If you are planning a regulated crypto or virtual asset business in Dubai, the licence fee is only one part of the budget. VARA charges an application fee and an annual supervision fee. You may also need substantial paid-up capital, working liquidity, insurance, a Dubai office and qualified staff.
As of September 2026, one regulated activity carries a VARA application fee of AED 40,000 or AED 100,000. Annual supervision costs AED 80,000 or AED 200,000 per activity. Paid-up capital starts at AED 100,000 for Advisory Services and can reach AED 1.5 million or more for Exchange Services, depending on your custody structure and fixed annual overheads.
This guide breaks down the VARA license cost Dubai businesses should plan for before applying.
VARA Application and Annual Supervision Fees
VARA's current Schedule 2 sets the following charges.
VARA regulated activity | Application fee | Annual supervision fee |
Advisory Services | AED 40,000 | AED 80,000 |
VA Transfer and Settlement Services | AED 40,000 | AED 80,000 |
Broker-Dealer Services | AED 100,000 | AED 200,000 |
Category 1 VA Issuance | AED 100,000 | AED 200,000 |
Custody Services | AED 100,000 | AED 200,000 |
Exchange Services | AED 100,000 | AED 200,000 |
Lending and Borrowing Services | AED 100,000 | AED 200,000 |
VA Management and Investment Services | AED 100,000 | AED 200,000 |
An Advisory-only business therefore starts with AED 120,000 in first-year application and supervision charges. A single Exchange, Broker-Dealer, Custody, Lending and Borrowing or Management and Investment activity starts with AED 300,000 in first-year VARA charges.
These figures do not include paid-up capital, the commercial licence or operating costs. VARA specifically states that its fees are separate from charges imposed by other competent authorities.
Check VARA's official Schedule 2 fee schedule
When Do You Pay the VARA Application Fee?
According to VARA's official licence application process, new applicants follow two stages.
At Stage 1, you submit an Initial Disclosure Questionnaire through Dubai Economy and Tourism or a relevant Dubai free zone. VARA says the initial payment is typically 50% of the licence application fee. If VARA grants Approval to Incorporate, you can establish the entity and prepare operations, but you cannot provide regulated virtual asset services yet.
At Stage 2, you submit the full VASP licence application and pay the remaining application fee plus the first year's supervision fee.
For Exchange Services, that could mean around AED 50,000 at Stage 1, then the remaining AED 50,000 plus AED 200,000 in annual supervision fees, subject to VARA's payment instructions.
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What If You Need More Than One VARA Activity?
Schedule 2 applies a licence extension fee equal to 50% of the lower applicable application fee for each additional regulated activity.
For example:
Exchange Services plus Broker-Dealer Services: AED 100,000 for the primary application plus an AED 50,000 extension fee.
Exchange Services plus Advisory Services: AED 100,000 plus an AED 20,000 extension fee.
Annual supervision works differently. VARA charges the applicable supervision fee for every licensed activity.
So an Exchange plus Advisory licence would carry AED 280,000 in annual supervision fees before any additional amount VARA may impose based on the firm's risk profile.
VARA Paid-Up Capital Requirements in 2026
Paid-up capital is often the largest regulatory funding requirement.
Regulated activity | Paid-up capital requirement |
Advisory Services | AED 100,000 |
Broker-Dealer with approved VARA-licensed custodian | Higher of AED 400,000 or 15% of fixed annual overheads |
Broker-Dealer in other cases | Higher of AED 600,000 or 25% of fixed annual overheads |
Custody Services | Higher of AED 600,000 or 25% of fixed annual overheads |
Exchange with approved VARA-licensed custodian | Higher of AED 800,000 or 15% of fixed annual overheads |
Exchange in other cases | Higher of AED 1,500,000 or 25% of fixed annual overheads |
Lending and Borrowing Services | Higher of AED 500,000 or 25% of fixed annual overheads |
VA Management and Investment with approved custodian | Higher of AED 280,000 or 15% of fixed annual overheads |
VA Management and Investment in other cases | Higher of AED 500,000 or 25% of fixed annual overheads |
VA Transfer and Settlement Services | Higher of AED 500,000 or 25% of fixed annual overheads |
These requirements come from Part VI of VARA's Company Rulebook. VARA also requires firms with multiple licensed activities to calculate capital for each activity using the relevant overheads.
Category 1 VA Issuance follows separate rules. An FRVA issuer must maintain paid-up capital equal to AED 1.5 million plus 2% of the value of available FRVA supply.
For an ARVA issuer, the requirement is at least the higher of AED 1.5 million or 2% of the average market value of applicable Reserve Assets over the preceding 24 months.
Your Capital Requirement Can Be Higher Than the Minimum
The fixed AED amount is a floor. It may not be your final requirement.
Suppose an Exchange Services business does not use an approved VARA-licensed custodian and projects AED 8 million in fixed annual overheads.
Twenty-five percent of AED 8 million is AED 2 million. Since AED 2 million is higher than the AED 1.5 million minimum, the required paid-up capital becomes AED 2 million.
VARA requires paid-up capital to be maintained continuously and reconciled monthly. This is why you should build a proper operating forecast before filing. A lower office or staffing estimate might make your business plan look cheaper, but the figures still need to reflect the operation you genuinely intend to run.
Paid-Up Capital Is Not a VARA Licence Fee
This distinction is important. Application and supervision fees are regulatory charges. Paid-up capital is a continuing financial requirement of the VASP.
VARA states that paid-up capital can be maintained through a permitted arrangement such as a trust account with a UAE-licensed bank where VARA is named as beneficiary, a qualifying surety bond or another arrangement approved by VARA.
So if an Exchange business pays AED 300,000 in first-year application and supervision fees and maintains AED 1.5 million in capital, you should not describe AED 1.8 million as the licence fee.
The AED 300,000 is the published first-year VARA charge. The AED 1.5 million is regulatory capital.
Other Costs to Include in Your VARA Budget
Commercial Licence and Office
A VARA licence does not replace your commercial licence. Applications are made through DET for mainland businesses or an eligible Dubai free zone, excluding DIFC.
If you are still choosing a structure, compare Nexture's Dubai mainland vs free zone guide and its Dubai business setup cost guide before fixing your budget.
VARA also requires physical presence in Dubai. Broker-Dealer, Custody, Exchange, Lending and Borrowing, Management and Investment, Transfer and Settlement and Category 1 Issuance activities require a private office.
VARA itself does not specify a minimum office size. DET or your selected free zone may have separate requirements.
Staffing and Compliance
A VASP must appoint two Responsible Individuals. Each must be a full-time employee, meet VARA's fit-and-proper requirements and either reside in the UAE or hold a UAE passport. VARA must approve them during licensing.
You also need to budget for the compliance, AML, information security, finance, legal and operational capability required by your business model. These staffing costs matter because they also feed into your annual overhead calculations.
Liquidity, Insurance and Reserve Assets
Paid-up capital is not the only financial test.
VARA requires VASPs to maintain Net Liquid Assets so that the surplus of current liquid assets over current liabilities is worth at least 1.2 times monthly operating expenses.
If your monthly operating expenses are AED 200,000:
AED 200,000 × 1.2 = AED 240,000
You therefore need to model a minimum Net Liquid Assets requirement of AED 240,000 under that example.
VARA also requires specified insurance coverage. Reserve asset requirements can apply where the business has liabilities to clients.
Banking, Audit and Technology
Your budget should also cover corporate banking, external audit, legal documentation, cybersecurity, compliance systems and transaction monitoring.
For banking preparation, Nexture's UAE business bank account requirements guide explains the documents and KYC checks new UAE companies commonly face.
VARA does not publish one standard market price covering all these operating items. Be cautious with any advertised "all-inclusive VARA package" unless the provider clearly states which regulator fees, capital requirements and third-party costs are included.
We’ll model the requirements and send back a single-page breakdown within 24 hours.
Practical First-Year VARA Cost Examples
Example | First-year VARA fees | Starting capital floor | Fees + capital* |
Advisory only | AED 120,000 | AED 100,000 | AED 220,000 |
Transfer and Settlement only | AED 120,000 | AED 500,000 | AED 620,000 |
Broker-Dealer, no approved custodian | AED 300,000 | AED 600,000 | AED 900,000 |
Exchange, no approved custodian | AED 300,000 | AED 1,500,000 | AED 1,800,000 |
*Paid-up capital is not a fee. Actual capital can be higher because of the fixed-overheads test or additional prudential requirements imposed by VARA.
How to Build a Realistic VARA Budget
Before applying, confirm your exact regulated activity first. Then calculate the application and annual supervision fees and run the paid-up capital test against your projected fixed annual overheads. Add the Net Liquid Assets requirement next.
After that, price your commercial licence, private office, visas, staffing, insurance, audit, legal work, banking and technical controls.
Your custody model also deserves attention. Using a VARA-licensed custodian, or another arrangement accepted during licensing, can materially change the capital calculation for Broker-Dealer, Exchange and Management and Investment Services.
VARA can impose additional supervision fees based on factors such as a VASP's market share, target clients, business complexity and regulatory track record. It can also require additional capital, liquidity, insurance or reserve assets depending on the scale and risk of the operation.
Conclusion
The VARA license cost Dubai founders see in a fee table is only the starting point.
For one activity, first-year application and supervision charges currently range from AED 120,000 to AED 300,000.
Paid-up capital starts at AED 100,000 for Advisory Services and can reach AED 1.5 million or more for Exchange Services. Your annual overheads, custody structure and activity mix can raise the requirement further.
Work out the capital and liquidity tests before committing to your full operating structure. You will get a much clearer picture of the money required to reach licensing and keep the business compliant after approval.
Frequently Asked Questions
How much is a VARA licence in Dubai in 2026?
For one regulated activity, the application fee is AED 40,000 or AED 100,000. Annual supervision is AED 80,000 or AED 200,000. Paid-up capital and operating costs are separate.
What is the lowest VARA application fee?
Advisory Services and VA Transfer and Settlement Services have the lowest published application fee at AED 40,000. Their annual supervision fee is AED 80,000. Their capital requirements differ significantly.
Is the VARA application fee refundable?
No. VARA's regulations state that application fees are not refundable if an application is denied or withdrawn.
Does VARA charge an annual fee?
Yes. VARA states that a VASP licence is annual and renewed for 12 months. The annual supervision fee is payable at renewal.
Does a VARA licence cover DIFC?
No. VARA regulates virtual asset activities across Dubai mainland and Dubai free zones, except the Dubai International Financial Centre.
