VARA VASP registration in Dubai: documents and corporate paperwork checklist
A VARA VASP application runs in two stages. Stage 1 is an Initial Disclosure Questionnaire leading to an Approval to Incorporate; Stage 2 is the full document set, which VARA lists as 18 corporate items, from the incorporation certificate and UBO list to a wind-down plan, as of October 2026.
KEY FACTS
| Regulator | VARA (Dubai, outside the DIFC) |
|---|---|
| Filing route | Dubai Economy and Tourism (mainland) or a Dubai free zone other than DIFC |
| Stage 1 fee | Typically 50% of the licence application fee |
| Stage 2 payments | Remaining application fee plus first year's supervision fees |
| Responsible Individuals | Two, full-time, UAE resident or UAE passport holder |
| Net Liquid Assets | At least 1.2 times monthly operating expenses |
Source: VARA licence applications page and Company Rulebook (rulebooks.vara.ae), accessed October 2026.
This guide is for readers who want to understand what stands behind a VARA licence in Dubai, for example when judging a counterparty. It is not a filing manual, and VARA's own guidance is the authority for any real application.
How does a VARA VASP application work?
A new firm applies in two stages: first for an Approval to Incorporate, then for the VASP Licence itself. As of October 2026, VARA states that the firm is not permitted to carry on virtual asset activities between those stages.
| Stage | What the applicant does | Payment | Outcome |
|---|---|---|---|
| 1. Approval to Incorporate | Submits an Initial Disclosure Questionnaire to Dubai Economy and Tourism or a free zone, plus any extra documents requested | Typically 50% of the licence application fee | Approval to Incorporate; no virtual asset activity yet |
| 2. VASP Licence | Submits documents under VARA's guidance and receives VARA's feedback | Remaining application fee plus first year's supervision fees | Licence, possibly with operational conditions |
The fee amounts sit in Schedule B of the Virtual Assets and Related Activities Regulations 2023; VARA's page does not state them or any processing time.
Authorisation is also per activity. The Regulations require a Licence for each VA Activity an entity conducts in the Emirate, so a firm that wants exchange and broker-dealer services applies for both.
Which corporate documents does VARA list?
VARA publishes a non-exhaustive list of 18 items under Corporate Structure and Governance, and says it may ask for more. The table groups them; VARA's page does not assign each item to a specific stage.
| Group | Items on VARA's list |
|---|---|
| Entity and ownership | Certificate of entity incorporation; list of Ultimate Beneficial Owners; organisational structure; close links and associated entities analysis |
| People | Fit and Proper confirmations; key personnel details (job descriptions, CVs, passport copies); succession plan |
| Governance and business | Governance framework; local entity website; Regulatory Business Plan |
| Money and resilience | Source of funds evidence; financial projections; group and entity financial statements; proof of paid-up capital; available capital locked up; reserve account report; insurance certificates; wind-down plan |
Eight of the 18 items concern money and resilience, which is why a licence entry implies far more than a company registration.
VARA's page also shows headings for Risk and Compliance, Technology and Other, with no items listed under them. Policies in those areas come from the compulsory rulebooks that every licensed entity must follow, so the live guidance should be read before assuming the list above is complete.
What does the Company Rulebook require behind the paperwork?
The Company Rulebook turns several of those documents into standing obligations. Each item below is a rule a licensed VASP has to keep meeting after the licence is granted, as of October 2026.
- Dubai legal entity (Rule I.A.2). The VASP must maintain a legal entity in Dubai, in a form approved by a commercial licensing authority there.
- Transparent ownership (Rules I.A.3 to I.A.5). The chain of ownership, delegated authority and voting powers must be clear enough for VARA to identify Controlling Entities and UBOs. Trusts, nominee arrangements and DAOs need extra disclosure, and a material structure change needs VARA's written approval beforehand.
- Fit and proper board (Rule I.B.1). Each board member is assessed by the VASP and approved by VARA, and the board re-confirms fitness at least annually.
- Two Responsible Individuals (Rule I.C). Both must be full-time employees, UAE residents or UAE passport holders, and approved by VARA.
- Company Secretary (Rule I.E). The secretary is independent of senior management and reports to the board; an external firm counts as outsourcing under Part IV.
How does VARA judge fit and proper people?
Part III of the Company Rulebook sets five tests for any individual who must be a Fit and Proper Person: qualifications, honesty and integrity, relevant virtual asset or sector experience, understanding of the regulatory framework, and financial soundness. VARA assesses case by case and will not approve someone it is not satisfied about.
That explains why the checklist asks for CVs, passport copies and job descriptions per key person. The same rules allow VARA to approve an individual who fails one element, after weighing all relevant factors, so the test is a judgement and not a scorecard.
What capital and insurance evidence is required?
Paid-Up Capital under Rule VI.B.1 is the higher of a fixed floor and a share of fixed annual overheads, and it depends on the activity and on custody arrangements. As of October 2026 the Company Rulebook sets these amounts.
| Activity | With a VARA-licensed custody VASP | All other cases |
|---|---|---|
| Advisory Services | AED 100,000 | AED 100,000 |
| VA Management and Investment | Higher of AED 280,000 or 15% of overheads | Higher of AED 500,000 or 25% of overheads |
| Broker-Dealer | Higher of AED 400,000 or 15% of overheads | Higher of AED 600,000 or 25% of overheads |
| Exchange | Higher of AED 800,000 or 15% of overheads | Higher of AED 1,500,000 or 25% of overheads |
Overheads means the fixed annual overheads of that activity only; a multi-activity VASP holds the amount for each activity.
The capital must sit at all times in a trust account with a UAE licensed bank naming VARA as beneficiary, in a surety bond naming VARA as beneficiary, or in another form VARA specifies in the Licence. It is reconciled monthly.
Two further tests apply. Net Liquid Assets must stay at or above 1.2 times monthly operating expenses, reconciled daily and reported to VARA monthly. Insurance (Rule VI.D.1) covers professional indemnity, directors' and officers' cover, and commercial crime or similar cover for virtual assets in hot wallets, with amounts set in the Licence conditions.
Illustrative example (hypothetical numbers, not a quote). An Exchange applicant using a VARA-licensed custody VASP has fixed annual overheads of AED 4,000,000 for that activity. 15% is AED 600,000, which is below the AED 800,000 floor, so AED 800,000 applies. Without such custody, 25% is AED 1,000,000, below the AED 1,500,000 floor, so AED 1,500,000 applies.
What does this checklist mean for someone vetting a counterparty?
The submitted documents are not public, so a reader cannot audit an applicant's file. What is public is the register entry, and the practical test is the one in our guide on checking a VARA licence in one minute: licence number, entity name and the exact activities listed.
The checklist helps with the questions that follow. Does the licensed entity match the company that will receive funds, and does the activity list cover what is being offered? The broader OTC desk verification checklist turns those questions into steps. For reference, the licence of our own entity is shown in the licence section of the main page.
What happens after the documents are filed?
VARA gives feedback directly on the Stage 2 submission, the applicant pays the remaining fees and first-year supervision fees, and VARA then issues the Licence, which may carry operational conditions. VARA's page gives no processing time, so none should be assumed.
Separate from this corporate file is the paperwork a licensed provider asks of its own clients, such as ID and company documents. That list is published in the onboarding section of our main page and is not the same thing as the application described here.
FAQ
Can a company start trading while its VARA application is pending?
No. VARA states that after Stage 1 the firm is not permitted to carry on virtual asset activities. Only a granted Licence authorises an activity, and a Licence is issued per activity, as of October 2026.
Is the VARA document list fixed?
No. VARA describes its list as non-exhaustive and says it may require further documentation. The Stage 2 submission follows the guidance VARA issues once the Approval to Incorporate is received.
Do all VASPs need the same capital?
No. Paid-Up Capital under Company Rulebook Rule VI.B.1 depends on the activity and on whether a VARA-licensed custody VASP is used. Each licensed activity carries its own requirement, as of October 2026.
Where is a VARA VASP application filed in Dubai?
Applications go through Dubai Economy and Tourism for mainland firms, or through a Dubai free zone other than DIFC. DIFC is excluded from this route, as of October 2026.
Can a reader check what an applicant filed?
No. The submitted documents are not public. What a reader can check is the VARA public register entry: licence number, entity name and licensed activities.
Questions about dealing with a licensed desk
IWGT is operated by OFZA Fintech Virtual Asset Exchange Services LLC, VARA licence VL/24/12/002. All-in spread 0.08% to 0.40% by size, published openly.
SOURCES
- VARA: Licence Applications (stages, filing route, document list), accessed 22 October 2026.
- VARA Rulebooks: Licensing Requirements, Part IV.A, accessed 22 October 2026.
- Company Rulebook: Company Ownership Structure (Rules I.A.1 to I.A.5), accessed 22 October 2026.
- Company Rulebook: The Board and Responsible Individuals, accessed 22 October 2026.
- Company Rulebook: Fit and Proper, General Principles, accessed 22 October 2026.
- Company Rulebook: Paid-Up Capital, Net Liquid Assets and Insurance, accessed 22 October 2026.
This guide is informational and is not legal, tax or investment advice, nor an invitation to buy or sell any virtual asset. It does not promise or imply that any application will succeed. 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.