VARA · ADGM · DIFC · federal CMA · Four regulators
United Arab Emirates
Four regulators, activity-by-activity licensing, and a federal re-licensing exercise with a closing date.
Verified
These claims have been checked against the instrument or the regulator's own material. Where a position is unsettled or a rule is still in draft, the page says so rather than implying certainty.
- SCA became the Capital Markets Authority on 1 Jan 2026
- Re-licensing grace period runs to 27 Feb 2027
- Conduct obligations apply throughout the grace period; supervision is live
Why this matters now
The UAE is among the most active jurisdictions in the world for digital-asset business formation, and one of the most structurally confusing: which regulator you fall under depends on where you sit and what you do, and the answer changes capital, governance and reporting requirements materially. Onshore, the Securities and Commodities Authority became the Capital Markets Authority on 1 January 2026, and the re-licensing grace period runs to 27 February 2027. The grace period is widely misread as a compliance holiday — it is not. Conduct obligations apply from day one and supervision is already live.
Who is in scope
Whether this reaches you.
- Virtual-asset service providers operating in or from the UAE
- Firms relocating into the UAE from other regimes
- Existing licensees caught by federal re-licensing
- Payment token service providers
Obligations
What the regime actually requires.
Choosing the right regulator
VARA, ADGM, DIFC or the federal regime — determined by location and activity, and expensive to get wrong.
Activity-by-activity licensing
Permissions are granted per activity, with capital and governance requirements attached to each.
Ongoing compliance
Reporting, cyber and AML obligations that are examined, not just filed.
Re-licensing
The transition has a closing date and the requirements are not identical to the previous regime. Conduct rules apply throughout — the grace period covers the licence, not your behaviour.
Dates
When.
| Date | Event |
|---|---|
| SCA became the Capital Markets Authority | |
| Federal CMA re-licensing grace period ends | |
| CARF first exchanges (wave two) |
What we do
How we help here.
- Regulator selection against your activity set
- Licence application preparation across VARA, ADGM and DIFC
- AML programme build and independent review
- Re-licensing transition management
- Substance and corporate tax interaction
Sources
- 01VARA rulebooks
Activity permissions and requirements — figures need checking against the rulebooks directly - 02ADGM FSRA virtual asset framework
Licensing route and conditions - 03CMA Decision No. 4/R.M of 2026 and Federal Decree-Law No. 32 of 2025
The virtual asset framework and the SCA to CMA succession
Does United Arab Emirates bind you?
Tell us where you are established, where your customers are and what you hold. That is usually enough to answer it — and to say what is already late.