Published summaries of the CMA Virtual Assets Framework indicate paid-up capital from roughly AED 100,000 to 300,000 (advice-only) up to AED 2 million and above (custody), plus liquid resources covering six months of operating expenses. These are indicative planning figures only: the operative capital and fee requirements sit in the framework's Prudential Requirements module, vary by sub-category, and are confirmed with the CMA at application.
Why CMA cost questions have two answers
The CMA Virtual Assets Framework, issued on 13 April 2026 and building on Decision No. 4/R.M/2026, is organised into five modules: General Requirements, Conduct of Business, Alternative Trading System, AML/CFT and Prudential Requirements. Everything that determines your capital budget lives in the last of those. Unlike VARA, whose Schedule 2 fees and Company Rulebook capital figures are published line by line, the CMA's operative virtual asset prudential figures vary by sub-category and are confirmed with the regulator at application. Any article, ours included, that quotes you a single hard number for a CMA virtual asset activity is ahead of the source material. What follows are the indicative ranges from published summaries, the one fee set we can verify against the CMA fee sheet, and the cost drivers that do not change whichever number the module produces.
Indicative capital ranges, activity by activity
Published summaries of the framework put the capital ranges for the main activity families as follows. Treat every line as indicative: the operative requirement sits in the Prudential Requirements module and varies by sub-category, projected assets under custody or management, and operational risk profile.
| Activity family | Indicative capital (published summaries) |
|---|---|
| Advisory (Providing Investment Advice) | AED 100,000 to 300,000 |
| Dealing (as Principal or as Agent) | AED 500,000 and above |
| Portfolio Management | AED 500,000 to 1 million and above |
| Exchange / Operating an MTF | AED 1.5 to 2 million and above (varies by tier) |
| Providing Custody | AED 2 million and above (varies by assets under custody) |
The framework regulates eight virtual asset activities in total; the arranging-style activities (Arranging Custody, Arranging Investment Deals) have no published range we are prepared to quote, and should be budgeted only against the module itself. The shape of the table will look familiar to anyone who has budgeted a licence elsewhere in the UAE: capital scales with custody risk, and holding client assets costs the most.
The liquid resources buffer: six months of opex
Per published summaries, the framework requires licensees to hold liquid resources covering at least six months of operating expenses on top of base capital. For a lean advisory model this is a modest add-on; for an exchange or custodian with a 20-person payroll, Emirati hosting infrastructure and insurance, the six-months buffer can exceed the headline capital requirement itself. It is the line most first-draft budgets miss, and the CMA will read your financial projections against it.
The one fee set we can verify
The CMA publishes exact fees for its securities-side licence categories, and those give the best available signal of how the regulator prices authorisation. The verified example is the Fifth Category (Arranging and Advice), the securities-side home of Promotion and Introducing: AED 8,000 in application fees plus AED 20,000 in licence fees, a total of AED 28,000, against paid-up capital of AED 500,000 (roughly USD 136,000, held as the company's own equity rather than a regulator deposit), per the CMA fee sheet. We cover that category in full in our Category 5 guide. It is a securities-side category, not a virtual asset framework activity, but it is the one CMA fee set with published, verifiable figures; fees for the eight virtual asset activities are confirmed with the CMA at application.
The cost drivers that are certain, whatever the module says
Three budget lines apply regardless of where the prudential figures land, and in our experience they decide whether a CMA application is viable more often than the capital number does:
- People. The framework requires accredited senior functions, compliance and AML/CFT capability, and fit-and-proper individuals with real UAE presence. Senior compliance hires in the UAE are a competitive market, and the payroll runs from the pre-application stage, not from licence grant.
- Premises and substance. A federal licence needs a UAE establishment: office space, local governance, audited financials and the operational infrastructure the business plan promises.
- Advisory and application costs. The application is a full regulatory programme: business plan, policy suite, prudential build, technology and custody documentation, and query rounds with the CMA's team. Our walkthrough of the stages is in the CMA application process guide.
How the budget compares with VARA
Dubai's VARA regime is the natural benchmark, and its numbers are fully published. VARA charges AED 40,000 application and AED 80,000 annual supervision for Advisory and VA Transfer and Settlement, and AED 100,000 application and AED 200,000 annual supervision for every other activity, with each additional activity adding 50 percent of the lower application fee. VARA paid-up capital runs from AED 100,000 (Advisory) to AED 1.5 million (Exchange without a VARA-licensed custodian; fiat-referenced token issuance), held in a UAE bank trust account with VARA as beneficiary, plus net liquid assets of at least 1.2 times monthly operating expenses. Full detail in our VARA licence cost guide.
Set side by side: the CMA's indicative capital ranges start in similar territory at the advice end and run higher at the custody end, its liquid resources buffer is expressed in months of opex rather than a 1.2x multiple, and its virtual asset fee schedule is the piece VARA applicants take for granted that CMA applicants must confirm. The decision between the two regulators is rarely a fee comparison anyway: it is a jurisdiction question, which we cover in CMA vs VARA and on our CMA virtual asset licence page.
How to budget a CMA application in practice
The sequencing that works: first confirm the perimeter (do you need the licence at all, and for which of the eight activities: see do I need a CMA licence?); second, confirm the operative capital, liquid resources and fee figures for your exact sub-category directly with the CMA at pre-application; third, build the people and premises budget around the confirmed numbers. Committing capital against indicative ranges is how applicants end up recapitalising mid-application. The cost of getting the perimeter wrong is a different order of magnitude again: unlicensed activity sits under Article 71 of Federal Decree-Law No. 33 of 2025, covered in our CMA fines article.
This article is general information as at September 2026 and is not legal advice. CMA virtual asset 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. VARA figures are as published in the VARA Regulations and Rulebooks at the review date. The Category 5 figures are per the CMA fee sheet at the review date.
