A VARA budget starts with the licensed activities, not one advertised package price. Application and annual supervision fees are charged by activity. Regulatory capital, company setup, people, compliance and technology sit outside those headline fees.
This guide consolidates Ape Law’s earlier VARA cost, licensing, VASP and security-readiness articles. The fee table below was checked against VARA Schedule 2 on 22 September 2026.
What Are VARA’s Published Fees?
| VA activity | Application fee | Annual supervision fee |
|---|---|---|
| Advisory | AED 40,000 | AED 80,000 |
| Transfer and settlement | AED 40,000 | AED 80,000 |
| Broker-dealer | AED 100,000 | AED 200,000 |
| Category 1 issuance | AED 100,000 | AED 200,000 |
| Custody | AED 100,000 | AED 200,000 |
| Exchange | AED 100,000 | AED 200,000 |
| Lending and borrowing | AED 100,000 | AED 200,000 |
| Management and investment | AED 100,000 | AED 200,000 |
The application fee covers one activity. Schedule 2 provides an extension-fee mechanism for each additional activity, while annual supervision is payable for each licensed activity. VARA can also modify fees based on a firm’s risk profile and regulatory burden.
What Does the Fee Table Exclude?
The published amounts are only one part of the first-year budget:
- paid-up capital under the applicable rulebooks;
- entity formation, premises and commercial-licence costs;
- compliance, MLRO, governance and senior-management roles;
- AML/CFT, sanctions, Travel Rule and transaction-monitoring systems;
- custody, wallet, security and operational-resilience controls;
- audit, insurance, banking and professional advisers; and
- the cost of responding to regulator questions and maintaining the permission.
Capital should not be described as a fee. Its calculation can depend on the activity, custody model and fixed annual overheads, so it must be modelled from the current rulebook and the applicant’s forecast.
Which Activities Apply?
VARA’s activity schedule defines the regulated categories. Map each customer flow against those definitions. A platform may need more than one activity where it arranges transactions, holds assets, operates a venue and transfers assets.
Product labels are unreliable. “OTC desk,” “wallet,” “marketplace” or “advisory platform” can each describe several different legal roles. The application should use one consistent activity map across the business plan, financial model, policies and technology description.
How Do Security and Operating Controls Affect Cost?
Security is not a bolt-on document. Wallet architecture, access management, outsourcing, incident response, logging, business continuity and client-asset controls affect the people and systems required to operate.
Before filing, build a control matrix showing the rule, owner, evidence and testing process. This is more useful than copying a generic policy pack that does not match the product.
What Should Your VARA Cost Model Show?
- Each proposed activity and the reason it applies.
- Application and annual fees per activity.
- The current capital calculation and its assumptions.
- Entity, office, visa and commercial costs.
- Named regulatory and operational roles.
- Technology, custody, monitoring, audit and insurance spend.
- A contingency for changes requested during review.
Model at least the application year and the first full operating year. A project that can fund the filing but not the ongoing control environment is not application-ready.
For jurisdiction selection, start with the UAE crypto licence guide. Our UAE licensing case study illustrates why an exchange assessed its operating model before starting an application. For a scoped application review, see Ape Law’s VARA licence application service.
This article is general information, not a quotation or legal advice. Confirm the current VARA rulebooks, fees, capital treatment and application expectations for the specific business model.
Stephan Roberto
