VARA Advisory Services License Dubai: Requirements, Cost and Application Process

If your Dubai business gives clients personalised recommendations about buying, selling, holding or otherwise dealing with virtual assets, you may fall within VARA’s Advisory Services category. A general consultancy or technology licence does not replace this regulatory approval.

The VARA advisory license Dubai framework applies across Dubai mainland and Dubai free zones, except the Dubai International Financial Centre. VARA defines Advisory Services around personal recommendations concerning actions or transactions involving virtual assets. This makes the substance of your service more important than the name written on your commercial licence. Dubai’s wider regulatory basis comes from Law No. 4 of 2022 Regulating Virtual Assets.

Before you apply, you need to get four things right: the regulated activity, corporate structure, senior team and compliance framework. The regulatory fee is only one part of the budget.

What Is a VARA Advisory Services Licence?

As stated in the VARA Advisory Services Rulebook, VARA treats Advisory Services as giving a personal recommendation to a client about one or more actions or transactions involving virtual assets. The recommendation may be requested by the client or initiated by the adviser. 

This is different from publishing general market commentary that is not personalised. Once your business starts recommending a particular virtual asset or course of action based on an individual client’s circumstances, you need to check carefully whether the activity sits inside VARA’s regulatory perimeter.

VARA currently regulates eight virtual asset activities. You can review the official VARA licensed activities here. One company can hold more than one regulated activity, subject to VARA’s rules. If your model also arranges transactions, manages assets or handles transfers, Advisory Services alone may not cover the full business.

Main VARA Advisory Licence Requirements

1. Establish a suitable Dubai legal entity

   A VASP needs a legal entity in Dubai through the Department of Economy and Tourism or an eligible Dubai free zone. DIFC sits outside VARA’s jurisdiction. VARA’s FAQ states that an LLC or FZCO is preferable and that sole proprietorship applications are not accepted.

2. Meet the capital and liquidity rules

   The minimum paid-up capital for Advisory Services is AED 100,000. VARA also requires VASPs to maintain net liquid assets equal to at least 1.2 times monthly operating expenses. 

   Paid-up capital must be maintained in the manner accepted by VARA, such as an eligible trust account or surety arrangement, and it must be reconciled monthly.

3. Appoint suitable senior and compliance staff

   VARA requires two Responsible Individuals. Both must be full-time employees, Fit and Proper Persons and UAE residents or UAE passport holders.

   The Compliance Officer must have at least five years of relevant compliance experience, be a full-time employee, meet Fit and Proper standards, be a UAE resident or UAE passport holder and report directly to the Board.

   The MLRO must have at least two years of AML/CFT experience and satisfy the Fit and Proper test. In some cases, the Compliance Officer may also hold the MLRO role if the combined duties do not create a conflict.

4. Build a proper client suitability process

   This is central to the Advisory Services Rulebook. Your firm must assess the client’s:

   • knowledge and experience with virtual assets

   • investment objectives, risk tolerance and time horizon

   • financial circumstances and ability to absorb significant losses

   The information must be kept accurate and current. Advisory suitability records must be retained for at least eight years. Each recommendation should also explain why it is appropriate for that particular client.

5. Keep advice independent and evidence-based

   Your policies need to explain how you preserve the independent basis of your advice and how you confirm adviser competency.

   VARA also requires advisers to verify factual information against reliable sources before making statements, promises or forecasts. Your methodology should consider a sufficiently broad range of virtual assets rather than relying on a narrow selection that may not suit the client.

   Public disclosures must address conflicts of interest, complaints, data privacy, whistleblowing and referral arrangements, including monetary or non-monetary benefits received.

6. Meet wider VASP compliance rules

   An Advisory Services licence does not sit on its own. You must also comply with VARA’s Company, Compliance and Risk Management, Technology and Information and Market Conduct Rulebooks.

   That means preparing risk management, AML/CFT, KYC, information security, record-keeping, audit, reporting and governance controls. UAE VASPs also sit within the federal AML/CFT framework.

VARA Advisory License Dubai Cost

VARA states that the initial licensing payment is typically 50% of the application fee. For Advisory Services, the direct application fee and first-year supervision fee therefore total AED 120,000. The AED 100,000 capital is not a fee. It remains a prudential requirement. 

Your actual first-year setup budget will be higher. You may also need to pay for company incorporation, office space, visas, staff, insurance, audit, cybersecurity, compliance systems, legal work and banking. VARA specifically notes that its regulatory charges are separate from fees charged by other authorities.

VARA Advisory Licence Application Process

1. Confirm the exact regulated activity

   Map every service your business plans to provide. Do not apply for Advisory Services if the real model also performs broker-dealer, management, custody or transfer functions without identifying those activities.

2. Submit the Initial Disclosure Questionnaire

   New firms start by submitting the IDQ through DET or the relevant Dubai free zone. The application covers areas such as the business model, company details, key persons, organisation and Fit and Proper information.

3. Pay the initial application amount

   VARA states that the initial payment is typically 50% of the licence application fee. For a single Advisory Services application, that would usually mean about AED 20,000 at this stage.

4. Receive Approval to Incorporate

   Once the initial stage is accepted, the firm receives Approval to Incorporate so it can finalise incorporation and operational setup, including office space and employee onboarding.

   You cannot start providing regulated virtual asset services at this point.

5. Build the regulated operation

   Prepare the governance structure, compliance function, AML controls, technology environment, client onboarding process, advisory methodology, record-keeping systems and required public disclosures.

6. Submit the full VASP licence package

   VARA may request meetings, interviews, clarifications and additional documents. Its published application list includes incorporation records, UBO details, Fit and Proper confirmations, source-of-funds evidence, organisational structure, governance documents, key-person CVs, a regulatory business plan, financial projections, proof of paid-up capital, insurance, succession planning and a wind-down plan. 

   Step 7: Pay the balance and first-year supervision fee

   Once the application progresses, you pay the remaining application amount and the first annual supervision fee.

7. Receive the VASP licence

   A licence may include operating conditions. This point is easy to miss.

   VARA’s public register shows Advisory Services firms with different client permissions. For example, RIV Technologies FZE is currently permitted to serve Institutional and Qualified Investors. Gap 3 Partners FZCO is permitted to serve Institutional, Qualified and Retail Investors.

   So you should not assume that every Advisory Services approval gives you the same client scope.

Common Application Mistakes

The first mistake is treating the application as a company-registration exercise. VARA reviews how the business will actually operate.

The second is using generic compliance templates that do not match the business model. If your suitability questionnaire, conflict policy and advisory process do not connect to your actual client journey, you are likely to face more questions during review.

Another problem is hiring key people too late. Your Responsible Individuals, Compliance Officer and advisory staff form part of the regulatory case. Their experience needs to support the model you are submitting.

Finally, avoid under-budgeting. AED 40,000 is the application fee, not the total cost of becoming operational.

Conclusion

Getting a VARA Advisory Services licence in Dubai is manageable when the business model is clear and the compliance structure is prepared before the final submission.

For 2026, the headline regulatory numbers are AED 40,000 for the application, AED 80,000 for annual supervision and AED 100,000 in minimum paid-up capital. You also need sufficient liquid assets, experienced staff and a client suitability process that can stand up to regulatory review.

The most important step is to define exactly what advice you will give, who you will serve and whether any part of your model falls into another regulated VARA activity.

Frequently Asked Questions