VARA Token Issuance: Issuing Regulated Virtual Assets in Dubai
VARA's token issuance framework covers two categories with different requirements. Category 1 requires a full VARA licence; Category 2 requires VARA prior approval. We manage both.
Tokens backed by fiat currency reserves. Full VARA Licence required. Additional requirements under ANNEX 1 of the VA Issuance Rulebook:
1:1 fiat reserve backing
Reserves in segregated UAE bank accounts
Regular reserve attestation by approved auditor
Redemption rights for token holders at par value
Category 2 All Other Virtual Assets
Any VA that is not Category 1 and not an Exempt VA. VARA prior approval required (not a full licence). Requirements:
VARA Issuance Approval Form (Category 2)
Whitepaper: purpose, use, technical architecture, rights of holders, risk factors, issuer governance, use of proceeds
AML/CFT compliance
Technical, information security, data privacy, and cryptographic controls
No anonymity-enhanced tokens permitted
What VARA Prohibits
Algorithmic stablecoins (no fiat reserve backing)
Anonymity-enhanced tokens (e.g. Monero, Zcash)
Any token issuance or marketing before VARA whitepaper approval
Material changes to an approved token without VARA re-approval (re-submission fee applies)
Key Requirements for Category 1
Capital
As specified in the VA Issuance Rulebook (separate from standard activity capital table).
Compulsory Rulebooks
Company Rulebook, Compliance and Risk Management Rulebook, Technology and Information Rulebook, Market Conduct Rulebook — plus FRVA Rules in Annex 1 of the VA Issuance Rulebook.
Responsible Individuals
2 RIs — UAE residents, full-time, VARA-approved.
What We Do for You
Token classification
Category 1 vs 2, regulatory treatment, potential securities law implications under UAE law.
Whitepaper preparation
VARA-compliant whitepaper covering all required disclosures.
AML/KYC for token sale
Investor KYC/AML procedures for the token offering process.
Reserve structure (Category 1)
Fiat reserve holding structure, UAE bank account setup, attestation framework design.
VARA engagement
Whitepaper review and approval process managed directly with VARA.
Post-issuance compliance
Ongoing reporting, reserve attestations (Category 1), material change procedures.
Frequently Asked Questions
No. Any public communication about an upcoming token — social media posts, community announcements, private investor communications — before VARA whitepaper approval is a violation of the Market Conduct Rulebook.
Material changes require a whitepaper re-submission to VARA. VARA reviews, assesses, and approves the change before it takes effect. A fee applies.
Tokens with equity-like rights, profit-sharing features, or investment contract characteristics may also fall under CMA or ADGM/FSRA securities regulation, independently of VARA's framework. We conduct a full regulatory classification analysis.
If the issuing entity is in Dubai or the token is offered to clients in the UAE, VARA's framework applies regardless of which blockchain the token is issued on.
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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.