Ask what a VARA licence costs and you will usually be given a single number. That number is almost always the application fee, which is the smallest of four separate costs and the least useful for planning.
The honest answer is that the regulatory fees are modest and predictable, the capital requirement is large and structural, and the unpublished costs — people, premises, technology, advisers — typically exceed both. Budgeting well means keeping those four layers separate, because they behave differently: fees are spent, capital is committed, and overheads recur.
Here is each layer with the published figures, followed by three worked budgets.
Layer 1 — Application fees
One-time, non-refundable, and charged per virtual asset activity. Two activities sit in a lower tier and everything else pays the standard rate.
Activity | Application fee | Tier |
|---|---|---|
Advisory Services | AED 40,000 | Lower |
VA Transfer & Settlement Services | AED 40,000 | Lower |
Broker-Dealer Services | AED 100,000 | Standard |
Custody Services | AED 100,000 | Standard |
Exchange Services | AED 100,000 | Standard |
Lending & Borrowing Services | AED 100,000 | Standard |
VA Management & Investment Services | AED 100,000 | Standard |
Category 1 VA Issuance | AED 100,000 | Standard |
Multiple activities: each additional activity carries an extension fee, generally 50% of that activity’s standard application fee — so roughly AED 50,000 for a standard-tier activity added alongside a first one. A firm applying for both Custody and Transfer & Settlement pays the full fee on the first and half on the second.
A vocabulary note: VA Transfer and Settlement Services replaced the retired Payments and Remittances Services category. Use the current name when scoping an application; the old term still circulates in advisory material and causes confusion at the intake stage.
Layer 2 — Annual supervision fees
Payable every year, in advance, per activity — and this is the number that matters for the operating model, since it recurs for as long as you hold the licence.
Activity | Annual fee | Application |
|---|---|---|
Advisory Services | AED 80,000 | AED 40,000 |
VA Transfer & Settlement Services | AED 80,000 | AED 40,000 |
Broker-Dealer Services | AED 200,000 | AED 100,000 |
Custody Services | AED 200,000 | AED 100,000 |
Exchange Services | AED 200,000 | AED 100,000 |
Lending & Borrowing Services | AED 200,000 | AED 100,000 |
VA Management & Investment Services | AED 200,000 | AED 100,000 |
The pattern is consistent: supervision runs at twice the application fee for every activity. A firm licensed for three standard activities pays AED 600,000 annually in supervision alone, before a single member of staff.
Where the higher numbers you have seen come from: some advisory sites quote supervision fees of AED 300,000 or more for Exchange Services. VARA reserves the right to impose additional or modified fees where enhanced regulatory oversight is required, or in response to complaints against a VASP. Treat the published schedule as the floor for a well-behaved firm rather than a ceiling for every firm.
Layer 3 — Paid-up capital — the number that actually shapes the plan
This is the layer people underestimate, and it is usually several times the size of the fees. The Company Rulebook sets minimum paid-up capital per activity as the higher of a fixed dirham amount or a percentage of fixed annual overheads.
Activity | With VARA-licensed custody | Otherwise |
|---|---|---|
Advisory Services | AED 100,000 | AED 100,000 |
Broker-Dealer | AED 400,000 or 15% FAO | AED 600,000 or 25% FAO |
Exchange Services | AED 800,000 or 15% FAO | AED 1,500,000 or 25% FAO |
Management & Investment | AED 280,000 or 15% FAO | AED 500,000 or 25% FAO |
Lending & Borrowing | AED 500,000 or 25% FAO | AED 500,000 or 25% FAO |
FAO means fixed annual overheads, and the requirement is always the higher of the two figures — so a firm with large overheads can find the percentage test binding rather than the fixed floor.
The single most consequential structural decision: for Exchange Services, using a VARA-licensed custody provider sets the capital floor at AED 800,000; doing custody yourself pushes it to AED 1,500,000. Nearly double, decided by an operating model choice rather than a fee schedule. The same split applies to Broker-Dealer and to Management & Investment. If capital is your binding constraint, this is the first lever to pull.
Where the capital has to sit
Paid-up capital must be held at all times in a UAE trust account with VARA as beneficiary, or provided through an acceptable surety bond. It is committed rather than consumed — still your money, but not working capital. Budget it as a locked balance, not an expense.
Firms licensed for more than one activity must hold capital for each activity, with fixed annual overheads allocated between them on a mutually exclusive and collectively exhaustive basis. You cannot count the same overhead twice to reduce the total, and you cannot net the requirements against each other.
There is also an expense-based test. VARA requires licensed firms to maintain capital of at least 1.2 times monthly operational expenses, alongside net liquid asset requirements. A lean firm clears this easily; a firm with heavy fixed costs may find it binds before the headline figure does.
Layer 4 — Everything VARA does not publish
The regulator publishes fees and capital. It does not publish what it costs to become licensable, and for most applicants that is the larger figure.
Physical presence. All licensed VASPs must have a physical presence in Dubai. Exchange, custody and broker-dealer activities specifically require a closed-door private office — a flexi-desk or shared space will not satisfy this.
Named function holders. Compliance officer, MLRO, senior management and board — with fit-and-proper assessment. These are salaried roles that must be in place before licensing, generating cost during a period with no revenue.
Legal and advisory. Application drafting, rulebook mapping, policy suites and regulator correspondence. Regulatory fees do not include any of it.
Technology and audit. Systems, controls, security assessments, external audit, and insurance where required by activity.
The uncomfortable arithmetic: these run for the duration of the application process, which can extend across many months, before a single client is onboarded. Cash flow, not the fee schedule, is what breaks most applications.
When you actually pay
VARA operates a two-stage process, and the payment schedule follows it.
Initial Disclosure Questionnaire. Submitted via the relevant free zone authority or Dubai Economy and Tourism. An instalment of 50% of the application fee is invoiced after this stage.
Full application and in-principle approval. Detailed submission against the rulebooks. In-principle approval permits preparation but does not permit servicing clients.
Final licensing. The remaining application fee plus a full year of supervision fees are collected before any client work is permitted.
Plan for the final step. A standard-activity applicant faces AED 50,000 of remaining application fee plus AED 200,000 of supervision due at the point of licensing — alongside the paid-up capital already locked. That is the cash-flow pinch point, and it arrives before revenue does.
VARA publishes no end-to-end processing standard, so timelines should be planned by stage and revised against regulator feedback rather than against an assumed total. Advisory commentary commonly describes the full process as running many months.
Other published fees worth knowing
Item | Fee | Notes |
|---|---|---|
Proprietary trading NOC | AED 1,000 per year | Flat, regardless of firm size |
VA issuance white paper submission | AED 5,000 | Initial submission |
White paper detailed review | AED 50,000 | Where a full review is required |
Licence withdrawal | AED 10,000 | Payable on winding up |
The proprietary trading NOC is worth flagging because it is so often missed. A firm trading only its own capital does not need a full VASP licence, but does need a no-objection certificate — at AED 1,000 a year, a rounding error against any of the figures above.
Three worked budgets
Regulatory items only. Staff, premises, technology and advisers sit on top and are usually the larger number.
A. Advisory boutique
Item | Amount | Type |
|---|---|---|
Application fee | AED 40,000 | Spent |
Year one supervision | AED 80,000 | Spent, recurring |
Paid-up capital | AED 100,000 | Committed |
Year one regulatory total | AED 220,000 | Of which 120,000 spent |
B. Broker-dealer using a VARA-licensed custodian
Item | Amount | Type |
|---|---|---|
Application fee | AED 100,000 | Spent |
Year one supervision | AED 200,000 | Spent, recurring |
Paid-up capital | AED 400,000 or 15% FAO | Committed |
Year one regulatory total | From AED 700,000 | Of which 300,000 spent |
C. Exchange running its own custody
Item | Amount | Type |
|---|---|---|
Application fee | AED 100,000 | Spent |
Year one supervision | AED 200,000 | Spent, recurring |
Paid-up capital | AED 1,500,000 or 25% FAO | Committed |
Year one regulatory total | From AED 1,800,000 | Of which 300,000 spent |
Compare B and C against the alternative structure. An exchange partnering with a licensed custodian rather than self-custodying reduces the capital floor from AED 1,500,000 to AED 800,000 — AED 700,000 of freed balance sheet, for the cost of a commercial relationship. That trade is worth modelling properly before defaulting to full vertical integration.
Common budgeting mistakes
Treating the application fee as the cost of the licence — it is typically under 10% of year one
Confusing committed capital with spent capital, and reporting a single blended number to a board
Forgetting supervision is payable annually in advance, and forever
Ignoring the percentage-of-overheads test and budgeting only the fixed floor
Assuming in-principle approval permits revenue — it does not permit servicing clients
Defaulting to self-custody without pricing the capital consequence
Planning premises around a flexi-desk when the activity requires a closed-door private office
Frequently asked questions
What is the cheapest VARA licence?
Advisory Services, at AED 40,000 application, AED 80,000 annual supervision and AED 100,000 paid-up capital. VA Transfer and Settlement shares the same fee tier but carries different capital treatment.
Are the fees refundable if the application fails?
Application fees are non-refundable. That is why the Initial Disclosure Questionnaire stage exists — to surface fundamental problems before the full fee is committed.
Is paid-up capital an expense?
No. It is committed, held in a UAE trust account with VARA as beneficiary or via an acceptable surety bond. It remains yours but is not available as working capital, so it belongs on a different budget line from fees.
Can I reduce my capital requirement?
Structurally, yes. Using a VARA-licensed custody provider lowers the floor materially for Exchange, Broker-Dealer and Management activities. Reducing fixed annual overheads also helps where the percentage test binds.
How much for multiple activities?
Full application fee on the first activity and an extension fee — generally half — on each additional one. Supervision and capital, however, are charged per activity in full, so multi-activity licensing scales quickly.
How long does licensing take?
VARA publishes no end-to-end standard. Advisory commentary describes a process running many months. Plan by stage and revise against regulator feedback rather than assuming a fixed total.
Do I need a licence to trade my own capital?
Not a full VASP licence, but proprietary trading requires a no-objection certificate carrying a flat annual fee of AED 1,000 regardless of firm size.
The short version
Application fees run AED 40,000 to AED 100,000 per activity, supervision runs at double that annually, and paid-up capital ranges from AED 100,000 to AED 1,500,000 depending on activity and custody structure. Fees are spent; capital is committed; overheads recur and usually exceed both.
If one number should drive the plan, make it the capital floor — and price the custody structure before you assume you will build everything yourself.
Disclaimer: This guide is for information only and is not legal, financial or regulatory advice. Figures are drawn from VARA’s published fee schedule and Company Rulebook as reported in 2026 and may have changed — verify current requirements against VARA’s own published materials and take professional advice before budgeting or applying.
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