From research to a working plan.
Regulation
VARA regulates virtual assets across Dubai mainland and free zones except DIFC. DIFC uses the DFSA’s financial-services framework, while ADGM has its FSRA virtual-asset framework. Identify where the activity takes place, which entity contracts with clients and who controls their assets. Other UAE authorities may be relevant to the product or activity.
Exchange verification
Read each provider’s status and authorised activities in the relevant regulator’s register. VARA distinguishes fully licensed firms from applicants holding in-principle approval. Its register expressly states that an IPA holder cannot begin virtual-asset operations or serve clients until a full licence is obtained. Match the register entry to the legal entity in your agreement.
Tax and record keeping
The Federal Tax Authority distinguishes a natural person’s business activity from qualifying personal investment income. Its guidance says a natural person comes within corporate tax when UAE business turnover exceeds AED 1 million in a calendar year, while specified personal income categories are excluded. Determine whether the particular activity meets those definitions. A company’s treatment requires its own assessment.
Starting a business
Choose the route after mapping the activities. A custody business, token issuer and software developer require different questions. DIFC’s rules effective 12 January 2026 place Crypto Token suitability assessment directly on firms. A business using that route must document and maintain its assessment against the DFSA criteria.
Banking and payments
Prepare the account-opening evidence around the actual flows of money. Show the ownership structure, business activity, anticipated counterparties and source of funds. Ask the bank which crypto-related transfers it will support and obtain its requirements for the proposed account. Use CryptoGov’s UAE business explorer and exchange directory to organise the research.
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