The VARA Licensing Process: What You Need to Know

The Dubai Virtual Assets Regulatory Authority (“VARA”) has established a structured two-stage licensing framework for entities seeking authorization to conduct virtual asset activities.

Stage 1 – Approval To Incorporate (ATI)

Step 1: Obtain Initial Approval from DET or the relevant free zone.Step 2: Submit the Initial Disclosure Questionnaire (IDQ) to VARA.Step 3: VARA Preliminary Assessment – checks completeness and regulatory fit.Step 4: Payment of Initial Fees (approx. 50% of application fees).Step 5: Receive Approval To Incorporate (ATI) – allows incorporation, office setup, staffing, and banking, but not VA activities.The first stage comprises the initial application, after which the successful applicant would receive an “Approval To Incorporate (“ATI”), while the second stage includes a comprehensive review and, ultimately, the full licensing. Understanding the procedural flow and requirements at each stage is essential for applicants planning their regulatory pathway.

Stage 2 – Full License

Step 6: Compile full application package including business plan, UBO/shareholder details, org charts, flow of funds, financial projections, and policies.Step 7: Submit full application – VARA conducts detailed review.Step 8: VARA Queries & Additional Requests – gap lists and clarifications.Step 9: Payment of Remaining Fees – balance of license fees and first‑year supervision fees.Step 10: Obtain Virtual Asset Service Provider (VASP) License – authorizes approved VA activities, subject to ongoing compliance.

Timeline

The complete licensing pathway typically spans six to twelve months, depending on application quality, responsiveness, and regulatory workload.

How Rasma Legal Can Help

Rasma Legal supports applicants throughout the licensing journey by advising on eligibility, preparing IDQs and business plans, drafting required policies, managing communications with VARA, and guiding compliance obligations post‑licensing.