The CMA's eight virtual asset activities, explained.

Where the eight activities come from

Federal Decree-Laws No. 32 and 33 of 2025 reconstituted the SCA as the Capital Market Authority from 1 January 2026, and the CMA's Virtual Assets Framework of 13 April 2026 replaced SCA Decision No. 26/RM of 2023 in full. The framework is built in five modules (General Requirements, Conduct of Business, Alternative Trading System, AML/CFT and Prudential Requirements) and defines the eight regulated activities below. Whether the framework applies to you at all is a geography and substance question covered in do I need a CMA licence?; this article assumes you are in CMA territory and asks which permissions you need.

A note on the capital figures quoted below: they are indicative ranges from published summaries. The operative requirements sit in the Prudential Requirements module, vary by sub-category and risk profile, and are confirmed with the CMA at application. Budget detail is in our CMA licence cost guide.

1. Dealing as Principal

What it captures: buying and selling virtual assets against clients from the firm's own balance sheet. The firm is the counterparty to the client's trade: it quotes a price, takes the other side, and carries the position.

Typical models: OTC desks quoting two-way prices to clients, market makers facing clients directly, dealing desks inside larger platforms, and structured product issuers hedging client flow on their own book. The dividing line that matters is the client: a desk trading purely its own treasury with no client on the other side is not dealing as principal in the regulated sense, but the moment third parties trade against the book, the perimeter is crossed. The same boundary runs through Dubai's regime, as our crypto OTC desk guide explains.

VARA equivalent: the principal limb of Broker-Dealer Services. Indicative capital: published summaries put dealing at AED 500,000 and above, confirmed at application.

2. Dealing as Agent

What it captures: receiving, transmitting or executing orders in virtual assets on behalf of clients, with the firm acting as intermediary rather than counterparty.

Typical models: retail and institutional brokerages, white-label execution providers, order routers passing client flow to exchanges or OTC desks, and copy-trading platforms that transmit client orders. Agency dealing carries less balance-sheet risk than principal dealing, but the conduct load is heavy: best execution, client classification, conflicts and order handling all live here.

VARA equivalent: the agency limb of Broker-Dealer Services. Indicative capital: within the same dealing family, AED 500,000 and above per published summaries, confirmed at application.

3. Providing Custody

What it captures: holding or controlling client virtual assets, or the private keys that control them. Control is the operative concept: a firm that can move client assets is a custodian whether or not it calls itself one.

Typical models: standalone qualified custodians, custodial wallet providers, prime brokers holding client assets, and platforms that custody the assets they trade for clients. Custody is the most heavily capitalised activity in the framework because it concentrates client asset risk: segregation, key management, and bankruptcy-remoteness of client holdings are the core of the supervisory conversation.

VARA equivalent: Custody Services, which VARA requires to sit in a separate legal entity. Indicative capital: AED 2 million and above per published summaries, varying by assets under custody, confirmed at application.

4. Arranging Custody

What it captures: bringing clients together with custody providers without the firm itself holding or controlling client assets or keys. The firm sits in the custody chain commercially, not operationally.

Typical models: platforms that onboard clients and route their assets to a third-party qualified custodian, introducers and referral arrangements with custodians, and technology providers whose commercial offer includes placing client assets with custody partners. The activity exists so that the perimeter catches the intermediary without forcing it into full custodian regulation.

VARA equivalent: no standalone category; arranging-style conduct in Dubai tends to be absorbed into Broker-Dealer or Advisory analysis. The concept will be familiar from the DFSA and FSRA rulebooks, where arranging is a longstanding regulated activity. Capital: no published range we are prepared to quote; confirm against the Prudential Requirements module at application.

5. Arranging Investment Deals

What it captures: making arrangements for others to buy, sell or subscribe for virtual asset investments, without dealing as principal or agent yourself. It is the deal-introduction and facilitation activity.

Typical models: placement agents for token offerings, platforms connecting investors with issuers, finders and introducers in primary rounds, and corporate finance boutiques running virtual asset raises. For token issuers, this is the activity their distribution partners most often trip over: the issuer's own position is a securities-law question under the substance test, while the people arranging the round need this permission.

VARA equivalent: again no standalone category; the nearest Dubai analysis runs through Broker-Dealer Services. Capital: no published range we are prepared to quote; confirm against the Prudential Requirements module at application.

6. Providing Investment Advice

What it captures: advising clients on the merits of buying, selling, holding or subscribing for virtual assets. Investment-merits advice is the trigger; general market commentary and pure legal or tax advice sit outside.

Typical models: virtual asset advisory boutiques, research houses selling recommendations, wealth managers advising on allocations without discretion, and signal services whose output amounts to personalised recommendations. Advice is the lightest activity to capitalise and the narrowest permission: no client assets, no execution, no discretion.

VARA equivalent: Advisory Services (VARA's cheapest licence at AED 100,000 paid-up capital). Indicative capital: AED 100,000 to 300,000 per published summaries, confirmed at application.

7. Portfolio Management

What it captures: managing virtual asset portfolios on a discretionary basis for clients, individually or through pooled structures.

Typical models: discretionary managers running client mandates, virtual asset fund managers, separately-managed-account platforms, and staking or yield strategies where the operator takes allocation discretion over client assets. Discretion is the boundary with advice: the moment the firm decides rather than recommends, it is managing.

VARA equivalent: VA Management and Investment Services. Indicative capital: AED 500,000 to 1 million and above per published summaries, confirmed at application.

8. Operating an MTF

What it captures: operating a multilateral trading facility: a system that brings together multiple buyers and sellers of virtual assets and matches them under non-discretionary rules.

Typical models: centralised exchanges, institutional trading venues, and, significantly, tokenised-securities venues. The framework's dedicated Alternative Trading System module covers both conventional-securities MTFs and tokenised-securities MTFs, which makes the CMA the onshore venue home for tokenised securities rather than leaving that role to ADGM alone. For issuers and platforms building tokenised bond, fund or real-world-asset markets aimed at onshore investors, that is the single most consequential design choice in the framework; the Dubai-side treatment of tokenised real-world assets is covered in our tokenised real estate guide.

VARA equivalent: Exchange Services. Indicative capital: AED 1.5 to 2 million and above per published summaries, varying by tier, confirmed at application.

The map against VARA, at a glance

All capital figures are indicative ranges from published summaries; the operative requirements sit in the Prudential Requirements module, vary by sub-category, and are confirmed with the CMA at application. The mapping is directional, not a passport: VARA also regulates lending and borrowing, transfer and settlement, and issuance as standalone categories, and the two perimeters draw the arranging line differently. Which regulator you need in the first place is a geography question: see CMA vs VARA and our CMA virtual asset licence page.

Choosing your activity mix

Activity selection is the highest-leverage decision in a CMA application. Every additional activity adds capital, systems, conduct obligations and supervisory scrutiny, and over-applying is as costly as under-applying: a platform that requests custody it could outsource, or principal dealing it does not need, buys itself the heaviest prudential treatment in the framework for optionality it may never use. The disciplined sequence is to map each revenue stream to the narrowest activity that lawfully covers it, then check the result against the application stages in our CMA application process guide and the definitions in what is a VASP?.

This article is general information as at September 2026 and is not legal advice. Capital figures for CMA virtual asset activities are indicative ranges from published summaries; the operative requirements sit in the Prudential Requirements module and are confirmed with the CMA at application. VARA references are as published in the VARA Regulations and Rulebooks at the review date.