Middle East/VARA/Comparables
Dubai (VARA)
Virtual Assets Regulatory Authority
The only purpose-built virtual-asset regulator in this file. VARA licences issuance, brokerage, custody, exchange and related activities in mainland Dubai. It is not ADGM and not DIFC. “Dubai regulated” without the authority and the activity code is not a source.
Seat
Mainland
Model
Activity
Passport
None
Similar regulation
The statute book
Primary instruments, with the RCA job each one actually does. Links open the official text.
- In force
Issuance licence — the closest activity-coded analogue to “being allowed to sell the token”
Translation
Rule 100–500 map
| RCA | Peer | Fit | Desk |
|---|---|---|---|
| Rule 100 | Virtual asset under VARA regulations | Partial | Activity-based, not Howey-based. |
| Rule 200 / 300 | VA issuance licence + marketing rules | Partial | You are licensed to issue, not exempted from a securities Act. |
| Rule 103 | White paper / disclosure duties under the issuance rulebook | Analogue | Closer to MiCA Title II than to a 103 website. |
| Rule 500 | No passport to ADGM, DIFC, or the UAE federal layer | No analogue | Three Dubai/UAE perimeters, zero passport. |
Analysis
What the file is
VARA is what people mean when they say a Gulf city licensed token issuance as a business line. The rulebook is activity-coded: an issuance licence is not a custody licence. Marketing that names “Dubai” and does not name VARA, the licence number and the activity is, on this desk, incomplete. There is no passport into the ADGM FSRA framework or the DIFC DFSA framework, and there is no NSMIA.
Research
The record
- Public register of licensed VASP activities is the evidence. A founding-partner press release is not.
- Issuance rulebook white-paper duties are the Rule 103 comparable — prescribed contents, regulator-facing, not a five-principle website.
Ideation
What to file
- If you hold a VARA issuance licence and would also file a NOR, say so. That is the dual-path take-up the PRA model is missing.
- Do not describe VARA as “MiCA for the Gulf.” It is an activity regulator in one emirate. MiCA passports. VARA does not.
Analysis
What the file is
VARA is what people mean when they say a Gulf city licensed token issuance as a business line. The rulebook is activity-coded: an issuance licence is not a custody licence. Marketing that names “Dubai” and does not name VARA, the licence number and the activity is, on this desk, incomplete. There is no passport into the ADGM FSRA framework or the DIFC DFSA framework, and there is no NSMIA.
Primary sources on file
Virtual Assets and Related Activities Regulations
VARA — Dubai/7 Feb 2023/RCA review 8 Aug 2026
Primary regulatory
RCA publishes source-linked intelligence for professionals. Nothing here is a token-buying call, a legal opinion, or an “approved / safe / regulated” badge. Every material claim is dated. Incomplete files stay incomplete.