VARA Issuance Guidance

The Virtual Assets Regulatory Authority [VARA] has published its Guidance on the Virtual Asset Issuance Rulebook - making Dubai the first jurisdiction globally to codify how digital assets must be created, disclosed, and distributed within a fully licensed environment.

The Guidance clarifies three issuance pathways:

Category 1 - Fiat-Referenced Virtual Assets (FRVAs) and Asset-Referenced Virtual Assets (ARVAs). Requires a VARA licence, whitepaper approval, reserve asset management, and ongoing compliance with all four compulsory rulebooks.

Category 2 - All other virtual assets (excluding Exempt VAs). No issuer licence required, but all placement and distribution must be carried out by a VARA-licensed Broker-Dealer acting as Licensed Distributor, who assumes responsibility for issuer compliance validation.

Exempt VAs - Non-transferable and redeemable closed-loop virtual assets only. No licence or approval required, but general conduct obligations apply.

CFC MENA has supported tokenisation and issuance licensing across multiple VARA-regulated structures including real estate fractionalisation, maritime trade finance, and equity-linked digital assets. Our experience spans the full issuance lifecycle - from token classification and whitepaper development to Category 1 licence applications and Licensed Distributor engagement.