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What a VARA licence requires as capital is not one number but a stack, and the figures a firm actually has to hold are usually not the round numbers in the table.
What a VARA licence requires as capital is not one number but a stack, and the figures a firm actually has to hold are usually not the round numbers in the table. Three layers run at once, and a fourth is added for stablecoin issuers.
The base layer is paid-up capital, set by the activity licensed. As a floor it ranges from AED 100,000 for advisory services to AED 1,500,000 for a standalone exchange (Company Rulebook, Rule VI.B.1, current as at 1 July 2026). But for most activities the requirement is expressed as the higher of a fixed sum or a percentage of the firm’s fixed annual overheads, so for any firm of real size the binding figure is the percentage, not the headline floor. Advisory is a flat figure, and issuance is sent out to the Issuance Rulebook rather than given a number here. For everything in between, the table sets the minimum, not the answer.
On top of that base sits an ongoing liquidity requirement. A VASP must hold net liquid assets worth at least 1.2 times its monthly operating expenses at all times, reconciled daily (Rule VI.C.1 and C.3). This layer has no fixed number at all. It is a multiple of whatever the firm spends, so it rises with the business and is measured continuously, not met once at licensing.
Two further layers apply by circumstance. Insurance and reserve-asset requirements sit in the same Part of the Company Rulebook, and for issuers of fiat- or asset-referenced stablecoins the paid-up capital figure is set not by the table but by the Issuance Rulebook and its Annexes (Rule VI.B.1, Category 1 VA Issuance), as a separate charge tied to the size of the issuance. The wider stablecoin regime is the subject of the companion article “How are stablecoins regulated, and what falls to the Central Bank instead?”; here the point is only that issuance carries a capital layer the other activities do not.
So the honest headline is that the framework gives floors and formulas, not a single figure. Two firms licensed for the same activity can face materially different requirements, because the binding number turns on their overheads, their spending, and the conditions VARA sets at licensing. The rest of this article takes the layers one at a time, then shows why the real requirement for a given firm is firm-specific by design.
Paid-up capital is the base of the stack, fixed by the activity a firm is licensed for, and it is the floor from which everything else is measured. The full schedule is short enough to read in one place (Company Rulebook, Rule VI.B.1, current as at 1 July 2026):
| VA activity | Paid-up capital requirement |
|---|---|
| Advisory Services | AED 100,000. |
| Broker-Dealer Services | Using a VARA-licensed custodian, or otherwise approved during licensing: the higher of AED 400,000 or 15% of fixed annual overheads. In all other cases: the higher of AED 600,000 or 25%. |
| Category 1 VA Issuance | As specified in the VA Issuance Rulebook and its Annexes. |
| Custody Services | The higher of AED 600,000 or 25% of fixed annual overheads. |
| Exchange Services | Using a VARA-licensed custodian, or otherwise approved during licensing: the higher of AED 800,000 or 15%. In all other cases: the higher of AED 1,500,000 or 25%. |
| Lending and Borrowing Services | The higher of AED 500,000 or 25% of fixed annual overheads. |
| VA Management and Investment Services | Using a VARA-licensed custodian, or otherwise approved during licensing: the higher of AED 280,000 or 15%. In all other cases: the higher of AED 500,000 or 25%. |
| VA Transfer and Settlement Services | The higher of AED 500,000 or 25% of fixed annual overheads. |
Two things about the table matter more than the figures in it. The first is the phrase that governs most of the rows: the requirement is the higher of a fixed sum or a percentage of the firm’s fixed annual overheads. For a small firm the fixed sum binds, because a percentage of modest overheads falls below it. For a firm of any real size the percentage binds, because a quarter, or even a sixth, of a serious operating budget quickly exceeds the floor. So the AED figures are not the requirement. They are the lowest the requirement can be, and most licensed firms hold more, calculated off their own cost base.
The second is the discount built into the percentage. Where a firm uses a VARA-licensed custodian, or is otherwise approved during licensing, the percentage is 15% and the fixed floor is lower; in every other case the percentage is 25% and the floor is higher. The effect is clearest at the extremes. An exchange that places client assets with a licensed custodian faces the higher of AED 800,000 or 15% of overheads; an exchange that holds those assets itself faces the higher of AED 1,500,000 or 25%. The difference between the two is the price the framework puts on holding client assets on your own book, and the same discount runs through broker-dealer, exchange and management alike. The capital rule and the custody rules examined in the companion article “What can a VASP do with client virtual assets?” are two views of one judgement about who should hold client assets.
For a firm licensed to carry on more than one activity, the requirements add. The firm holds the sum of the amount for each activity, and calculates each activity’s figure on the overheads attributable to that activity alone, split so that they are “mutually exclusive and collectively exhaustive” across the business, with total overheads accounted for in full and nothing counted twice (Rule VI.B.2). Paid-up capital is reconciled monthly. A multi-activity firm does not pick its largest single requirement; it carries them stacked.
How the capital is held is itself prescribed, and the form tells you who it is for. Paid-up capital must sit in a trust account with a UAE-licensed bank naming VARA as beneficiary, or in an open-ended surety bond from a UAE-authorised surety company again naming VARA as beneficiary, or in another manner VARA specifies when it grants the licence (Rule VI.B.3). In the two standing forms VARA is the named beneficiary, and the third is left to VARA’s own specification. Either way, the capital is held where the regulator can reach it, which is the same intervention logic that runs through the wind-down rules examined in the companion article “If my VASP fails, where does my crypto sit?”.
Paid-up capital, then, is the floor set at licensing and checked monthly. The layer that moves with the business, and is checked every day, is net liquid assets. Section III takes it.
Net liquid assets is the layer that moves with the business, and unlike paid-up capital it is tested every day. Where paid-up capital is a floor set at licensing, net liquid assets is a live solvency buffer: a VASP must hold, at all times, current liquid assets whose surplus over its current liabilities is worth at least 1.2 times its monthly operating expenses (Company Rulebook, Rule VI.C.1, current as at 1 July 2026).
The shape of that rule matters. It is a surplus test, not a balance held to one side. Liquid assets, less liabilities, must exceed the equivalent of 1.2 months of operating expense, and because the benchmark is the firm’s own monthly cost, the requirement has no fixed figure. It scales with the business. A firm that doubles its cost base doubles the buffer it must carry, whether or not its paid-up capital floor has moved at all. And it is not a hurdle cleared once: net liquid assets must be reconciled daily and reported to VARA monthly (Rule VI.C.3), so the buffer is a condition of continuing to operate, not of getting licensed.
What may count toward the liquid side is narrow, and deliberately so. Net liquid assets may be held only in cash and cash equivalents as defined under recognised accounting standards, and in virtual assets referencing the US dollar or the dirham that VARA has approved (Rule VI.C.4). A firm cannot meet the requirement with its own inventory of volatile tokens. The buffer must be genuinely liquid, and the only virtual assets that qualify are approved ones referencing the dollar or the dirham, which is as close to cash as the asset class gets.
The liabilities side carries a charge particular to this sector. When calculating the requirement, a firm must fold an agreed portion of its “Operational Exposure to Virtual Assets” into its current liabilities (Rule VI.C.2). That raises the liabilities figure, and so raises the surplus the firm must hold to stay above the 1.2 multiple. The portion is not fixed by the rule; it is agreed with VARA as a condition of the licence. So even this formula is not purely mechanical. Its most consequential input is set firm by firm, at licensing, which is the same pattern as the paid-up capital percentages: a published rule whose binding value is calibrated to the individual firm.
Net liquid assets, then, is a daily, self-scaling solvency test with a firm-specific input. It and paid-up capital are the two layers every VASP carries. The layers that apply by circumstance, insurance, reserve assets, and the capital charge that falls on stablecoin issuers, are Section IV.
Above paid-up capital and net liquid assets, the same Part of the Company Rulebook adds two more requirements that every VASP carries, and the Issuance rules add a fifth that falls only on stablecoin issuers.
The first does the most work, and it is easy to overlook because it is short. A VASP must hold, at all times, reserve assets equal to 100% of the liabilities it owes to clients across all of its activities, held one-to-one in the same virtual asset in which those liabilities are owed, reconciled daily and audited by an independent third party at least every six months (Company Rulebook, Rules VI.E.1 to E.3, current as at 1 July 2026). This is a full backing requirement, not a buffer. It scales exactly with what the firm owes rather than sitting at a floor, and it must be held in the same asset, so a firm cannot back a bitcoin liability with dirhams. It complements the client-asset rules of the companion articles “What can a VASP do with client virtual assets?” and “If my VASP fails, where does my crypto sit?”: those decide whose assets these are, and this one requires the firm to hold, one for one, the value it owes.
The second is insurance. Every VASP must carry insurance adequate to the size and complexity of its business, in the manner VARA specifies in its licence: professional indemnity, directors’ and officers’, commercial crime cover or similar for all virtual assets held in hot wallets, and any further cover VARA assesses as appropriate and writes into the licence (Rule VI.D.1). It must be placed with a regulated insurer (Rule VI.D.2), and it may be held by another group entity provided the VASP is a named insured with its cover level stated (Rule VI.D.3). Where a firm genuinely cannot meet a requirement, VARA may accept alternative protection set as a licence condition (Rule VI.D.4). As with the capital percentages, there is no fixed sum in the rule. The adequate level is calibrated to the firm and fixed at licensing.
The fifth layer falls only on issuers, and the two stablecoin types are calculated in opposite ways. A fiat-referenced issuer must hold paid-up capital equal to AED 1,500,000 plus 2% of the value of the coin’s available supply (Virtual Asset Issuance Rulebook, Annex 1, Rule III.F.1). An asset-referenced issuer must hold the higher of AED 1,500,000 or 2% of the average market value of its reserve assets over the preceding twenty-four months, where applicable (Annex 2, Rule III.G.1). The arithmetic is the point. The fiat-referenced charge adds the fixed sum and the percentage, so it exceeds AED 1,500,000 the moment any supply is in issue; the asset-referenced charge takes whichever limb is greater, so it holds at AED 1,500,000 until 2% of the reserve average grows past it. The headline numbers are identical and the results diverge. The rest of the stablecoin regime, its backing, redemption, audit and the treatment of dirham-referenced tokens, is the subject of the companion article “How are stablecoins regulated, and what falls to the Central Bank instead?”; only the capital charge belongs here.
So the full stack runs to as many as five layers: paid-up capital, net liquid assets, a 100% reserve against client liabilities, insurance, and, for issuers, the issuance capital charge. Not one of them resolves to a single clean figure a firm can be told in advance. Section V explains why that is deliberate, and what actually sets the binding number.
The reason none of these layers resolves to a single number is that the framework publishes floors and formulas, then keys almost every layer to inputs that differ from one firm to the next. The binding figure is assembled from a firm’s own numbers and its licence conditions. It is not read off a table.
Start with the base. For most activities, paid-up capital is the higher of a fixed sum or a percentage of fixed annual overheads, with advisory a flat figure and issuance following the Annex formulas of Section IV (Rule VI.B.1). The floor binds only the smallest firms; for a firm of any size the percentage binds, and the percentage runs off the firm’s own cost base, so two firms in the same activity with different overheads owe different amounts. The custody discount moves the figure again: a firm that places client assets with a licensed custodian is charged 15% against a lower floor, and a firm that holds them itself is charged 25% against a higher one (Section II). Before any firm-specific number is entered, the rate itself depends on a structural choice the firm has made.
A firm with more than one licence compounds this. It holds the sum of the requirement for each activity, each calculated on the overheads attributable to that activity alone (Rule VI.B.2). So the number depends not only on total overheads but on how a particular business splits its costs across the activities it runs. Two firms with the same headline budget and the same licences can still owe different amounts.
The live layers are firm-specific by construction. Net liquid assets is 1.2 times the firm’s own monthly operating expense, measured daily, and it folds into liabilities a portion of the firm’s operational exposure to virtual assets that is agreed with VARA at licensing (Rules VI.C.1 and C.2). Reserve assets track the liabilities the firm owes its clients, so they rise and fall with the book (Rule VI.E.1). Insurance is set at the level adequate to the size and complexity of the business, as VARA specifies (Rule VI.D.1). Each of these has its size fixed by what the firm actually does, not by a number in the rules.
Several of the inputs are set by VARA, firm by firm, as conditions of the licence. The manner in which paid-up capital is held, the portion of virtual-asset exposure that counts toward liabilities, the adequate level of insurance, and any alternative protection where cover cannot be obtained, are all fixed in the licence rather than in the rulebook (Rules VI.B.3, VI.C.2, VI.D.1 and D.4). The published rules set the structure; the licence sets several of the values.
So the honest answer to what a VARA licence requires as capital is a structured one, not a figure. It is a floor set by activity, a percentage of your overheads at a rate that depends on how you hold client assets, a daily multiple of your spend, a full reserve against what you owe your clients, insurance scaled to your business, and, for an issuer, a charge on your supply or reserves, with several of the inputs fixed in your licence. Anyone who answers with a single clean number is quoting the floor, not the requirement. The way to know the figure is to run your own overheads, spend and client liabilities through the formulas and then confirm the licence conditions, which is a modelling exercise and a licensing conversation, not a look-up.
What is settled here is the architecture and the figures, and on the current rulebooks neither is in doubt. Capital is a stack of up to five layers: paid-up capital set by activity, from a flat AED 100,000 for advisory to the higher-of floors and overheads percentages for everything else (Rule VI.B.1); net liquid assets at 1.2 times monthly operating expense, measured daily (Rule VI.C.1); a reserve equal to 100% of the liabilities owed to clients, in the same asset (Rule VI.E.1); insurance adequate to the business (Rule VI.D.1); and, for issuers, AED 1,500,000 plus 2% of supply for a fiat-referenced coin, or the higher of AED 1,500,000 or 2% of the twenty-four-month reserve average for an asset-referenced one (Annex 1 III.F.1; Annex 2 III.G.1). Every figure in this article was read at source, and every rule it rests on sits on the 19 June 2025 version.
What is open is smaller than in the insolvency article, and it is of two specific kinds. The first is currency. These figures are version-specific, and VARA revises its rulebooks on their own cycles, so a number correct today is not permanent. Even what counts toward a layer is version-set: net liquid assets may be held in cash equivalents and in approved dollar- or dirham-referenced virtual assets (Rule VI.C.4), a rule the current version fixes and a later one could change. A capital figure is worth confirming against the current rulebook at the point it is relied on, not carried forward on trust.
The second is not really uncertainty but a property of the design: the published rules do not yield a given firm’s actual requirement. The binding number is assembled from the firm’s own overheads, spending and client liabilities, at a percentage rate that depends on how it holds client assets, with several inputs fixed by VARA in the licence, the manner of holding capital, the virtual-asset exposure counted as a liability, and the adequate insurance level (Rules VI.B.3, VI.C.2, VI.D.1). So “what will my firm actually hold” is answered by a modelling exercise against these formulas and by the licensing conversation, not by the table. The rulebook is precise about the structure and deliberately silent on the single number.
So the throughline of the article is that the framework gives an honest architecture rather than a headline. Floors mark the minimum, percentages tie the requirement to the firm’s own scale, the reserve ties it to what the firm owes, and the licence fixes the rest. The one thing the framework declines to provide, a single clean figure that fits every firm in an activity, is the thing it should decline to provide, because that figure would be wrong for almost everyone. What a firm can do is run its own numbers through the layers, confirm the current version, and settle the conditions at licensing. That is the real answer to what a VARA licence requires as capital.
For your facts, in confidence, put the question to the firm.
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