Crypto company registration and VARA licence in the UAE (Dubai)

In short:

• Regulator: VARA licenses virtual asset activity in or from Dubai, excluding the DIFC; each activity is applied for separately.
• Company: a mainland company with DET or a company in a Dubai free zone; VARA prefers an LLC or an FZ CO.
• Stages: Initial Disclosure Questionnaire, Approval to Incorporate, licence application, VASP licence.
• People and place: two Responsible Individuals who live in the UAE and work full time; a physical office in Dubai.
• Tax: corporate tax 0% up to AED 375,000 and 9% above; 0% on qualifying income for a Qualifying Free Zone Person; VAT 5%.

Who this route suits

A Dubai company with a VARA licence suits a virtual asset business that wants a regulated base in the Gulf: an exchange or broker-dealer, a custody provider, an asset manager, a transfer and settlement service, a lending platform, a token issuer, an NFT marketplace or an advisory firm. Founders choose it for direct access to clients in the UAE and the wider region, a resident team in Dubai and the UAE tax framework.

The route asks for real presence: people in Dubai, an office and capital set by VARA's Company Rulebook. For a European client base the MiCA CASP licence in the EU is usually the better fit, and the jurisdiction comparison sets Dubai against the other open regimes.

Which VARA activities need a licence

VARA licenses eight activities, and each one is applied for explicitly:

• Advisory services;
• Broker-dealer services;
• Custody services;
• Exchange services;
• Lending and borrowing services;
• Management and investment services;
• Transfer and settlement services;
• Virtual asset issuance, Category 1.

Some structures need extra steps. Custody is carried on by a distinct legal entity with its own standalone licence. Proprietary trading requires a separate company and a VARA No Objection Certificate. Issuing a Category 2 virtual asset requires VARA approval with a whitepaper and AML/CFT compliance. An NFT marketplace applies for an exchange or broker-dealer licence, or both. Every VASP also follows the four compulsory rulebooks (Company; Compliance and Risk Management; Technology and Information; Market Conduct) and the rulebook of each licensed activity.

Free zone or mainland

VARA accepts applications through Dubai Economy and Tourism (DET) for mainland companies and through any free zone in Dubai except the DIFC. The licence is the same; the company, the market it may serve and the tax position differ.

Dubai and the other emirates

VARA's licence covers virtual asset activity in or from the emirate of Dubai. A company placed in another emirate or in Abu Dhabi Global Market works under the rules of that emirate or financial free zone, so the place of incorporation is decided together with the licence. We usually start from Dubai for this reason: the company licence and the VARA licence follow one path, and the office, the team and the bank account sit in the same emirate.

VARA licensing steps

1. Model and structure. Which of the eight activities you carry on, whether custody or proprietary trading needs a separate company, mainland or free zone, and the legal form.
2. Initial Disclosure Questionnaire. Filed with DET or the free zone, with a business plan and details of the beneficial owners and senior management. The initial fee, typically 50% of the licence application fee, starts the review.
3. Approval to Incorporate. VARA issues the ATI. With it you complete the incorporation, rent the office and bring staff on board. Virtual asset activity is still closed at this stage.
4. Licence application. The documentation set out in VARA's guidance, then feedback, meetings and interviews. The remaining part of the application fee and the first year's supervision fee are paid.
5. VASP licence. VARA issues the licence, which may carry operational conditions. VARA may also refuse the ATI or the licence.

People, office and documents

VARA sets no nationality restrictions for applicants. The applicant is a company licensed by DET or a Dubai free zone, and VARA states that an LLC or FZ CO is preferable for the sector; sole proprietorships are refused.

• Two Responsible Individuals. Each is a full-time employee of the VASP, a Fit and Proper Person approved by VARA, and a UAE resident or UAE passport holder.
• Office in Dubai. A physical presence in Dubai is required. All activities except advisory need a private office. VARA sets no minimum size; the licensor of the company does.
• Documents. VARA's non-exhaustive list includes the certificate of incorporation, the list of ultimate beneficial owners, fit and proper confirmations, source of funds, organisational structure and governance framework, a local website, CVs, passports and job descriptions of key personnel, the regulatory business plan, financial projections and statements, proof of paid-up capital, capital lock-up, a reserve account report, insurance, succession and wind-down plans, and a close-links analysis.
• Capital. Paid-up capital and reserves follow VARA's Company Rulebook and depend on the activity; we confirm the amount for your activity in writing.

Residence visas for founders and staff

The Responsible Individuals must live in the UAE, so residence permits are part of the plan from the start. A foreign national completes the residency procedures within 60 days of entering the UAE, and the residence permit is issued with an Emirates ID; fingerprints are given in person from the age of 15. In Dubai, an investor or partner can hold a green residence permit for up to five years. The ten-year Golden Visa for investors starts at AED 2,000,000, for example as a deposit, company capital or a partnership stake.

Bank account

The Central Bank of the UAE rulebook says banks should seek to open an account within 3 business days for applicants they assess as low risk. Dubai reports that the Dubai Unified Licence cut the average time to open a business account from 65 days to five. These are targets and averages. A virtual asset company should expect enhanced due diligence, with requests for the ATI or the licence, the ownership chart, source of funds and the AML framework. We prepare this pack together with the VARA file so the bank sees the same story as the regulator.

Tax and reporting

• Corporate tax. 0% on taxable income up to AED 375,000 and 9% above it, for tax periods starting from 1 June 2023.
• Qualifying Free Zone Person. 0% on qualifying income and 9% on other taxable income. The conditions include adequate substance in the UAE, qualifying income, no election for the standard regime, transfer pricing compliance and audited financial statements. Non-qualifying revenue must stay within 5% of total revenue or AED 5,000,000, whichever is lower. Whether crypto income qualifies depends on the activity lists of Ministerial Decision 229/2025 and is checked for each model. Small business relief is unavailable to a Qualifying Free Zone Person.
• Corporate tax registration. A company incorporated on or after 1 March 2024 registers within three months of incorporation. Late registration carries a penalty of AED 10,000, waived if the first return is filed within seven months after the first tax period. Returns and payment are due within nine months after the tax period, and records are kept for seven years.
• VAT. 5%; registration is mandatory from AED 375,000 of taxable supplies and voluntary from AED 187,500.
• Beneficial owners. Companies keep a register of beneficial owners holding 25% or more, file it within 60 days of licensing and update it within 15 days of a change.

Risks of setting up alone

A free zone company such as DMCC can be set up in about ten working days. The VARA licence goes through two regulatory stages with meetings and interviews, and mistakes made at the start carry through every later step.

• Starting operations too early. Activity before the licence, or on the strength of the ATI, is unlicensed activity. VARA's enforcement tools include cease and desist orders, fines, licence suspension and closure of the entity.
• The wrong structure. Custody bundled into the trading company, a sole proprietorship or a free zone with the wrong activity list sends the file back to the first stage.
• People who fail the test. Responsible Individuals who live abroad, work part time or fall short of the fit and proper standard stop the application at interview.
• An office that does not fit the activity. A flexi-desk works for some licensors and fails VARA's private office requirement for most activities.
• Refusal. VARA may refuse the ATI or the licence. A file built around the rulebooks from the first stage is the best protection.
• Tax status lost. A free zone company that misses substance, audit or de minimis conditions pays 9% on all income; a missed registration deadline costs AED 10,000.
• A bank that says no. An account application filed without the regulatory pack invites refusals and long delays.

Under a contract with Blocons these risks sit with a team that has the work in writing: scope, timeline, fee and who answers each request.

How Blocons works on a VARA licence

1. Business model review at a consultation (30 min — €100; written — from €200): the VARA activities, mainland or free zone, separate entities, the tax regime.
2. Company set-up with DET or the free zone and the Initial Disclosure Questionnaire with the business plan and the ownership file.
3. After the ATI: office, Responsible Individuals, residence visas, the rulebook documents and the bank pack.
4. Licence application, meetings and interviews with VARA until the licence; then renewals, tax registration and reporting.

The project is quoted in writing after the review.

• VARA, licensor and tax in one file. We prepare the company licence, the VARA application and the corporate tax position together, so the business starts with one coherent file.
• We take on regulators and banks. Information requests, remarks, bank refusals, delays: we respond, revise, resubmit or appeal at no extra charge until the matter is closed.
• A senior specialist on every file. An experienced specialist leads your project personally, and the same people stay on it even when the review takes months.
• Your project stays yours. Information about founders, beneficial owners, wallets and deals reaches neither competitors nor third parties. We disclose only what the law or the procedure requires, and the contract says so.

FAQ

Do I need a VARA licence to run a crypto company in Dubai?

Yes, any virtual asset activity carried on in or from Dubai, outside the DIFC, needs a VARA licence, registration or a No Objection Certificate before it starts. Each of the eight licensed activities, from advisory to exchange and custody, is applied for separately.

Free zone or mainland: where should a crypto company be set up?

Both routes lead to the same VARA licence. The application starts with Dubai Economy and Tourism for a mainland company or with a Dubai free zone, except the DIFC. A free zone company that wants to serve the mainland market needs a DET licence or permit and separate accounts. The choice depends on your clients, your office and the tax regime you plan to use.

How does the VARA licensing process work?

Two stages. First an Initial Disclosure Questionnaire goes to DET or the free zone with a business plan and details of beneficial owners and senior management, and part of the application fee is paid. VARA issues an Approval to Incorporate, which lets you incorporate, rent an office and hire staff. Then you file the licence application with the rulebook documents, attend meetings and interviews, pay the remaining fees and receive the VASP licence.

Who are the Responsible Individuals?

Every VASP appoints two Responsible Individuals. Each must be a full-time employee of the company, a Fit and Proper Person approved by VARA, and a UAE resident or a UAE passport holder. Planning these two people early saves months at the licence stage.

Do I need an office in Dubai?

Yes, VARA requires a physical presence in Dubai to carry on virtual asset activities from Dubai. Activities other than advisory need a private office. VARA sets no minimum size; the size rules come from DET or the free zone that licenses the company.

How much does a VARA licence cost?

VARA fees are set in the fee schedule of the Virtual Assets and Related Activities Regulations 2023 and depend on the activity: part is paid at the start of the review, the rest with the first-year supervision fee. Company set-up, office and capital come on top. Our consultation costs €100 for 30 minutes, a written review starts at €200, and the project is quoted in writing after the review.

What tax does a crypto company pay in the UAE?

Corporate tax is 0% on taxable income up to AED 375,000 and 9% above it. A Qualifying Free Zone Person pays 0% on qualifying income and 9% on the rest, provided it keeps adequate substance, audited financial statements and transfer pricing records. Whether crypto income counts as qualifying depends on the activity lists of Ministerial Decision 229/2025 and is checked for each model. VAT is 5%.

How long is a VARA licence valid?

The licence is annual and is renewed for 12 months at a time. VARA sends the renewal notice 90 days in advance, and the annual supervision fee is paid at renewal. Licensed firms appear on the VARA public register.

Can a foreign founder own the company?

Yes, VARA sets no nationality restrictions for applicants; the applicant is a company licensed by DET or a Dubai free zone, preferably an LLC or an FZ CO, and sole proprietorships are refused. For mainland companies, Federal Decree-Law 32/2021 removed the rule on an Emirati majority partner, except for activities on the strategic-impact list.

Related pages

• Crypto licences by country
• Countries we work in
• Choosing a jurisdiction for a crypto project
• Registration of companies
• Opening bank accounts
• MiCA CASP licence in the EU
• Crypto licensing in Singapore

Sources

• VARA, licence applications: IDQ, ATI and VASP licence stages, rulebooks
• VARA, licensed activities
• VARA, frequently asked questions: Responsible Individuals, office, renewal, legal form
• VARA, public register of licensed firms
• DMCC, set up a new business
• Dubai Media Office, free zone to mainland operating permit (Executive Council Resolution 11/2025)
• UAE Ministry of Finance, corporate tax
• Ministerial Decision 229/2025, qualifying and excluded activities
• Federal Tax Authority, corporate tax registration timeframes
• Federal Tax Authority, VAT registration
• Central Bank of the UAE rulebook, account opening
• ICP, UAE Golden residency

Facts checked against the sources above on 15 November 2026. This page is general information about the regulatory framework; requirements for a specific business depend on its model.