- It is a regulated activity. The trade licence alone does not authorise any virtual-asset service.
- Your category decides the approval. Exchange, custody and broking are separate approvals, each with its own rulebook.
- The conditions are substantial, and meeting them is a project in itself.
- The regulator decides on its own assessment, so a complete, well-evidenced application is what moves it forward.
Ask this before raising money or marketing, because the expensive mistake is to incorporate, take on customers or funds, then find the activity needed an approval you never held.
Is a trade licence enough?
What founders believe
A crypto business just needs a trade licence, like any other company.
What is true in practice
A trade licence lets you be in business; virtual-asset services need a separate regulator approval, and the service you offer decides which one.
VARA licence requirements by category
In and from Dubai, outside DIFC, virtual assets fall under the Virtual Assets Regulatory Authority (VARA), which licenses virtual asset service providers (VASPs) by category, each with its own rulebook.
Exchange
A trading venue where clients buy and sell virtual assets.
Broker-dealer
Matching or dealing in virtual assets for clients.
Custody
Holding or safeguarding virtual assets on behalf of clients.
Lending & borrowing
Credit and yield activity in virtual assets.
Management & investment
Managing assets or running investment products.
Advisory
Advising on virtual assets as a regulated service.
DIFC and ADGM run their own regimes for certain token activities, and federally the CMA (formerly SCA) and the Central Bank have roles. Where your service falls can change the regulator and the jurisdiction entirely.
The regulator decides
The regulator decides on its own assessment of the applicant and the model. Anyone promising approval or a fixed timeline is misdescribing how this works. We map what is required and help you meet it; the outcome is the regulator's to give.
What getting the approval wrong costs
Months lost
What a wrong-structure attempt can waste before anything is operational, along with the money spent on it.
Operating without the required approval brings enforcement, including penalties and orders to cease the activity. Even short of that, a company built under the wrong regulator may need its banking and contracts rebuilt.
How we handle it
We start from a precise description of your intended service and identify its regulator, category and what the approval demands, before money goes into the wrong structure. Where the model spans regulators or cannot work as described, we say so before anything is incorporated.
