21/09/25
This update details the latest revisions to the UAE’s regulatory framework for virtual assets, focusing on the September 2025 VARA rulebook updates, the formalised cooperation between VARA and SCA, and what Virtual Asset Service Providers (VASPs) must do to comply. We cover the legal changes, the reasoning, and how these compare with earlier rules.
🧾 Recent Rulebook Revisions by VARA
On 8 September 2025, VARA published updates to its full set of rulebooks: not only the VA Activity-specific ones (Exchange, Custody, Lending & Borrowing, Transfer & Settlement, Advisory, Broker-Dealer, Management & Investment) but also the compulsory rulebooks (Company; Compliance & Risk Management; Technology & Information; Market Conduct) and the Virtual Asset Issuance Rulebook.
The Virtual Assets and Related Activities Regulations 2023 remain the legal backbone for these rulebooks.
Key changes include refined definitions (especially around client assets, collateral arrangements), enhanced technical/operational governance provisions, stronger risk management and compliance standards.
The June 2025 transition deadline (19 June 2025) remains relevant for many of the earlier rulebook versions; the September updates reflect further refinements rather than wholesale new categories.
🤝 SCA-VARA Unified Framework: What Is Established
The UAE’s Securities & Commodities Authority (SCA) and Dubai’s VARA have formalised a partnership aimed at harmonising the regulation of virtual assets across the country.
Among the core features: mutual recognition of VASP licenses granted by one authority being recognised by the other, though this is subject to regulatory checks (AML/CFT, operational readiness, governance, etc.). It is explicitly not automatic passporting of licenses across all jurisdictions.
As part of the partnership, a Coordinating Committee for Legislative Review has been or will be created, chaired by SCA, to align existing and new regulations with international best practices.
The partnership also includes mechanisms for joint oversight, shared supervision, data/information exchange, and coordinating enforcement where relevant.
🔍 What VASPs Must Do: Obligations & Examples
All VASPs operating under VARA must ensure compliance with the 8 September 2025 versions of the relevant rulebooks; this means reviewing internal policies, governance, technology, risk, and disclosure frameworks.
Issuers of Virtual Assets should classify their issuances correctly. Under VARA’s Issuance Rulebook: Category 1 issuances (including Fiat-Referenced Virtual Assets (FRVAs) and Asset-Referenced Virtual Assets (ARVAs) backed by real-world assets) require full licensing, disclosure via whitepapers, risk-statements, etc.
For VASPs with licenses under VARA wishing to operate or offer services beyond Dubai (e.g. other Emirates under SCA jurisdiction), the mutual recognition process simplifies cross-Emirate work but does not eliminate requirements: compliance with supervisory, governance, and AML/CFT checks under both regulators.
Technical and operational governance expectations have increased: wallet security, cybersecurity, system resilience, risk management, reporting, and audit trails. Those providing custody, transfer, or broker-dealer services in particular should ensure their arrangements (collateral, segregation, client assets) comply.
In conclusion, the September 2025 updates to the UAE virtual asset regulation reflect a maturing, clearer, and better coordinated regulatory environment. VARA’s rulebooks have been refined across all major domains (technical, operational, risk, governance, issuance). The SCA-VARA partnership is a confirmed step toward unified oversight, licensing reciprocity (not full passporting), and shared supervision. For VASPs, token issuers, exchanges, custodians, advisory services, etc., the message is clear: review your classification, your license, policies and technical controls under the latest rulebooks; ensure alignment with both VARA and SCA where applicable.
If you need assistance assessing whether your business operations are compliant under the September 2025 VARA rulebooks, or navigating the SCA-VARA framework (licensing, cross-Emirate operations, risk & disclosure), please contact NUR Legal. We are prepared to advise on strategy, compliance reviews, regulatory filings and enforcement risk.
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Emil Korpinen