How much does a VARA VASP licence cost in Dubai? Fees and ongoing costs
A VARA licence for one core activity costs AED 100,000 to apply for and AED 200,000 a year in supervision fees, as of October 2026. On top sit paid-up capital of AED 280,000 to AED 1,500,000 per trading activity, insurance and running costs that VARA does not publish as a price list.
KEY FACTS
| Regulator | Dubai Virtual Assets Regulatory Authority (VARA) |
|---|---|
| Application fee, core activity | AED 100,000 per activity (AED 40,000 for Advisory and Transfer and Settlement) |
| Annual supervision fee, core activity | AED 200,000 per activity (AED 80,000 for Advisory and Transfer and Settlement) |
| Extra activity in one application | Extension fee of 50% of the lower application fee |
| Paid-up capital, Exchange Services | Higher of AED 800,000 or 15% of fixed annual overheads with a VARA-licensed custodian; AED 1,500,000 or 25% otherwise |
| Net Liquid Assets | At least 1.2 times monthly operating expenses |
Source: VARA Rulebooks, Schedule 2 and Company Rulebook Part VI, as of October 2026.
What does VARA charge to apply for and keep a licence?
VARA publishes its fees in Schedule 2 of the rulebooks. Fees are set per regulated activity, so the bill depends on which activities from the VARA licensing framework a firm wants to run, not on the firm as a whole. The table shows the figures as of October 2026.
| VA activity | Application fee | Annual supervision fee |
|---|---|---|
| Exchange Services | 100,000 | 200,000 |
| Broker-Dealer Services | 100,000 | 200,000 |
| VA Management and Investment Services | 100,000 | 200,000 |
| Custody Services | 100,000 | 200,000 |
| Lending and Borrowing Services | 100,000 | 200,000 |
| Category 1 VA Issuance | 100,000 | 200,000 |
| Advisory Services | 40,000 | 80,000 |
| VA Transfer and Settlement Services | 40,000 | 80,000 |
The application fee covers one regulated activity. Each additional activity in the same application carries a licence extension fee of 50% of the lower application fee. Both are due at submission, and VARA does not process an application until the payment arrives. The annual supervision fee is payable in advance of conducting each licensed activity.
Schedule 2 also notes that VARA may add supervision fees or modify fees according to a firm's risk profile: market share, client base, complexity of the business, compliance history and the need for extra oversight. Fees charged by VARA are separate from fees charged by any other authority inside or outside the UAE. The page shows no revision date, so treat the table as the version published on the date of access and recheck it before budgeting.
When are the fees paid, and what other charges exist?
VARA's licensing page describes two stages. In the first, the applicant submits an Initial Disclosure Questionnaire to Dubai Economy and Tourism or a relevant free zone, and pays initial fees to start the review, typically about 50% of the licence application fee, to receive Approval to Incorporate. In the second, the applicant submits the full documentation and pays the remaining application fees together with the first year's supervision fees before the licence is issued. No review timeframe is stated on that page. VARA also says holders of a Legacy Operating Permit may receive up to a 50% discount on licensing fees and reduced capital requirements.
Outside the main schedule, VARA's fees announcement of 22 June 2023 lists smaller charges.
| Charge | Amount |
|---|---|
| Licence update, per amendment request | 500 |
| Licence withdrawal (leaving Dubai and winding down) | 10,000 |
| No-objection certificate for proprietary traders, annual | 1,000 |
| Whitepaper submission (plus detailed review of up to 50,000) | 5,000 |
| Written confirmation on the licensing perimeter | up to 4,000 |
The whitepaper charges apply to issuers. For a trading venue or desk, the update and withdrawal lines are the ones that matter, and only if the firm changes its licence or leaves.
How much capital must a licensed firm hold?
Capital is the largest number in the budget, but it is not a fee. Part VI.B of the Company Rulebook requires paid-up capital to be held at all times. For most activities the requirement is the higher of a fixed AED floor or a percentage of fixed annual overheads, and the floor drops when the firm uses a VARA-licensed custodian or VARA approves another arrangement at licensing.
| VA activity | With licensed custodian | All other cases |
|---|---|---|
| Exchange Services | 800,000 or 15% | 1,500,000 or 25% |
| Broker-Dealer Services | 400,000 or 15% | 600,000 or 25% |
| VA Management and Investment Services | 280,000 or 15% | 500,000 or 25% |
| Custody Services | 600,000 or 25% | |
| Lending and Borrowing Services | 500,000 or 25% | |
| VA Transfer and Settlement Services | 500,000 or 25% | |
| Advisory Services | 100,000 flat | |
A firm licensed for several activities holds the amount for each, calculated on that activity's own overheads, and reconciles paid-up capital monthly. Capital must sit in a trust account with a licensed UAE bank naming VARA as beneficiary, in a surety bond from a UAE-authorised surety company with no end date, or in another form VARA specifies in the licence. The rulebook table uses "fixed annual overheads" without defining it on that page, so the percentage branch is something to settle with VARA during licensing.
What do insurance and liquidity add to the running cost?
Two further prudential rules have a cash cost. Under Part VI.C, a firm must keep Net Liquid Assets whose surplus over current liabilities is at least 1.2 times its monthly operating expenses. Assets that count are cash and cash equivalents under recognised accounting standards, plus virtual assets referencing USD or AED approved by VARA. The firm reconciles this daily and reports to VARA monthly, and must notify VARA immediately of any shortfall in capital, liquidity, insurance or reserve assets.
Part VI.D requires professional indemnity insurance, directors' and officers' insurance, and commercial crime or similar cover for virtual assets in hot wallets, plus any other cover VARA stipulates in the licence. Insurance must be held with a regulated insurer, and a group entity may hold the policy if it names the licensed firm as an insured party. The rulebook gives no minimum insured amount: cover must be adequate to the size and complexity of the business. Premiums are therefore a quote from an insurer, not a figure any regulator can give you. The 2026 changes to VARA's rulebooks are worth reading alongside, because compliance duties keep moving.
What could a three-activity licence add up to?
Illustrative example. This is arithmetic on the published schedules for a hypothetical applicant, not a quote and not a description of any real firm. Take a firm that applies for Exchange, Broker-Dealer and VA Management and Investment Services together, using a VARA-licensed custodian, with overheads low enough that the AED floors apply.
| Item | Working | AED |
|---|---|---|
| Application and extension fees | 100,000 + 50,000 + 50,000 | 200,000 |
| Annual supervision fees | 3 x 200,000 | 600,000 |
| Paid-up capital floors (held, not spent) | 800,000 + 400,000 + 280,000 | 1,480,000 |
Fees paid to VARA in the first year come to AED 800,000, and AED 1,480,000 of capital must sit in a trust account or bond. Insurance, Net Liquid Assets, staff, technology, premises and Dubai Economy and Tourism or free-zone charges come on top and are not in the table because no regulator publishes them as one schedule. Without a licensed custodian the capital floors would be AED 2,600,000 on the same activities.
Which costs does VARA not publish?
The licence fee schedule is a small share of what operating costs. Categories to price from your own quotes include the following.
- Dubai Economy and Tourism or free-zone incorporation and trade licence charges, which are set by those bodies and are separate from VARA's fees.
- Insurance premiums for the three mandatory policy types.
- The cost of the rulebook-mandated functions: compliance, risk, technology and information security, and market conduct controls under the four compulsory rulebooks.
- Custody arrangements, since using a VARA-licensed custodian lowers the capital floor but carries its own charges.
- Funding cost on the capital that is locked in trust or bond.
This is why published licence fees understate the true cost of entry. VARA does not state processing times on its licensing page either, so the time between paying the first instalment and receiving a licence is also uncertain.
What does the cost of a licence mean for someone choosing a counterparty?
A desk that carries these costs has a regulator, capital requirements and insurance duties behind it, which is part of why price is not the only measure. You can confirm the activities a firm holds in the public register, as the guide to checking a VARA licence explains. IWGT is operated by OFZA Fintech Virtual Asset Exchange Services LLC, VARA licence VL/24/12/002, and its licence details are on the licence section of the home page. Its spread bands of 0.08% to 0.40% by ticket size are on the published pricing.
FAQ
Is the VARA application fee refundable?
VARA's Schedule 2 states that fees are due at submission and the application is not processed until they are paid. VARA's fees announcement of 22 June 2023 says nothing on refunds, so ask VARA in writing before paying if a refund matters to you.
Do you pay VARA fees once or every year?
Both. The licence application fee is paid during the application. The annual supervision fee is payable in advance of conducting each licensed activity, and VARA lists it per regulated activity.
Is a licence with several activities cheaper per activity?
Partly. Schedule 2 sets a licence extension fee of 50% of the lower application fee for each additional activity. The annual supervision fee still applies to each regulated activity, and paid-up capital is calculated for each activity.
Does the paid-up capital count as a cost?
It is not a fee paid to VARA. It is capital the firm must hold at all times in a UAE bank trust account or a surety bond naming VARA as beneficiary, so it is tied up rather than spent. The cost is the funding and the bond or trust arrangements.
Can VARA charge more than the published fees?
Yes. Schedule 2 says VARA may impose additional supervision fees or modify fees based on a firm's risk profile, including market share, client base, business complexity and compliance history.
Trade with a desk that holds a VARA licence
IWGT is a VARA-licensed OTC desk for USDT in Dubai. Request a quote to see pricing for your ticket size and the onboarding steps.
SOURCES
- VARA Rulebooks, Schedule 2: Supervision and Authorisation Fees, accessed 24 October 2026.
- VARA, Clarification and Further Information on Fees (22 June 2023), accessed 24 October 2026.
- VARA, Licence Applications, accessed 24 October 2026.
- VARA Company Rulebook, Part VI.B Paid-Up Capital, accessed 24 October 2026.
- VARA Company Rulebook, Part VI.D Insurance, accessed 24 October 2026.
- VARA Company Rulebook, Part VI (Net Liquid Assets, Reserve Assets, notifications), accessed 24 October 2026.
- VARA public register, accessed 24 October 2026.
- IWGT published pricing bands, October 2026.
This guide is informational and is not legal, tax or investment advice, nor an invitation to buy or sell any virtual asset. Rules and figures are as of October 2026 — re-check the sources before acting. Virtual assets may lose their value in full or in part and are subject to extreme volatility.