Moving virtual assets for customers may look simple on the surface. A client gives an instruction, assets move between wallets and the transaction settles.
In Dubai, that activity can place your business inside a specific regulatory category.
VARA defines VA Transfer and Settlement Services as the transmission, transfer and/or settlement of virtual assets from one entity to another entity, wallet, address or location. A company providing these services in or from Dubai generally needs authorisation from the Virtual Assets Regulatory Authority before it starts operating.
The VARA transfer and settlement license Dubai framework applies across Dubai mainland and its free zones, except the Dubai International Financial Centre, which has its own financial regulatory system.
What Does a VARA Transfer and Settlement Licence Cover?
This licence is intended for businesses that transfer or settle virtual assets for clients.
That can include businesses running virtual asset payment infrastructure, institutional settlement systems, crypto transfer platforms or services that move digital assets between users, wallets or other entities.
The important point is the actual activity, not the label you use for your company.
Calling a platform a "fintech company", "blockchain infrastructure provider" or "payment technology company" does not automatically put it outside VARA regulation. VARA looks at what the service does in practice.
You can review VARA's official list of regulated virtual asset activities before deciding which licence category fits your model.
There is another distinction to watch. If your transfer process includes converting one virtual asset into another or converting virtual assets into fiat currency, the Transfer and Settlement licence alone may not cover the full activity.
VARA states that such conversions must use a VASP licensed for Exchange Services or, for an entity outside Dubai, an entity approved by VARA. The transfer provider still remains responsible to its client for completing the service.
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VARA Transfer and Settlement Licence Requirements
Getting licensed involves far more than registering a company and paying an application fee.
Your firm must comply with the activity-specific Transfer and Settlement Services Rulebook plus VARA's four compulsory rulebooks covering company governance, compliance and risk management, technology and information and market conduct.
Dubai Legal Entity and Business Structure
A new applicant needs an appropriate legal presence in Dubai. Applications are submitted through the Dubai Department of Economy and Tourism for mainland companies or through a relevant Dubai free zone.
VARA also reviews ownership, ultimate beneficial owners, group structure, senior management and the people responsible for operating the business.
Governance and Key Personnel
VARA's application documentation includes the organisational structure, governance framework, fit-and-proper information, key staff details, CVs, job descriptions and source-of-funds evidence.
Applicants should also expect to prepare a regulatory business plan, financial projections, financial statements, succession arrangements and a wind-down plan.
A thin business plan prepared only for company incorporation will usually not address these regulatory questions. Your submission should explain exactly how assets move, who controls each stage and what happens when a transaction fails.
AML, KYC and the Travel Rule
AML controls are central to this licence because the business is directly involved in transferring virtual assets.
VARA requires VASPs to follow applicable federal AML/CFT rules as well as its own Compliance and Risk Management Rulebook.
For virtual asset transfers above AED 3,500, VARA's Travel Rule provisions require the VASP to obtain and hold required originator and beneficiary information. Counterparty VASPs also require risk-based due diligence. Your procedures need to address unhosted wallets, non-compliant transfers and attempts to split transactions to avoid regulatory thresholds.
VARA expects applicants to demonstrate their Travel Rule controls during licensing.
This sits within a wider global AML framework. FATF's July 2026 update again identified Travel Rule implementation, unhosted-wallet risks and effective VASP supervision as active regulatory priorities.
For broader UAE requirements, Nexture's UAE AML compliance guide covers customer due diligence, risk assessments, monitoring and record keeping.
Client Asset and Transaction Controls
A transfer provider cannot freely use client virtual assets.
VARA prohibits selling, lending, pledging, rehypothecating, converting or otherwise using virtual assets involved in a transfer unless the client has given the required explicit consent. Your system must also verify that transfers are authorised and follow client instructions.
If an unauthorised or incorrectly executed transaction occurs, the VASP must, once aware of the problem, restore or refund the client as soon as practicable and in all cases within 24 hours. Records of client instructions must be retained for eight years.
VARA also requires receipts when a transaction is initiated and again when it is finalised. The required information includes transaction details, amounts, fees and transaction references.
Technology and Cybersecurity
A settlement business depends heavily on its technology stack, so systems are part of the licensing review.
VARA's Technology and Information Rulebook covers technology governance, cybersecurity, cryptographic keys, wallet management, transaction systems, testing, business continuity, incident response and data protection.
In practical terms, you should be ready to explain wallet architecture, access controls, key-management procedures, transaction monitoring, recovery processes and how the platform deals with service outages or blockchain failures.
Default and Settlement Procedures
VARA requires legally enforceable default rules for situations where a client cannot meet settlement obligations.
These procedures should address financial and operational defaults, unsettled transactions, client assets, loss allocation, close-out arrangements and steps designed to stop one default from affecting the wider service.
VARA says these default rules should be tested at least annually and after material changes.
VARA Transfer and Settlement Licence Fees
The regulator's current fee schedule is relatively clear.
Cost | Current VARA Requirement |
Licence application fee | AED 40,000 |
Annual supervision fee | AED 80,000 |
First-year VARA fees for one activity | AED 120,000 |
Minimum paid-up capital | Higher of AED 500,000 or 25% of fixed annual overheads |
Net liquid assets | At least 1.2 × monthly operating expenses |
These figures come directly from VARA's current fee schedule and Company Rulebook.
The AED 500,000 capital requirement is not a licence fee. It is capital that the VASP must maintain.
Paid-up capital must also be reconciled monthly. VARA allows it to be maintained through specified arrangements such as a trust account with a UAE licensed bank naming VARA as beneficiary, an eligible surety bond or another arrangement approved by VARA.
Your real first-year budget can therefore include commercial licensing, office costs, employees, compliance personnel, insurance, cybersecurity, audits, banking, technology systems and professional support on top of the AED 120,000 regulatory fees.
How to Apply for a VARA Transfer and Settlement Licence
VARA uses a two-stage process for new VASP applicants.
Choose the business structure and commercial jurisdiction. Decide whether the company will operate through Dubai mainland or an eligible free zone and map the exact regulated activities.
Submit the Initial Disclosure Questionnaire. The IDQ goes through DET or the relevant free zone along with details such as the business plan, owners and senior management.
Pay the initial application amount. VARA states that the initial payment is typically 50% of the licence application fee.
Receive Approval to Incorporate. The ATI allows you to complete incorporation, lease premises, recruit staff and build the operating setup. It does not permit you to start providing virtual asset services.
Complete the full VASP application. Submit the detailed governance, compliance, AML, technology, financial and operational documents requested by VARA. Meetings, interviews and further information requests may follow.
Pay the remaining fees and obtain the licence. Before operations begin, the remaining application amount and first annual supervision fee are paid. VARA may issue the licence with specific operational conditions.
VARA does not publish one guaranteed approval time for every application. The review depends on the business model, quality of documents, regulatory issues and how quickly the applicant responds to questions.
We’ll model the requirements and send back a single-page breakdown within 24 hours.
Banking and Operational Setup
Do not leave banking until the final stage.
Virtual asset businesses generally receive additional scrutiny because banks need to understand ownership, source of funds, transaction flows, expected counterparties and compliance controls.
Prepare the banking case alongside the VARA application. Nexture's UAE business bank account requirements guide explains the documents and KYC checks commonly involved.
You should also map every money and asset flow before filing. If your platform involves third-party exchanges, custodians, banks, wallet providers or overseas VASPs, their roles should be clear in your business plan and client documentation.
Conclusion
The VARA transfer and settlement license Dubai framework is built for businesses that actually move or settle virtual assets for customers. It is therefore heavily focused on transaction controls, AML, client protection, technology and the ability to complete settlements safely.
For 2026, the headline regulatory cost is AED 40,000 for the application and AED 80,000 for annual supervision. The larger financial requirement is paid-up capital, set at the higher of AED 500,000 or 25% of fixed annual overheads.
Before applying, define the complete transaction flow. Confirm whether you are transferring assets only or whether exchange, custody or another regulated activity also takes place. That decision affects your licence scope, documents, capital and compliance setup.
Frequently Asked Questions
How much does a VARA Transfer and Settlement Services licence cost?
VARA currently charges AED 40,000 as the application fee and AED 80,000 as the annual supervision fee for this activity. These fees are separate from commercial licensing, office, staffing and other business costs.
What is the minimum capital for a VARA Transfer and Settlement licence?
The requirement is the higher of AED 500,000 or 25% of fixed annual overheads. The capital must be maintained in accordance with VARA's Company Rulebook.
Does the licence allow crypto-to-fiat conversion?
Transfer and Settlement Services involving an exchange, trade or conversion must use a VASP licensed by VARA for Exchange Services or an approved entity outside Dubai. Depending on your business model, separate regulated permissions may therefore be required.
Does VARA's Travel Rule apply to transfer businesses?
Yes. VARA's current rulebook sets a threshold above AED 3,500 for specified originator and beneficiary information and requires VASPs to demonstrate Travel Rule controls during licensing.
Can you operate after receiving Approval to Incorporate?
No. VARA states that an ATI allows the company to finish incorporation and operational preparation. The firm cannot begin regulated virtual asset activities until it receives the full VASP licence.
