Last reviewed: 8 November 2026 · Regulatory Gate · General information, not legal advice

Short answer. Yes, if you run the exchange from Dubai outside the DIFC. VARA's regulations bar any entity from carrying out a virtual asset activity by way of business in the emirate without a VARA licence, unless it is exempt (VARA Rulebook).

Which licence

  • Each activity needs authorisation. VARA requires a firm to be licensed for each virtual asset activity it carries out (VARA Rulebook). Running an exchange falls under VA Exchange Services (VARA). Several activities can be combined under one licence (VARA).
  • Holding client assets as part of trading. In our reading, an exchange or broker-dealer that holds client assets only as part of its trading service does not need a separate custody licence. It must still follow VARA's client asset rules: separate wallets labelled as client wallets, one-to-one holding, and no ownership of client assets (VARA Rulebook).
  • Custody as a service needs its own entity. Offering custody as a service is different. VARA requires a custodian to be a distinct legal entity with a standalone licence. Custody is the only activity VARA requires to be segregated in this way (VARA).

How the process works

  1. Start with your commercial licensor. Submit an Initial Disclosure Questionnaire to Dubai Economy and Tourism or your Dubai free zone. The DIFC is not part of this route (VARA).
  2. Get an Approval to Incorporate. VARA reviews your business plan, owners and senior management. The approval lets you incorporate and set up, but not yet operate (VARA).
  3. Apply for the VASP Licence. You submit the full application, answer VARA's questions and pay the remaining fees. The licence may carry operating conditions (VARA).

Fees sit in Schedule B of VARA's 2023 regulations, and capital requirements in Part IV of its Company Rulebook (VARA).

If you are not in Dubai

A DIFC exchange answers to the DFSA, and an ADGM exchange to the FSRA. Elsewhere in the onshore UAE, the CMA's virtual asset framework applies. Our guide, Choosing a UAE regulator for a virtual asset business, compares all five regulators.

Planning an exchange in Dubai? Book a call with Regulatory Gate.