Crypto license in the UAE

Crypto legal structuring in the UAE

There is no single crypto regulator here. Federal Cabinet Resolution No. 111 of 2022 places virtual assets and their service providers under the Securities and Commodities Authority across the State, free zones included. Dubai is carved out of that: there VARA licenses. The financial free zones, ADGM and DIFC, run their own regimes under their own regulators.

So the first question is where your entity and your clients sit. That answers which rulebook binds you, which capital floor applies and which fee schedule you pay.

VARA, for Dubai and its free zones

• Sole authority for virtual assets across Dubai's mainland and free zones, with the DIFC outside its jurisdiction.
• Seven licensed activities plus Category 1 issuance; a firm assessed as trading on its own account pays an annual no-objection fee of AED 1,000.
• Two stages. An approval to incorporate lets you finish setting the company up; only the full licence lets you operate.
• Paid-up capital is set per activity, and an approved custody provider lowers it: exchange services need AED 1,500,000 or 25% of fixed annual overheads, whichever is higher, and AED 800,000 with such a provider.
• Net liquid assets of at least 1.2 times monthly operating expenses, plus professional indemnity, directors' and commercial crime cover.

ADGM, for Abu Dhabi under the FSRA

• Authorisation is a financial services permission under the Financial Services and Markets Regulations; the virtual asset rules sit in Chapter 17 of the conduct rulebook.
• The virtual asset charge sits on top of the fees for the underlying regulated activities, so the total is cumulative rather than a single headline number.
• In the regulator's own worked example a firm dealing as principal and arranging deals pays USD 70,000 to apply and USD 75,000 a year, of which the virtual asset part is USD 20,000 and USD 15,000.
• A multilateral trading facility using virtual assets also pays a monthly trading levy on the value it trades.
• Amendments of 10 June 2025 reworked how a token is accepted for use in ADGM, revised capital requirements and fees, and barred privacy tokens and algorithmic stablecoins.

Innovation City, the former RAK DAO

• The Ras Al Khaimah free zone launched as RAK Digital Assets Oasis was relaunched as Innovation City on 18 September 2025, with digital assets still one of its pillars.
• It licenses companies rather than financial activity: published packages run AED 6,600, 13,200, 15,400 and 22,550 a year, each with its own list of permitted activities.
• A service provider based here sits outside Dubai and outside the financial free zones, so the federal regulator licenses the service itself.
• It fits where the activity genuinely falls outside a licensed perimeter and what you need is a company and a bank.

What the three routes charge

The rest of our Emirates practice is on the UAE page.

Sources: Cabinet Resolution No. 111 of 2022 (uaelegislation.gov.ae); VARA Virtual Assets and Related Activities Regulations 2023, Schedule 2, and Company Rulebook Part VI (rulebooks.vara.ae); FSRA FEES Rules 3.17 and 3.18 and Guidance on Regulation of Virtual Asset Activities in ADGM, 10 June 2025 (adgm.com); Innovation City relaunch, RAK Government Media Office, 18 September 2025.