Set up and license a virtual asset firm in Dubai.

What counts as a virtual asset firm (a VASP) in Dubai

"Virtual asset firm" is the market's phrase; the regulatory term is Virtual Asset Service Provider, or VASP: any business conducting a regulated activity in relation to virtual assets, whether that is running an exchange, dealing for clients, holding their assets, lending against them, managing portfolios, advising on them, moving them, or issuing tokens. Two boundaries matter. Trading purely your own assets is not a licensed activity (though VARA expects a No Objection Certificate and, at scale, registration). And building technology without touching client assets or the client relationship generally sits outside the perimeter. Everything in between, if done in or from Dubai outside the DIFC, needs a VARA licence before it starts, because unlicensed activity is an offence under Article 17 of Dubai Law No. 4 of 2022.

The regulator map: who licenses what

The UAE runs parallel virtual asset regimes, and picking the wrong one is the most expensive early mistake. The short version:

The full comparison is in our four-regulator guide, and the VARA-versus-CMA decision specifically in CMA vs VARA. Most founders targeting Dubai itself end up with VARA; most models needing onshore federal reach, or falling within tokenised securities, look at the CMA.

The eight VARA activities, with the real numbers

Under Schedule 2 of the Virtual Assets and Related Activities Regulations and the Company Rulebook, VARA's fees and paid-up capital by activity are:

Each additional activity adds 50 percent of the lower application fee. Capital sits in a UAE bank trust account with VARA as beneficiary, and every licensee must hold net liquid assets of at least 1.2 times monthly operating expenses. Full budgeting detail, including the costs applicants forget, is in the VARA licence cost guide. CMA capital under the federal framework is set in its Prudential Requirements module and varies by sub-category; published summaries indicate ranges from roughly AED 100,000 to 300,000 for advisory up to AED 1.5 to 2 million plus for an exchange, but these are indicative only and should be confirmed against the module itself: see our CMA crypto licence page.

The setup path, start to licence

1. Perimeter and venue. Classify the activity, pick the regulator, and confirm the licence scope before anything is incorporated. Misclassification here is the error every later stage inherits.
2. Entity formation. Incorporate the Dubai vehicle (mainland or non-DIFC free zone for a VARA firm), with a structure that anticipates VARA's rules, including the requirement that custody sit in a separate legal entity.
3. IDQ and application. File the Initial Disclosure Questionnaire, then the full application: business plan, financial model, AML/CFT and governance frameworks, technology and key personnel.
4. Approvals and conditions. Work through VARA's rounds of queries to approval, then satisfy the conditions: capital injected into the trust account, Dubai office, approved persons in seat (two Responsible Individuals, a UAE-resident Compliance Officer, an MLRO).
5. Go-live and supervision. Operational licence, goAML registration, and the ongoing prudential, reporting and conduct obligations. Our first 90 days guide covers what the diary looks like after the licence lands.

End to end, a well-prepared VARA application typically runs eight to twelve months from IDQ to operational licence: see the timeline guide, and the fuller walkthrough in how to set up a virtual asset company in Dubai.

Named work: Animoca Brands

Neo Legal advised Animoca Brands on securing its Virtual Asset Service Provider licence from Dubai's VARA, announced 16 February 2026, covering VA Broker-Dealer and VA Management & Investment Services: the first regulated VASP licence obtained by the Animoca Brands group globally. Neo Legal worked alongside Animoca's internal legal and compliance team and the group's other advisers. The mandate is public, and the detail is in our Animoca Brands case note.

Why Neo Legal for virtual asset firms

First, depth over time: the practice has advised in virtual assets since 2015, including the world's first cryptocurrency IPO, so it predates every UAE virtual asset regime it now works under. Secondly, regulator-side insight: our Director of Licensing and Regulatory Compliance, Manpreet Kaur, previously served inside VARA itself. Thirdly, a bilingual China Desk: matters run in English and Mandarin for the Chinese-speaking founders who make up a substantial share of Dubai's virtual asset market: see the China practice. Every engagement is partner-led by Harly Zappino, and Neo Legal is the UAE practice of Cornwalls, the Australian firm established in 1891.