VARA NOC vs VARA Licence: Which One Do You Need?
Last updated: 19 October 2026
Key takeaways
- Any virtual asset service or activity in Dubai requires a VARA licence, registration or an NOC. No virtual asset activity is exempt from supervision.
- If you do something with virtual assets for someone else, you most likely need a licence. VARA licenses eight activities.
- An NOC is enough only in a few specific cases. The clearest one is proprietary trading: a company that trades only with its own money and has no clients.
- The NOC for proprietary traders costs AED 1,000 a year and usually takes about 4 to 8 weeks together with the company licence.
- An NOC is not a “light licence”: it does not allow you to serve clients.
“Do we really need a VARA licence?” This is one of the first questions founders ask us when they plan a crypto business in Dubai. Sometimes the honest answer is no. But it is almost never “you don’t need VARA at all”. Between a full licence and doing nothing, there is a third option that many people have not heard of: the No Objection Certificate, or NOC.
Below we explain what an NOC is, who needs one, and where the line is after which an NOC is no longer enough.
Licence, registration or NOC
The Virtual Assets Regulatory Authority (VARA) regulates virtual assets in Dubai, including its free zones, except the Dubai International Financial Centre (DIFC), which has its own regulator. VARA’s own position is very clear: any virtual asset service or activity requires a VARA licence, registration or an NOC, and no virtual asset activity is “exempt” from supervision. In practice, this gives three levels:
- Licence. For businesses that provide virtual asset services to others. This is the full regime with capital requirements, compliance staff and ongoing supervision.
- Registration. For certain activities that VARA wants to see and monitor, but does not license. The best-known example is large-scale proprietary trading.
- NOC. A written confirmation from VARA that a specific activity may be carried out without a licence. It is not a “light licence”: it does not allow you to serve clients. It simply confirms that VARA has no objection to what you plan to do.
When you need a licence
VARA licenses eight 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, which covers tokens referenced to fiat currencies or real-world assets. The common thread is simple: if you do something with virtual assets for someone else, you most likely need a licence.
Getting one is a serious project. The process has two stages. In the first, you submit an Initial Disclosure Questionnaire through Dubai Economy and Tourism (DET) or a free zone and receive an Approval to Incorporate. In the second, VARA reviews your full documentation and issues the licence. Fees are charged per activity: AED 40,000 or AED 100,000 for the application and AED 80,000 or AED 200,000 for annual supervision, depending on the activity.
When an NOC is enough
The clearest case is proprietary trading: a company that buys and sells virtual assets only with its own money and has no clients. VARA does not require a licence for this, at least for now, but it does require an NOC, and it must be obtained before trading starts. If the company’s trading volume over a rolling 30 days goes above VARA’s threshold, it must also register with VARA.
There is one detail that often surprises our clients: a company that already holds a VASP licence is not allowed to do proprietary trading. If a licensed exchange or broker wants to trade for its own account, it needs a separate company, and that company needs its own NOC.
How the NOC process works
The VARA NOC application for proprietary trading is submitted directly through the VARA Connect portal. Applicants complete an Initial Disclosure Questionnaire (IDQ), providing information about the company, its ownership and management, proposed trading activities, business model and source of funds.
Importantly, the application can be initiated before the company is incorporated, using the proposed company details. Once submitted, VARA reviews the application and may request additional information before issuing its decision.
The process typically takes around 4–8 weeks, depending on the completeness of the application and VARA's review.
The line you should not cross
An NOC covers exactly the activity described in it. The moment a proprietary trading firm starts trading for a friend’s fund, holding someone else’s crypto or giving investment advice, it is no longer proprietary trading, and an NOC is no longer enough. VARA takes this seriously. In October 2025 it fined 19 firms between AED 100,000 and AED 600,000 for unlicensed activity and marketing breaches and ordered them to stop operating.
What we recommend
- Describe your business model honestly and in detail: who you work with, whose money is involved and what exactly you do with virtual assets.
- Check it against VARA’s eight licensed activities. If any of them fits, plan for a licence, not an NOC.
- If you only trade with your own funds, obtain the NOC before the first trade.
- Revisit the analysis whenever the business model changes. A new client or a new service can move you from an NOC to a licence overnight.
The bottom line
An NOC is the right tool for a narrow group of businesses, and for them it saves months of work and a lot of money compared with a full licence. But it is not a way around licensing. If you are not sure whether your crypto business needs a licence, a registration or an NOC, AML Zone can help you assess your model and take you through the right route with VARA.
Sources
1. Dubai Law No. 4 of 2022 Regulating Virtual Assets — https://u.ae/en/about-the-uae/digital-uae/regulatory-framework/regulation-of-digital-properties ; VARA Virtual Assets and Related Activities Regulations 2023 — https://rulebooks.vara.ae/rulebook/virtual-assets-and-related-activities-regulations-2023
2. VARA, Frequently Asked Questions and “Licensed Activities” — https://www.vara.ae/en/faq/
3. VARA, “Licensed Activities” — https://www.vara.ae/en/licenses-and-register/licensed-activities/
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. 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
6. 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/
19.10.2026
