assets in Dubai’s free zones, and at federal level the Securities and Commodities Authority was replaced by the Capital Market Authority from 1 January 2026. Founders relying on older articles should check which regime they describe.
Why the distinction matters
A company that offers virtual asset services or markets them in the UAE with only a DMCC licence is operating without a licence. In October 2025, VARA fined nineteen firms between AED 100,000 and AED 600,000 for unlicensed activity and marketing breaches and ordered them to stop operating. A commercial licence does not protect against these fines.
What we recommend
- Start from what the business actually does, not from the name of the licence.
- Check whether any activity falls within VARA’s eight licensed activities, including trading for or with others.
- If you trade only your own funds, obtain the VARA NOC before the first trade.
- Budget for VARA fees and capital separately from DMCC costs: they are paid to different authorities.
The bottom line
DMCC is often the right place for a crypto company in Dubai, but a DMCC licence is a trade licence, not an authorisation to provide virtual asset services. That authorisation comes only from VARA, so the “DMCC crypto licence” is in fact two or more documents from different authorities. Founders who understand this from the start choose the right activities and avoid paying for a licence that does not let them operate. AMLzone can help you map your business model, choose the right structure in DMCC and take you through the VARA process.
Sources
1. DMCC, “Managing Crypto Regulation in Dubai: The Roles of DMCC and VARA”, 18 September 2026. https://dmcc.ae/blog/managing-crypto-regulation-in-dubai-the-roles-of-dmcc-and-vara
2. DMCC, “Managing Crypto Regulation in Dubai: The Roles of DMCC and VARA”, 18 September 2026. https://dmcc.ae/blog/managing-crypto-regulation-in-dubai-the-roles-of-dmcc-and-vara
3. Dubai Law No. 4 of 2022 Regulating Virtual Assets in the Emirate of Dubai, Art. 3 and Art. 15(a); VARA, “About VARA”. https://rulebooks.vara.ae/sites/default/files/en_net_file_store/VARA_EN_338_VER1.pdf
4. DMCC, “Crypto and Blockchain” ecosystem. https://dmcc.ae/ecosystems/crypto-and-blockchain
5. VARA, Frequently Asked Questions. https://www.vara.ae/en/faq/
6. DMCC, “Managing Crypto Regulation in Dubai: The Roles of DMCC and VARA”, 18 September 2026. https://dmcc.ae/blog/managing-crypto-regulation-in-dubai-the-roles-of-dmcc-and-vara
7. VARA, Frequently Asked Questions. https://www.vara.ae/en/faq/
8. DMCC, “Managing Crypto Regulation in Dubai: The Roles of DMCC and VARA”, 18 September 2026; VARA, “Licence Applications”. https://www.vara.ae/en/licenses-and-register/licence-applications/
9. DMCC, press release on the launch of the DMCC Crypto Centre, 24 May 2021. https://landing.dmcc.ae/hubfs/C5-Migrated-Files/Press%20Releases/2021/May-24.pdf
10. DMCC, “Managing Crypto Regulation in Dubai: The Roles of DMCC and VARA”, 18 September 2026. https://dmcc.ae/blog/managing-crypto-regulation-in-dubai-the-roles-of-dmcc-and-vara
11. Federal Decree-Law No. 32 of 2025, Art. 2(2). https://www.uaelegislation.gov.ae/en/legislations/4001/download
12. VARA, “VARA Steps Up Enforcement to Safeguard Dubai’s Virtual Asset Market: 19 Unlicensed Firms Penalised and Public Warning Issued”, 7 October 2025. https://www.vara.ae/en/regulations/regulatory-notices/vara-steps-up-enforcement-to-safeguard-dubai-s-virtual-asset-market-19-unlicensed-firms-penalised-and-public-warning-issued/
03.11.2026
