VARA Licence Cost in 2026: Fees, Capital and Ongoing Costs
Last updated: 5 November 2026
Key takeaways:
- The cost of a VARA licence falls into three groups: the licensing process itself, government fees and regulatory capital, and operating costs in the first year.
- Each licensed activity has a one-off application fee and an annual supervision fee: AED 40,000 and AED 80,000 for advisory and transfer and settlement, AED 100,000 and AED 200,000 for the other activities.
- Minimum paid-up capital depends on the activity: from AED 100,000 for advisory to at least AED 1,500,000 for an exchange that does not use a VARA-licensed custodian.
- There are no discounts on VARA licence fees for new applicants.
- Not every crypto business needs a licence: a company that trades only its own funds needs a No Objection Certificate (NOC) instead, which costs AED 1,000 a year under VARA’s 2023 fee guidance.
“How much does a VARA licence cost?” is usually the first question a founder asks us, and the answer they expect is a single number. In practice, the cost falls into three groups: the licensing process itself, government fees and regulatory capital, and the operating costs of running a licensed company in its first year.
All of this applies to companies that need a licence. A company that trades only its own funds, without clients, needs a No Objection Certificate (NOC) instead, which costs AED 1,000 a year under VARA’s 2023 fee guidance.
1. The licensing process
Obtaining a licence is a project in its own right. The applicant completes VARA’s Initial Disclosure Questionnaire, receives an Approval to Incorporate, and then submits a full application and answers VARA’s questions, which may include meetings and interviews. Behind the application stands a business plan and a full set of policies: anti-money laundering, compliance, risk management, technology and information security, among others. Preparing them takes months of specialist work, and many companies engage a consultancy to do it. That cost belongs in the budget from the start. Timing matters too: typically, half of the application fee is paid when VARA’s review starts, and the rest of it, together with the first year’s supervision fee, before the licence is issued.
2. Government fees and regulatory capital
VARA charges two fees for each licensed activity: a one-off licence application fee and an annual supervision fee.
A broker-dealer therefore pays VARA AED 300,000 before its first client. Each additional activity adds its own annual supervision fee, but instead of a second full application fee VARA charges a licence extension fee of 50% of the lower application fee. VARA may also impose additional supervision fees, and VARA may impose additional supervision fees or modify fees based on a company’s risk profile. Smaller fees appear along the way: AED 500 for each licence update request, AED 10,000 to withdraw a licence, up to AED 4,000 for a legal review of whether an activity needs a licence, and, for token issuers, AED 5,000 per whitepaper submission plus a review fee of up to AED 50,000.
The second amount owed to the regulator, in effect, is capital. It is not a fee: it must be held at all times while the company is licensed, and the amount depends on the activity chosen. The lower figures apply where the company uses a VARA-licensed custodian or is otherwise approved during licensing. If a company is licensed for several activities, the requirements add up.
The second amount owed to the regulator, in effect, is capital. It is not a fee: it must be held at all times while the company is licensed, and the amount depends on the activity chosen. The lower figures apply where the company uses a VARA-licensed custodian or is otherwise approved during licensing. If a company is licensed for several activities, the requirements add up.
The capital must be held in a UAE bank trust account naming VARA as beneficiary, through a surety bond or in another way VARA allows, and reconciled monthly.
3. Operating costs in the first year
A licensed company must operate to VARA’s standards from its first day, so the first year should be budgeted in full:
- People. Two Responsible Individuals of sufficient seniority, each a UAE resident or UAE passport holder and a full-time employee; a Compliance Officer with the same residence and full-time requirements and at least five years of experience; a Money Laundering Reporting Officer. A Chief Information Security Officer is required as well and must be a different person from the Compliance Officer.
- Office and commercial licence. The company also needs a commercial licence and premises from Dubai Economy and Tourism or a free zone, and the cost depends on the licensor.
- Service providers. An independent auditor of the financial statements and an independent technology auditor for penetration testing at least once a year, including smart contract reviews where relevant. Travel Rule compliance and client onboarding also require systems, which in practice usually come from external providers. Monthly, quarterly and annual returns to VARA add to the workload.
- Insurance. Professional indemnity, directors’ and officers’ cover and, for virtual assets kept in hot wallets, commercial crime insurance. VARA sets no minimum amounts; the cover must be adequate to the size and complexity of the business.
- Working capital. On top of the paid-up capital, the company must keep net liquid assets of at least 1.2 times its monthly operating expenses, and reserve assets equal to 100% of the virtual assets it holds for clients, in the same asset. This list is not exhaustive: depending on the business model, other costs may apply.
Are there discounts?
Not for new applicants. The only discount VARA has announced, of up to 50% on licensing fees together with reduced capital requirements, was for legacy operators that were already active in Dubai and moved to the licensing regime.
The cost of skipping the licence
Operating without a licence is not a cheaper alternative. In October 2024, VARA fined seven firms between AED 50,000 and AED 100,000; in October 2025, it fined nineteen firms between AED 100,000 and AED 600,000 for unlicensed activity and marketing breaches and ordered them to stop operating. The maximum fine for a company is the higher of AED 50 million and 15% of annual revenue.
What we recommend
- Budget all three groups, not just the fees, and plan the first year of operations in full.
- Choose your activities carefully: each one adds fees and may raise the capital requirement, which a VARA-licensed custodian can lower.
- Plan the UAE-based hires and key service providers before you apply: VARA will ask who fills each role.
The bottom line
A VARA licence costs far more than the fee schedule suggests, but the costs are predictable if planned from the start. The process is labour-intensive, and many companies rely on a consultancy, which is a cost item in its own right. Those that run out of money usually underestimate capital and operating costs, not fees. AMLzone can help you choose the right activities, build a realistic budget and take you through the VARA licensing process.
Sources
1. VARA, Virtual Assets and Related Activities Regulations 2023, Schedule 2 “Supervision and Authorisation Fees”. https://rulebooks.vara.ae/rulebook/schedule-2-supervision-and-authorisation-fees
2. VARA, “Licence Applications”. https://www.vara.ae/en/licenses-and-register/licence-applications/
3. VARA, Virtual Assets and Related Activities Regulations 2023, Schedule 2 “Supervision and Authorisation Fees”. https://rulebooks.vara.ae/rulebook/schedule-2-supervision-and-authorisation-fees
4. VARA, “VARA Publishes Clarification and Further Information on Fees”, 22 June 2023. https://www.vara.ae/en/news/vara-publishes-clarification-and-further-information-on-fees/
5. VARA, Company Rulebook, Part VI, Rule B “Paid-up Capital”. https://rulebooks.vara.ae/rulebook/b-paid-capital
6. VARA, Company Rulebook, Part VI, Rule B “Paid-up Capital”. https://rulebooks.vara.ae/rulebook/b-paid-capital
7. VARA, Company Rulebook, Part VI, Rules C “Net Liquid Assets” and E “Reserve Assets”. https://rulebooks.vara.ae/rulebook/c-net-liquid-assets
8. VARA, Company Rulebook, Part VI, Rule D “Insurance”. https://rulebooks.vara.ae/rulebook/d-insurance
9. VARA, Company Rulebook, “Responsible Individuals”; Compliance and Risk Management Rulebook, rules on the Compliance Officer and the Money Laundering Reporting Officer. https://rulebooks.vara.ae/rulebook/c-responsible-individuals
10. VARA, Technology and Information Rulebook, “Chief Information Security Officer and Management”. https://rulebooks.vara.ae/rulebook/i-chief-information-security-officer-and-management
11. VARA, Compliance and Risk Management Rulebook, “Audit” and “Regulatory Reporting”; Technology and Information Rulebook, “Testing and Audit”. https://rulebooks.vara.ae/rulebook/e-testing-and-audit
12. VARA, “Licence Applications” (Legacy Operating Permit). https://www.vara.ae/en/licenses-and-register/licence-applications/
13. VARA, “VARA Publishes Clarification and Further Information on Fees”, 22 June 2023. https://www.vara.ae/en/news/vara-publishes-clarification-and-further-information-on-fees/
14. VARA, regulatory notices of 9 October 2024 and 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/
15. VARA, Virtual Assets and Related Activities Regulations 2023, Schedule 3 “Fines”. https://rulebooks.vara.ae/rulebook/schedule-3-fines
05.11.2026
