Last reviewed: 9 November 2026 · Regulatory Gate · General information, not legal advice

Short answer. Not if it targets them without a UAE licence. Dubai, federal and Central Bank rules all reach firms abroad that market to or serve people in the UAE. Which licence you need depends on where your clients are and what you offer them.

Where the rules apply

  • Dubai, outside the DIFC. VARA bars any virtual asset activity by way of business in the emirate without a VARA licence (VARA Rulebook). Only a VARA-licensed firm, or someone acting for one with its approval, may market a virtual asset activity in or targeting Dubai (VARA Marketing Regulations).
  • The rest of the onshore UAE. Federal Decree-Law No. 33 of 2025 covers anyone targeting clients in the UAE, even from abroad or from a financial free zone (Article 2). Promotion is itself a licensed activity (Article 3). A virtual asset may be traded in the UAE only if a CMA-licensed platform has admitted it to its official list (Article 39) (Decree-Law No. 33).
  • Stablecoin payments. No one may provide a payment token service in the UAE, or directed to persons in the UAE, without a Central Bank licence or registration. The same rule covers promoting those services (CBUAE Rulebook).
  • The DIFC and ADGM. Clients based in the financial free zones bring in their own regulators, the DFSA and ADGM's FSRA. The federal and Central Bank rules above exclude these zones.

What counts as targeting the UAE

VARA's guidance gives a clear picture of how regulators read targeting (VARA guidance):

  • Gulf-wide campaigns count. VARA treats a campaign aimed at the GCC as including the UAE, and a UAE campaign as including Dubai.
  • Geo-blocking is not a safe harbour. Blocking UAE users is one factor VARA weighs. It does not settle the question on its own.
  • Any local element counts. A single part of a campaign in the UAE, or a channel aimed at UAE residents, can bring the whole campaign in scope.

VARA's marketing rules do not apply to a firm that meets all three tests. It is not located in Dubai, it carries out no virtual asset activity there, and it does no marketing in or targeting the UAE (VARA Marketing Regulations).

Where to start

  1. Map where your UAE clients are and what you offer each group.
  2. Pause any marketing in or aimed at the UAE until you hold the right licence.
  3. Pick your route: VARA for Dubai, the CMA for the rest of the onshore UAE, or the DFSA or FSRA for a financial free zone. Our guide, Choosing a UAE regulator for a virtual asset business, compares all five regulators.

Serving UAE clients from abroad? Book a call with Regulatory Gate.