Virtual asset regulation in the United Arab Emirates
Last Updated: August 2026
Last Updated: August 2026
Virtual asset regulation in the United Arab Emirates is based on a combination of federal regulation, emirate-level regulation and separate regulatory regimes in the country's financial free zones. The framework establishes licensing and supervisory requirements for virtual-asset activities and includes measures relating to investor protection and anti-money-laundering and counter-terrorist-financing compliance.
Table of Content:
- Early regulation in Abu Dhabi Global Market
- Development of token regulation in the DIFC
- Establishment of VARA in Dubai
- Expansion of the DIFC regime
- Federal virtual-asset framework
- VARA's full-market regulatory framework
- Regulation of payment tokens
- Coordination between the federal regulator and VARA
- Federal capital-market reform
- 2026 federal Virtual Assets Framework
- Current regulatory structure
Early regulation in Abu Dhabi Global Market
One of the earliest dedicated virtual-asset regulatory regimes in the UAE was developed in Abu Dhabi Global Market (ADGM). On 25 June 2018, its Financial Services Regulatory Authority (FSRA) launched a framework regulating spot crypto-asset activities conducted in ADGM.
The framework covered crypto-asset activities carried out by exchanges, custodians and other intermediaries in ADGM. It addressed risks relating to money laundering and financial crime, consumer protection, technology governance, custody and exchange operations.
The ADGM framework applied to activities conducted within ADGM and operated as a separate financial-free-zone regulatory regime.
Source: ADGM - ADGM launches Crypto Asset Regulatory Framework
One of the earliest dedicated virtual-asset regulatory regimes in the UAE was developed in Abu Dhabi Global Market (ADGM). On 25 June 2018, its Financial Services Regulatory Authority (FSRA) launched a framework regulating spot crypto-asset activities conducted in ADGM.
The framework covered crypto-asset activities carried out by exchanges, custodians and other intermediaries in ADGM. It addressed risks relating to money laundering and financial crime, consumer protection, technology governance, custody and exchange operations.
The ADGM framework applied to activities conducted within ADGM and operated as a separate financial-free-zone regulatory regime.
Source: ADGM - ADGM launches Crypto Asset Regulatory Framework
Development of token regulation in the DIFC
In October 2021, the Dubai Financial Services Authority (DFSA) introduced a regime for the regulation of Investment Tokens in the Dubai International Financial Centre (DIFC). This was the first phase of the DFSA's regulatory work relating to tokens and was followed by a broader Crypto Token regime in 2022.
Source: DFSA — Crypto Token regime comes into force
In October 2021, the Dubai Financial Services Authority (DFSA) introduced a regime for the regulation of Investment Tokens in the Dubai International Financial Centre (DIFC). This was the first phase of the DFSA's regulatory work relating to tokens and was followed by a broader Crypto Token regime in 2022.
Source: DFSA — Crypto Token regime comes into force
Establishment of VARA in Dubai
On 28 February 2022, Dubai issued Law No. 4 of 2022 Regulating Virtual Assets in the Emirate of Dubai. The law established the Virtual Assets Regulatory Authority (VARA) as the authority responsible for regulating, supervising and overseeing virtual-asset services in Dubai.
Sources: Dubai Legislation Portal — Law No. 4 of 2022 Regulating Virtual Assets in the Emirate of Dubai
The law applies to virtual-asset services in all zones across Dubai, including special development zones and free zones, but expressly excludes the DIFC.
Source: Dubai Legislation Portal — Law No. 4 of 2022, Article 3
Under the law, VARA was established as a public corporation with legal personality and financial and administrative autonomy and was affiliated to the Dubai World Trade Centre Authority.
Source: Dubai Legislation Portal — Law No. 4 of 2022, Article 4
VARA's statutory objectives include developing Dubai as a regional and international hub for virtual assets, attracting investment, protecting investors and developing rules for the regulation and supervision of virtual-asset platforms and service providers. Its functions include licensing and supervising virtual-asset service providers and regulating the issuance, offering and trading of virtual assets.
Source: Dubai Legislation Portal — Law No. 4 of 2022, Articles 5–6
The establishment of VARA introduced a specialised virtual-asset regulator for Dubai outside the DIFC while the UAE was also developing broader regulation of virtual assets at the federal level.
On 28 February 2022, Dubai issued Law No. 4 of 2022 Regulating Virtual Assets in the Emirate of Dubai. The law established the Virtual Assets Regulatory Authority (VARA) as the authority responsible for regulating, supervising and overseeing virtual-asset services in Dubai.
Sources: Dubai Legislation Portal — Law No. 4 of 2022 Regulating Virtual Assets in the Emirate of Dubai
The law applies to virtual-asset services in all zones across Dubai, including special development zones and free zones, but expressly excludes the DIFC.
Source: Dubai Legislation Portal — Law No. 4 of 2022, Article 3
Under the law, VARA was established as a public corporation with legal personality and financial and administrative autonomy and was affiliated to the Dubai World Trade Centre Authority.
Source: Dubai Legislation Portal — Law No. 4 of 2022, Article 4
VARA's statutory objectives include developing Dubai as a regional and international hub for virtual assets, attracting investment, protecting investors and developing rules for the regulation and supervision of virtual-asset platforms and service providers. Its functions include licensing and supervising virtual-asset service providers and regulating the issuance, offering and trading of virtual assets.
Source: Dubai Legislation Portal — Law No. 4 of 2022, Articles 5–6
The establishment of VARA introduced a specialised virtual-asset regulator for Dubai outside the DIFC while the UAE was also developing broader regulation of virtual assets at the federal level.
Expansion of the DIFC regime
On 1 November 2022, the DFSA's Crypto Token regime came into force in the DIFC. It was introduced as the second phase of the DFSA's digital-asset regulatory framework following the Investment Token regime introduced in October 2021.
The regime addressed financial services involving Crypto Tokens and covered risks relating to trading, clearing, holding and transferring such tokens. It included requirements relating to AML/CFT, consumer protection, market integrity, custody and the financial resources of service providers.
Source: DFSA - Crypto Token regime comes into force
On 1 November 2022, the DFSA's Crypto Token regime came into force in the DIFC. It was introduced as the second phase of the DFSA's digital-asset regulatory framework following the Investment Token regime introduced in October 2021.
The regime addressed financial services involving Crypto Tokens and covered risks relating to trading, clearing, holding and transferring such tokens. It included requirements relating to AML/CFT, consumer protection, market integrity, custody and the financial resources of service providers.
Source: DFSA - Crypto Token regime comes into force
Federal virtual-asset framework
On 12 December 2022, the UAE government issued Cabinet Resolution No. 111 of 2022 Regulating Virtual Assets and the Related Service Providers. The resolution was published in the Federal Gazette on 15 December 2022 and entered into force on 14 January 2023.
The resolution established a federal framework for virtual assets and related service providers outside the UAE's financial free zones. Regulated virtual-asset activities within its scope require a licence from the federal securities regulator or from a competent local licensing authority.
The resolution excluded the financial free zones from its scope and also excluded activities already falling within the regulatory competence of the CBUAE and certain activities regulated separately by the federal securities regulator.
The resolution defined a Local Licensing Authority as a local authority competent to regulate virtual assets in an emirate. It also assigned the federal securities regulator supervisory and coordinating responsibilities in relation to virtual-asset service providers regulated by local authorities.
Source: UAE Legislation — Cabinet Resolution No. 111 of 2022
On 12 December 2022, the UAE government issued Cabinet Resolution No. 111 of 2022 Regulating Virtual Assets and the Related Service Providers. The resolution was published in the Federal Gazette on 15 December 2022 and entered into force on 14 January 2023.
The resolution established a federal framework for virtual assets and related service providers outside the UAE's financial free zones. Regulated virtual-asset activities within its scope require a licence from the federal securities regulator or from a competent local licensing authority.
The resolution excluded the financial free zones from its scope and also excluded activities already falling within the regulatory competence of the CBUAE and certain activities regulated separately by the federal securities regulator.
The resolution defined a Local Licensing Authority as a local authority competent to regulate virtual assets in an emirate. It also assigned the federal securities regulator supervisory and coordinating responsibilities in relation to virtual-asset service providers regulated by local authorities.
Source: UAE Legislation — Cabinet Resolution No. 111 of 2022
VARA's full-market regulatory framework
On 7 February 2023, VARA issued the Virtual Assets and Related Activities Regulations 2023, developing the regulatory powers established by Dubai Law No. 4 of 2022 into a detailed regulatory framework for virtual assets and related activities in Dubai.
The Regulations established rules covering the issuance of virtual assets, regulated virtual-asset activities, licensing, activity-specific rulebooks, AML/CFT requirements, marketing, market offences, supervision and enforcement.
Source: VARA - Virtual Assets and Related Activities Regulations 2023
The framework was intended to provide greater regulatory clarity for virtual-asset service providers and to address risks associated with different types of virtual-asset activity.
On 7 February 2023, VARA issued the Virtual Assets and Related Activities Regulations 2023, developing the regulatory powers established by Dubai Law No. 4 of 2022 into a detailed regulatory framework for virtual assets and related activities in Dubai.
The Regulations established rules covering the issuance of virtual assets, regulated virtual-asset activities, licensing, activity-specific rulebooks, AML/CFT requirements, marketing, market offences, supervision and enforcement.
Source: VARA - Virtual Assets and Related Activities Regulations 2023
The framework was intended to provide greater regulatory clarity for virtual-asset service providers and to address risks associated with different types of virtual-asset activity.
Regulation of payment tokens
A separate regulatory regime was introduced for digital assets used in payment services. The CBUAE's Payment Token Services Regulation became effective on 31 August 2024.
The regulation establishes three categories of Payment Token Services: Payment Token Issuance, Payment Token Conversion, and Payment Token Custody and Transfer.
A person providing a Payment Token Service within the UAE, or directing such a service to persons in the UAE, must hold the licence or registration required by the CBUAE.
The Payment Token Services Regulation applies specifically to payment-token services, while Cabinet Resolution No. 111 of 2022 excludes activities that fall within the regulatory competence of the CBUAE from its virtual-asset framework.
Sources: CBUAE - Payment Token Services Regulation
A separate regulatory regime was introduced for digital assets used in payment services. The CBUAE's Payment Token Services Regulation became effective on 31 August 2024.
The regulation establishes three categories of Payment Token Services: Payment Token Issuance, Payment Token Conversion, and Payment Token Custody and Transfer.
A person providing a Payment Token Service within the UAE, or directing such a service to persons in the UAE, must hold the licence or registration required by the CBUAE.
The Payment Token Services Regulation applies specifically to payment-token services, while Cabinet Resolution No. 111 of 2022 excludes activities that fall within the regulatory competence of the CBUAE from its virtual-asset framework.
Sources: CBUAE - Payment Token Services Regulation
Coordination between the federal regulator and VARA
On 5 September 2024, the Securities and Commodities Authority (SCA) and VARA signed a cooperation agreement governing coordination between the federal and Dubai virtual-asset regimes. The agreement was publicly announced on 9 September 2024.
Source: SCA/CMA - SCA and VARA set regulatory framework for the UAE's virtual assets sector, 9 September 2024
The agreement established rules and procedures for the licensing and supervision of virtual-asset service providers and covered mutual supervision, regulatory information exchange, penalties and enforcement cooperation.
Source: SCA/CMA - SCA and VARA cooperation agreement
Under the agreement, VASPs operating in or from Dubai, or seeking to service Dubai, are required to obtain a VARA licence and can be registered with the federal regulator to service the wider UAE. VASPs seeking to operate from other emirates are required to obtain the applicable federal licence.
Source: SCA/CMA - Licensing of VASPs under the SCA–VARA cooperation framework
On 5 September 2024, the Securities and Commodities Authority (SCA) and VARA signed a cooperation agreement governing coordination between the federal and Dubai virtual-asset regimes. The agreement was publicly announced on 9 September 2024.
Source: SCA/CMA - SCA and VARA set regulatory framework for the UAE's virtual assets sector, 9 September 2024
The agreement established rules and procedures for the licensing and supervision of virtual-asset service providers and covered mutual supervision, regulatory information exchange, penalties and enforcement cooperation.
Source: SCA/CMA - SCA and VARA cooperation agreement
Under the agreement, VASPs operating in or from Dubai, or seeking to service Dubai, are required to obtain a VARA licence and can be registered with the federal regulator to service the wider UAE. VASPs seeking to operate from other emirates are required to obtain the applicable federal licence.
Source: SCA/CMA - Licensing of VASPs under the SCA–VARA cooperation framework
Federal capital-market reform
The UAE federal capital-markets regime was reorganised through Federal Decree-Law No. 32 of 2025 Regarding the Capital Market Authority and Federal Decree-Law No. 33 of 2025 Regarding the Regulation of Capital Market. Both laws entered into force on 1 January 2026.
Sources:
UAE Legislation - Federal Decree-Law No. 32 of 2025 Regarding the Capital Market Authority
UAE Legislation - Federal Decree-Law No. 33 of 2025 Regarding the Regulation of Capital Market
Federal Decree-Law No. 32 of 2025 reconstituted the SCA as the Capital Market Authority (CMA). The CMA became the legal successor to the SCA and assumed its rights, obligations and regulatory functions.
Sources: UAE Legislation - Federal Decree-Law No. 32 of 2025
Federal Decree-Law No. 33 of 2025 gives the CMA responsibility for regulating trading in virtual assets and the financial activities, services and functions associated with them within its statutory perimeter.
Source: UAE Legislation - Federal Decree-Law No. 33 of 2025 Regarding the Regulation of Capital Market
The new legislation retained existing regulatory decisions to the extent that they did not conflict with the new laws, allowing the earlier virtual-asset framework to continue during implementation of the reformed capital-market regime.
Sources: UAE Legislation - Federal Decree-Law No. 32 of 2025, final provisions
The UAE federal capital-markets regime was reorganised through Federal Decree-Law No. 32 of 2025 Regarding the Capital Market Authority and Federal Decree-Law No. 33 of 2025 Regarding the Regulation of Capital Market. Both laws entered into force on 1 January 2026.
Sources:
UAE Legislation - Federal Decree-Law No. 32 of 2025 Regarding the Capital Market Authority
UAE Legislation - Federal Decree-Law No. 33 of 2025 Regarding the Regulation of Capital Market
Federal Decree-Law No. 32 of 2025 reconstituted the SCA as the Capital Market Authority (CMA). The CMA became the legal successor to the SCA and assumed its rights, obligations and regulatory functions.
Sources: UAE Legislation - Federal Decree-Law No. 32 of 2025
Federal Decree-Law No. 33 of 2025 gives the CMA responsibility for regulating trading in virtual assets and the financial activities, services and functions associated with them within its statutory perimeter.
Source: UAE Legislation - Federal Decree-Law No. 33 of 2025 Regarding the Regulation of Capital Market
The new legislation retained existing regulatory decisions to the extent that they did not conflict with the new laws, allowing the earlier virtual-asset framework to continue during implementation of the reformed capital-market regime.
Sources: UAE Legislation - Federal Decree-Law No. 32 of 2025, final provisions
2026 federal Virtual Assets Framework
On 13 April 2026, the CMA introduced a new federal Virtual Assets Framework. The framework comprises five core regulatory modules covering general requirements, conduct of business, alternative trading systems, AML/CFT and prudential obligations.
Sources: Capital Market Authority - Virtual Assets Framework, 13 April 2026
The framework expanded the number of federally regulated virtual-asset activities from three to eight. The activities include dealing as principal, dealing as agent, custody, arranging custody, arranging deals in investments and providing investment advice.
Sources: Capital Market Authority - Virtual Assets Framework announcement
On 13 April 2026, the CMA introduced a new federal Virtual Assets Framework. The framework comprises five core regulatory modules covering general requirements, conduct of business, alternative trading systems, AML/CFT and prudential obligations.
Sources: Capital Market Authority - Virtual Assets Framework, 13 April 2026
The framework expanded the number of federally regulated virtual-asset activities from three to eight. The activities include dealing as principal, dealing as agent, custody, arranging custody, arranging deals in investments and providing investment advice.
Sources: Capital Market Authority - Virtual Assets Framework announcement
Current regulatory structure
As of 2026, the UAE does not have a single regulator or licence covering all forms of virtual-asset and digital-asset activity. Different regulatory regimes apply according to the activity, the location from which it is conducted and whether the business operates within one of the country's financial free zones.
The CMA administers the federal capital-market framework for virtual assets and related financial activities within its statutory perimeter.
Source: UAE Legislation - Federal Decree-Law No. 33 of 2025
VARA regulates virtual-asset services throughout Dubai, including its special development zones and free zones, but excluding the DIFC.
Source: Dubai Legislation Portal - Law No. 4 of 2022, Article 3
The FSRA regulates virtual-asset activities conducted within ADGM under the financial centre's separate regulatory framework.
Source: ADGM - Crypto Asset Regulatory Framework
The DFSA regulates financial services involving Crypto Tokens in or from the DIFC under its Crypto Token regime.
Source: DFSA - Crypto Token regime
The CBUAE regulates Payment Token Services under its separate payments framework.
Source: Central Bank of the UAE - Payment Token Services Regulation
As of 2026, the UAE does not have a single regulator or licence covering all forms of virtual-asset and digital-asset activity. Different regulatory regimes apply according to the activity, the location from which it is conducted and whether the business operates within one of the country's financial free zones.
The CMA administers the federal capital-market framework for virtual assets and related financial activities within its statutory perimeter.
Source: UAE Legislation - Federal Decree-Law No. 33 of 2025
VARA regulates virtual-asset services throughout Dubai, including its special development zones and free zones, but excluding the DIFC.
Source: Dubai Legislation Portal - Law No. 4 of 2022, Article 3
The FSRA regulates virtual-asset activities conducted within ADGM under the financial centre's separate regulatory framework.
Source: ADGM - Crypto Asset Regulatory Framework
The DFSA regulates financial services involving Crypto Tokens in or from the DIFC under its Crypto Token regime.
Source: DFSA - Crypto Token regime
The CBUAE regulates Payment Token Services under its separate payments framework.
Source: Central Bank of the UAE - Payment Token Services Regulation
This article is provided for informational purposes only and does not constitute legal or regulatory advice. Businesses should seek professional advice specific to their circumstances.