Licensed VASP Summary

Total Licensed VASPs (approx.): 21

Licensing Framework: Two-Step MVP Process

Regulatory Basis: Virtual Assets and Related Activities Regulations 2023

Public Register: VARA Public Register

Key Licensing Milestones

Licensed Activity Categories

VARA licenses VASPs across seven regulated activity categories:

1. Advisory Services — Virtual asset investment advice
2. Broker-Dealer Services — Intermediated trading (BitOasis — first operational licence)
3. Custody Services — Digital asset safekeeping (Hex Trust, Komainu)
4. Exchange Services — Trading platforms (Binance, OKX)
5. Lending and Borrowing — Virtual asset lending
6. Payment and Remittance — VA-based payment services
7. VA Management and Investment — Portfolio management

Additional licence codes include VA Issuance (Category 1, created November 2023) and VA Proprietary Trading (created May 2023).

Regulatory Context

Licensed VASPs are subject to comprehensive ongoing compliance obligations, including AML/CFT requirements, Travel Rule implementation, marketing regulations, and consumer protection standards.

VARA’s enforcement actions against 36+ unlicensed entities demonstrate the consequences of operating without proper licensing.

For licensing costs, see our fee structure analysis. For guidance on the application process, see our how-to guide.

Source: VARA Public Register | VARA News

For complementary intelligence, visit UAE Tokenization Regulations.

Licensed VASP Ecosystem Analysis

The licensed VASPs dashboard tracks all entities that have received VARA licensing to conduct virtual asset activities in the Emirate of Dubai. As of early 2026, approximately 21 entities hold VARA licences, spanning multiple activity categories and representing both international and regional operators.

Licensed Entity Profiles

Major licensed entities include:

• Binance Dubai: MVP Licence, September 2022. One of the earliest major exchange licensees, operating exchange services.
• BitOasis: MVP Operational Licence, May 2023. First broker-dealer to complete the full two-step process. MENA-native platform.
• Crypto.com Dubai: MVP Preparatory Licence, March 2023. Consumer-focused global platform with 80+ million users worldwide.
• OKX Middle East: MVP Preparatory Licence, June 2023. Positioning UAE as strategic global and regional business hub.
• Bybit Dubai: VARA-licensed entity. Global headquarters relocated to Dubai, major derivatives platform.
• Rain Financial: MENA-focused platform with multi-jurisdictional GCC regulatory presence.
• GCEX MENA: MVP Preparatory Licence, February 2023. Digital prime brokerage.
• Enjinstarter MENA: Initial approval announced May 2023. Web3 launchpad and advisory.

Licensing Trends

VARA’s licensing activity has evolved through distinct phases:

Phase 1: Early Licensees (2022): Binance Dubai and initial MVP licensees established the precedent for major international exchanges entering Dubai’s regulated framework.

Phase 2: Expansion (Early 2023): Publication of the Virtual Assets and Related Activities Regulations 2023 on February 7, 2023, triggered a wave of licensing activity. GCEX, Crypto.com, BitOasis, and OKX all received licences in this period.

Phase 3: Market Maturation (2024-2026): Ongoing licensing of specialised providers alongside enhanced supervision of existing licensees. The focus shifted from licensing new entities to supervising the growing regulated ecosystem.

Compliance Obligations for All Licensed VASPs

All licensed entities must maintain comprehensive compliance programmes covering:

• AML/CFT/CPF requirements (March 2026 implementation circular)
• Virtual Assets Travel Rule (February 2026)
• FATF high-risk jurisdiction screening (January 2026)
• Qualified investor classification (January 2026)
• EOCN sanctions screening (November 2025)
• Marketing regulations compliance
• Rulebook v2.0 requirements (May 2025)

Public Register

VARA maintains a public register of licensed VASPs accessible through vara.ae. The register is complemented by the SCA-VARA unified register providing federal-level recognition.

For entity-specific analysis, see our entity profiles. For the licensing process, see our two-step licensing guide and fee structure.

Activity Category Distribution

Licensed VASPs span multiple activity categories, with exchange services being the most common:

• Exchange Operations: Binance Dubai, OKX Middle East, Bybit Dubai, Crypto.com Dubai
• Broker-Dealer Services: BitOasis (first MVP Operational Licence)
• Custody Services: Multiple entities, subject to custody and staking rules
• Advisory Services: Specialised advisory firms
• Other Categories: Lending/borrowing, payment/remittance, VA management

Licensing vs Enforcement Balance

As of early 2026, the ratio of licensed to enforced entities is approximately 21:36+ — meaning VARA has taken enforcement action against nearly twice as many unlicensed entities as it has licensed. This ratio reflects the regulator’s commitment to market integrity and the scale of unlicensed activity that existed before VARA’s systematic enforcement campaign.

Monitoring Regulatory Status

VARA’s public register provides the authoritative source for verifying an entity’s licensing status. The SCA-VARA unified register extends this verification to the federal level.

For compliance professionals and counterparty due diligence teams, verifying VARA licensing status should be a standard step when engaging with virtual asset service providers operating in or from Dubai. The enforcement record demonstrates the consequences of operating without authorisation.

Licensing Pipeline and Market Growth

The licensed VASP ecosystem continues to grow as VARA processes additional applications. The pipeline of entities at various stages of the licensing process — from initial engagement through preparatory licensing to operational licensing — provides forward visibility into the evolution of Dubai’s regulated virtual asset market.

Factors Driving Licensing Applications

Several factors drive ongoing demand for VARA licensing:

• Enforcement Deterrence: VARA’s enforcement record (36+ actions against unlicensed operators) makes operating without a licence increasingly untenable
• Institutional Demand: Institutional investors and corporate partners increasingly require regulatory licensing as a prerequisite for engagement
• Banking Requirements: UAE banks are increasingly requiring VARA licensing as a condition for maintaining banking relationships with virtual asset businesses
• Global Regulatory Convergence: As regulation becomes the global norm, VARA licensing provides a credible credential for multi-jurisdictional operators
• Market Growth: Dubai’s growing virtual asset market creates commercial incentives for licensed entry