VA Exchange License
License for operating order-book exchange platforms for trading virtual assets with real-time matching and settlement capabilities.
VARA Regulations 2023, VA Exchange Services Rulebook, Dubai Law No. 4 of 2022
Capital Required
AED 800,000-1,500,000 plus 1.2x monthly expenses
Timeline
6-10 months
Fees
AED 100,000 application + AED 200,000 annual supervision
Regulatory Body
Virtual Assets Regulatory Authority (VARA)
Legislative Framework
Dubai Law No. 4 of 2022, Virtual Assets and Related Activities Regulations 2023, VARA Rulebooks (13 total: 5 Compulsory, 8 Activity-Specific)
Last updated: August 2025
Key Requirements
Base capital of AED 800,000-1,500,000 depending on custody integration plus 1.2x monthly operational expenses
Real-time order matching and settlement with finality within 24 hours per VARA rulebook standards
Comprehensive market surveillance detecting market abuse, unusual patterns, and prohibited activity
Segregated customer fund accounts with third-party custodian or own custody license meeting VARA standards
Qualified Senior Management Team including Chief Compliance Officer and Chief Risk Officer approved by VARA
Professional indemnity insurance of minimum AED 1,000,000 covering trading platform liabilities
Robust cybersecurity framework with annual penetration testing and incident response documented per VARA
Clear fee schedule and service terms with mandatory dispute resolution accessible to retail traders
Application Process
Prepare comprehensive VA Exchange license application with business plan and technology architecture
Submit organizational structure, management CVs, and VARA fit-and-proper assessments for board
Provide compliance manuals, AML/KYC procedures, market conduct rules, and conflicts-of-interest policies
Undergo VARA pre-application consultation to discuss platform design and regulatory expectations
Submit final application with capital adequacy, insurance coverage, and operational readiness evidence
VARA review and approval following evaluation of market surveillance and governance frameworks
Expected Total Timeline
6-10 months
Ongoing Obligations
After obtaining your VA Exchange License, these are the continuing compliance requirements you must maintain.
Quarterly capital adequacy reporting and annual independent audit certified by VARA-approved auditors
Daily market surveillance reports including suspicious activity, margin calls, and circuit breaker triggers weekly
Monthly customer fund reconciliation with independent custodian verification statements
Annual fit-and-proper assessments for Senior Management Team with notifications to VARA within 5 days
Quarterly compliance certifications covering AML/KYC, market conduct rules, and conflicts management
Maintain professional indemnity insurance continuously and notify VARA of any coverage changes
Cost Summary
Capital Requirement
AED 800,000-1,500,000 plus 1.2x monthly expenses
Application & Licensing Fees
AED 100,000 application + AED 200,000 annual supervision
Jurisdiction Setup Cost
$50,000-$100,000
Annual: $40,000-$120,000
Other UAE / Dubai Licenses
Explore other license types available in UAE / Dubai.
VA Broker-Dealer License
VA Custody License
VA Lending & Borrowing License
VA Management & Investment License
VA Advisory License
VA Issuance License
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