VARA charges AED 40,000 application and AED 80,000 annual supervision for Advisory and for VA Transfer and Settlement, and AED 100,000 application and AED 200,000 annual supervision for every other activity, plus 50 percent of the lower application fee per additional activity (Schedule 2). On top sits paid-up capital from AED 100,000 to AED 1.5 million by activity, net liquid assets of at least 1.2 times monthly operating expenses, insurance, office space and the people VARA requires.
What VARA itself charges
Schedule 2 of the Virtual Assets and Related Activities Regulations sets two fee tiers. Advisory Services and VA Transfer and Settlement Services pay AED 40,000 on application and AED 80,000 in annual supervision fees. Every other activity (Broker-Dealer, Custody, Exchange, Lending and Borrowing, VA Management and Investment Services, and Issuance) pays AED 100,000 on application and AED 200,000 in annual supervision. Applying for more than one activity adds an extension fee of 50 percent of the lower application fee for each additional activity.
Paid-up capital, activity by activity
Capital under Rule VI.B.1 of the Company Rulebook is the larger budget line, and it scales with custody risk:
| Activity | Paid-up capital |
|---|---|
| Advisory Services | AED 100,000 |
| Broker-Dealer Services | AED 400,000 or 15% of fixed annual overheads (whichever is higher) using a VARA-licensed custodian; otherwise AED 600,000 or 25% |
| Custody Services | AED 600,000 or 25% of fixed annual overheads |
| Exchange Services | AED 800,000 or 15% using a VARA-licensed custodian; otherwise AED 1,500,000 or 25% |
| Lending & Borrowing Services | AED 500,000 or 25% of fixed annual overheads |
| VA Management & Investment Services | AED 280,000 or 15% using a VARA-licensed custodian; otherwise AED 500,000 or 25% |
| VA Transfer & Settlement Services | AED 500,000 or 25% of fixed annual overheads |
| Issuance: fiat-referenced tokens (FRVA) | AED 1,500,000 plus 2% of tokens in circulation |
| Issuance: asset-referenced tokens (ARVA) | Higher of AED 1,500,000 or 2% of average reserve assets over 24 months |
The capital is not decorative: it sits in a UAE bank trust account with VARA as beneficiary. Full analysis in our paid-up capital guide.
The ongoing prudential layer
Licensees must hold net liquid assets of at least 1.2 times monthly operating expenses at all times, maintain professional indemnity, directors and officers and crime insurance appropriate to the business, and keep physical office space in Dubai. Fiat-referenced token issuers add 100 percent 1:1 reserve backing audited every six months with monthly public disclosures.
The budget lines applicants forget
In Neo Legal's experience, the items that break first budgets are rarely the published fees. Custody must sit in a separate legal entity under VARA's rules, which doubles incorporation, office and governance costs for exchange models that self-custody. The people requirements are real payroll: two full-time Responsible Individuals, a UAE-resident Compliance Officer with five years of compliance experience reporting to the Board, and an MLRO with at least two years of AML/CFT experience (the MLRO, CISO and DPO roles may be outsourced; the rest may not). Finally, VARA expects to see operating runway in the financial projections, not capital scraped to the regulatory minimum.
What legal fees look like
Advisory fees depend on scope: a perimeter opinion is a fixed, modest engagement; a full licence application is a milestone-based programme covering the application pack, policies, prudential build and query rounds. Neo Legal scopes and fixes fees before you commit, so the regulator numbers above are the only variables left open. For how the spend spreads over the application period, see how long a VARA licence takes.
This article is general information as at September 2026 and is not legal advice. Fee and capital figures are as published in the VARA Regulations and Rulebooks at the review date; confirm current figures before budgeting.
