# What could your UAE stablecoin licence actually cost?

- Author: [Victoria Wells](https://ape.law/victoria-wells)
- Published: 2026-01-19
- Updated: 2026-09-24

[Licensing](https://ape.law/blog/category/licensing)

Compare published regulator fees with capital and reserve rules; do not treat a single fee as a complete UAE stablecoin budget.

[![Portrait of Victoria Wells](https://ape.law/brand/victoria-wells-square.png) By Victoria Wells](https://ape.law/blog/authors/victoria-wells)

Published 19 January 2026 · Updated 24 September 2026 · 3 min read

![Illuminated pillars labelled VARA, ADGM and CBUAE against the Dubai skyline.](https://ape.law/assets/blog/legacy/25eec5dc6aa4c7a5fa20ed981c4df5e63078314380c2f5296c43515012a437a2.webp)

A stablecoin budget starts with the token, the issuer, the service and the jurisdiction. Application fees, annual supervision, paid-up capital, reserve assets and operating costs are different amounts. A published regulator fee is not a reliable total project budget.

## What does VARA publish for issuance?

For Category 1 virtual-asset issuance, [VARA Schedule 2](https://rulebooks.vara.ae/rulebook/schedule-2-supervision-and-authorisation-fees) lists an AED 100,000 licence application fee and AED 200,000 annual supervision fee. Those figures cover the stated regulated activity. Additional activities, other authority fees and VARA’s risk-based adjustments require separate analysis.

For a licensed issuer of a full reserve virtual asset, VARA’s [FRVA capital rule](https://rulebooks.vara.ae/rulebook/f-capital-requirements) requires paid-up capital equal to **AED 1.5 million plus 2% of the value of the available FRVA supply**. The amounts are cumulative, not alternatives. Capital is distinct from the assets backing the token and from legal or technology costs.

## What if the token falls under the Central Bank regime?

The [CBUAE Payment Token Services Regulation](https://rulebook.centralbank.ae/en/entiresection/5731) has its own issuer, capital and reserve rules in Articles 13 and 22. The earlier description of a flat capital requirement and cash reserves “without exception” was incomplete. The exact capital calculation and reserve arrangement depend on the licensed issuer and permitted model. The Central Bank’s online rulebook was not consistently retrievable during this update, so this guide does not quote a CBUAE amount. Confirm the current operative text and applicable model directly before using a number in a transaction budget.

## What about ADGM?

ADGM’s FSRA has finalised a [fiat-referenced token framework](https://www.adgm.com/media/announcements/adgm-fsra-finalises-regulatory-framework-for-regulated-activities-involving-fiat-referenced-tokens). Permissions, fees and capital depend on the proposed activities. This guide does not quote an ADGM FRT application fee or trading-platform capital figure: the earlier figures were drawn from consultation-era or mismatched material and have not been verified against the final fee and prudential modules.

## How should you prepare a budget?

List each entity and regulated activity. Then record the current fee rule, annual supervision, paid-up capital, reserve composition, custody, compliance staff, audit and technology work in separate lines. State which amounts are refundable capital or reserve assets and which are expenses. Ask each relevant authority to confirm the classification before quoting a launch schedule.

## Sources and notes

- [VARA, Schedule 2](https://rulebooks.vara.ae/rulebook/schedule-2-supervision-and-authorisation-fees): Category 1 application and supervision fees; not an all-in budget.
- [VARA, FRVA capital requirements](https://rulebooks.vara.ae/rulebook/f-capital-requirements): AED 1.5 million **and** 2% of available supply.
- [CBUAE, Payment Token Services Regulation](https://rulebook.centralbank.ae/en/entiresection/5731), Articles 13 and 22: issuer capital and reserve arrangements. Direct retrieval was inconsistent during this update; no unverified amount is quoted here.
- [ADGM FSRA, final FRT-framework announcement](https://www.adgm.com/media/announcements/adgm-fsra-finalises-regulatory-framework-for-regulated-activities-involving-fiat-referenced-tokens): framework context, not proof of a particular fee.

*Updated 24 September 2026. Figures are rulebook amounts for stated activities, not a quote or legal advice.*

**General information only**

This article is general education and does not constitute personal legal, tax, financial, investment or regulatory advice. Rules, programmes and regulatory positions can change. Obtain advice from appropriately qualified professionals who understand your facts and the relevant jurisdictions before acting.

Relevant legal service

## Stablecoin Regulatory Advisory

Separate issuing, holding, transferring and using a stablecoin, then review the role your business actually performs.

[Review a stablecoin model](https://ape.law/services/stablecoin-regulatory-advisory)

[Discuss your situation](https://ape.law/#contact)

[stablecoins](https://ape.law/blog?q=stablecoins)

[VARA](https://ape.law/blog?q=VARA)

[CBUAE](https://ape.law/blog?q=CBUAE)

[regulatory capital](https://ape.law/blog?q=regulatory%20capital)

![Portrait of Victoria Wells](https://ape.law/brand/victoria-wells-square.png)

About the author

## Victoria Wells

Principal & Co-Founder

Victoria leads Ape Law’s Web3 legal practice across licensing, tokenization and regulation. She is also a founding partner of Project Get Out.

[View profile and articles](https://ape.law/blog/authors/victoria-wells)

Keep reading

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Canonical page: https://ape.law/blog/stablecoin-license-costs-uae