TL;DR: Issuing an Asset-Referenced Virtual Asset (ARVA) - a token representing rights to a real-world asset - in Dubai mainland requires a VARA Category 1 VA Issuance license. The rulebook governing this took effect on 19 June 2025, and requires a whitepaper, monthly reserve disclosures, and paid-up capital equal to the higher of AED 1,500,000 or 2% of the average market value of reserve assets over the preceding 24 months.
What ARVA Means
Asset-Referenced Virtual Asset (ARVA) is a category of virtual asset under VARA's framework representing rights to a real-world asset, such as real estate or commodities. It is one of two token types covered by Category 1 VA Issuance - the other being FRVA (Fiat-Referenced Virtual Assets, i.e. stablecoins).
Capital Requirements
ARVA issuers must maintain paid-up capital equal to the higher of two amounts: AED 1,500,000, or 2% of the average market value of reserve assets over the preceding 24 months. This differs from the FRVA (stablecoin) formula, where capital is calculated as AED 1,500,000 plus 2% of the value of available supply an additive, not a higher-of, calculation.
Ongoing Obligations
A published whitepaper, together with a separate Risk Disclosure Statement published in the same location
Monthly disclosure of reserve holdings, with an independent audit every six months
Compliance with VARA's four compulsory rulebooks: Company, Compliance and Risk Management, Technology and Information, and Market Conduct
Licensing Process and Timeline
The process runs in two formal stages: an Initial Disclosure Questionnaire (IDQ) submitted through VARA Connect leading to an Approval to Incorporate (ATI), followed by a full VASP License application. The ATI does not authorise any virtual asset activity — it only permits the applicant to complete incorporation, lease office space, and begin operational setup. Multiple independent legal sources report the ATI stage typically taking one to three months from IDQ submission, with the full end-to-end process — from initial application to full VASP License — commonly cited in the range of six to twelve months, depending on business complexity and documentation readiness. VARA's own licensing page describes the two-stage structure but does not publish one guaranteed processing time for every applicant, so any timeline should be treated as an industry planning estimate rather than an official SLA.
AML Zone Service
AML Zone prepares VARA Category 1 VA Issuance applications, including whitepaper drafting support, reserve/custody structuring advice, and AML/KYC compliance frameworks for ARVA issuers.
Frequently Asked Questions
Both fall under Category 1 VA Issuance. ARVA tokens reference real-world assets such as real estate or commodities; FRVA tokens are stablecoins referencing fiat currency. Their capital formulas differ: ARVA uses a higher-of calculation, FRVA uses an additive one.
The updated Virtual Asset Issuance Rulebook, which introduced the ARVA category, came into effect on 19 June 2025.
Industry sources commonly cite six to twelve months end-to-end, though VARA does not publish a guaranteed timeframe; well-prepared applications with complete documentation tend to move faster.
No. The ATI only allows the applicant to incorporate the legal entity and complete operational setup - it does not authorise any virtual asset activity, including token issuance, until the full VASP License is granted.
A published whitepaper is required for Category 1 VA Issuance generally, covering both ARVA and FRVA token types, describing the token structure and reserve arrangements.
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Please note: We do not provide any personalized investment advice, token selection guidance, or transaction recommendations. AMLzone is a compliance consultancy and project management services provider, not a Virtual Asset Advisor.