Dubai's VARA Issues World-First Guidance on Token Issuance Categories

9 April 2026 - 09:00 CEST
Dubai VARA Guidance
Tempura

(Updated with link to guidelines and exclusive comment from CEO Matthew White)

Dubai’s Virtual Assets Regulatory Authority (VARA) has published dedicated guidance on its Virtual Assets Issuance Rulebook, making the emirate the first jurisdiction to provide detailed, category-based rules for how digital assets must be created, disclosed, and distributed in a regulated environment.

The 76-page document clarifies three issuance pathways for entities issuing virtual assets (VAs) in the course of business in Dubai. All issuers must prepare a white paper detailing the token’s purpose, features, rights, and risks, plus a Risk Disclosure Statement to aid investor decisions. Compliance does not constitute regulatory endorsement of any token or issuer.

Matthew White, VARA Chief Executive Officer, told Sandmark, "What this guidance represents is a natural evolution in how virtual asset markets are structured... By setting clear, enforceable expectations around how virtual assets are created, disclosed and distributed, we are addressing the foundations of the market itself. Not all virtual assets carry the same risk profile or serve the same function, and regulation needs to recognize that."

Category 1 requires full licensing

Category 1 covers fiat-referenced virtual assets (FRVAs, such as stablecoins) and asset-referenced virtual assets (ARVAs), including tokens backed by real estate, commodities, or other real-world assets. Issuers must obtain a specific VARA licence, comply with multiple compulsory rulebooks, maintain reserve assets, and secure prior approval of their white paper. Real estate tokenization projects, for example, must clearly outline profit or income distribution to token holders.

Lighter rules for category 2 and exempt assets

Category 2 includes most other tokens, such as governance or protocol-linked assets. Issuers need no direct licence but must route all placement and distribution through VARA-licensed distributors or broker-dealers, who handle due diligence.

Exempt virtual assets face minimal requirements. These cover non-transferable tokens and redeemable closed-loop assets, such as certain loyalty points or restricted community badges, provided no secondary markets form around them. All categories still require adherence to general integrity rules.

Ruben Bombardi, VARA General Counsel, said: "Trust is built through clarity, and clarity begins with disclosure. By strengthening the standards around how virtual assets are issued and communicated to the market, this guidance reinforces Dubai’s position as a jurisdiction that enables responsible innovation while safeguarding market integrity."

Dubai advances regulated crypto hub status

Established in 2022, VARA oversees virtual assets across most of Dubai (excluding the Dubai International Financial Centre). The guidance shifts focus from trading to token formation, building on the authority’s recent rules for crypto derivatives trading, which introduced client suitability assessments and margin controls.