Table of Contents
Frequently Asked Questions
What does activity code 6619.85 — Virtual Assets Exchange Services — actually permit a business to do
Activity code 6619.85 permits a business to facilitate the buying, selling, and conversion of virtual assets, including cryptocurrencies, digital tokens, and other blockchain-based instruments traded between counterparties or through a platform.
The scope is specific to executing or facilitating trades between buyers and sellers. It is not a catch-all licence — activities such as custody, brokerage, lending, or advisory services carry separate regulatory requirements and will need additional approvals beyond this activity code.
Who regulates virtual assets exchange businesses in Dubai
The primary regulator is the Virtual Assets Regulatory Authority (VARA), established under Dubai Law No. 4 of 2022. It is the world's first dedicated standalone virtual assets regulator and oversees Virtual Asset Service Provider (VASP) licensing at the emirate level.
For mainland-registered entities dealing with securities-linked products, the Securities and Commodities Authority (SCA) holds oversight. Operators must identify which authority governs their specific activity before incorporation, as the dual-regulator landscape is well-defined.
What licence does an operator need to legally run a crypto exchange in Dubai
Any entity operating under activity code 6619.85 must obtain a Virtual Asset Service Provider (VASP) licence issued by VARA. This licence comes with specific conditions attached to exchange operations, including minimum capital thresholds, governance requirements, and ongoing reporting obligations.
Operators should engage with VARA's licensing process before commencing any exchange activity. Running an exchange without the appropriate VASP licence would place the business outside Dubai's regulatory framework and expose it to enforcement action.
What are the AML and KYC compliance requirements for a virtual assets exchange in Dubai
Anti-money laundering (AML) and counter-financing of terrorism (CFT) compliance is non-negotiable. The Central Bank of the UAE sets the overarching AML standards that all virtual asset businesses must align with.
In practice, this means implementing a documented KYC programme, real-time or near-real-time transaction monitoring systems, suspicious activity reporting procedures, and appointing a designated compliance officer. Customer due diligence protocols and segregation of client assets from operating funds are also mandatory operational requirements.
What is the size and growth outlook of Dubai's virtual assets market
The UAE consistently ranks among the top ten countries globally for cryptocurrency adoption by both ownership rates and transaction volumes, placing it well ahead of most comparable economies in the Middle East and North Africa region.
The GCC digital assets market is projected to grow significantly through 2027, driven by both institutional and retail demand. Regional sovereign wealth funds, family offices, and international trading desks are actively seeking regulated UAE entities to access digital asset markets across the GCC, South Asia, and East Africa.
What tax advantages does the UAE offer for virtual assets businesses and investors
The UAE offers a highly favourable tax environment for virtual asset operators and investors. There is zero capital gains tax on crypto holdings and no personal income tax on cryptocurrency earnings in the UAE.
This positions Dubai as one of the most competitive jurisdictions globally for crypto businesses and individuals compared with major financial centres in Europe and Asia, where capital gains and income taxes on digital assets can be substantial.
How does a virtual assets exchange licence differ from a brokerage or custody licence
These are three distinct regulated activities. An exchange licence (activity code 6619.85) covers facilitating trades between buyers and sellers of virtual assets. A brokerage licence covers acting as an agent on behalf of a client to execute trades. A custody licence covers holding virtual assets on behalf of third parties.
Each carries its own regulatory requirements and approval process under VARA. Operators who intend to offer more than one of these functions — for example, both exchange and custody services — must obtain the relevant approvals for each activity separately rather than relying on a single licence.
Who is a virtual assets exchange licence in Dubai best suited for
The licence is well suited to founders building crypto trading platforms, fintech operators offering digital currency conversion services, and institutional desks looking to establish a regulated UAE presence from which to serve regional and international clients.
It is particularly relevant for businesses targeting institutional clients such as family offices or sovereign wealth funds seeking regulated access to GCC digital asset markets. However, operators whose core model includes custody, lending, or advisory functions will need to plan for additional regulatory approvals beyond this activity code alone.
How to Start a Virtual Assets Exchange Business in Dubai
Most financial centres are still arguing about how to treat crypto. Dubai stopped arguing. It wrote the law, set up a regulator, and opened the door to firms that play by the rules.
This guide covers the Virtual Assets Exchange Services license, activity code 6619.85. You will learn what the license lets you do, who checks up on you, what the market looks like, and how to set up with Meydan Free Zone.
Key Stats at a Glance
What a Virtual Assets Exchange License Covers
Activity code 6619.85 lets you help people buy, sell and swap virtual assets. That covers cryptocurrencies, digital tokens, and other things built on a blockchain, whether traded directly between two parties or through your platform.
What you can do. Match buyers with sellers and complete the trade. Swap one digital asset for another. Handle currency conversion for your users.
What you cannot do. This license does not cover everything crypto. Holding client assets, acting as an agent for a client, lending, and giving advice all sit outside it. Each needs its own approval.
Who it suits. Founders building a crypto trading platform. Fintech firms offering digital currency swaps. Trading desks that want a regulated UAE base to serve clients in the region and abroad.
Exchange, Brokerage or Custody: Which Do You Need
People mix these three up all the time. They are separate regulated jobs with separate approvals.
Want to do two of these? You need approval for each one. One license will not stretch to cover the rest, so map out your full business model before you apply.
Who Regulates Virtual Asset Exchanges in Dubai
<div class="mdf-post-table"><table border="1" cellpadding="10" cellspacing="0"><thead><tr><th>Body</th><th>What it does</th><th>When it matters to you</th></tr></thead><tbody><tr><td>VARA (Virtual Assets Regulatory Authority)</td><td>Sets the rules for virtual asset firms in Dubai. Issues the Virtual Asset Service Provider (VASP) license.</td><td>Always. No VASP license, no exchange.</td></tr><tr><td><a href="https://www.centralbank.ae/en/">Central Bank of the UAE</a></td><td>Sets the national anti-money laundering standards for all financial and crypto firms.</td><td>Always. Its rules sit on top of VARA's.</td></tr><tr><td><a href="https://www.sca.gov.ae/en/home">Securities and Commodities Authority (SCA)</a></td><td>Covers virtual asset work tied to securities and derivatives.</td><td>If your products touch securities, or you register on the mainland.</td></tr></tbody></table></div>
VARA came out of Dubai Law No. 4 of 2022. Any firm running under code 6619.85 has to go through its licensing process. The VASP license comes with strings attached: a minimum capital level, rules on how the company is run, and regular reports you have to file.
Work out which body covers your activity before you set up, not after. If your products touch securities, VARA and the SCA both apply at the same time.
What You Need in Place Before You Start
The compliance bar is high here, and there is no way around it. Break the rules and you risk enforcement action.
Know your customers. You need a written KYC process and customer due diligence checks on everyone who trades with you.
Watch the money. Put in transaction monitoring that runs in real time or close to it. You also need a clear process for reporting anything suspicious.
Protect the systems. Your cybersecurity setup has to meet VARA's technical standards.
Keep money apart. Client funds stay separate from your own operating money. Always.
Report and audit. Expect regular audits and regular filings to the regulator. Name a compliance officer to own all of this.
Bring in a compliance adviser who knows both VARA and the SCA before you launch. On this kind of license, that is not a nice to have.
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How to Set Up with Meydan Free Zone, Step by Step
Meydan Free Zone gives you a simple, low cost route to a licensed exchange business in Dubai. Here is how it runs:
- Step 1, check your activity: Pick activity 6619.85 and go through the permitted work with the Meydan Free Zone team. Check whether your business model needs extra activities added to the license.
- Step 2, get your papers ready: Send in passport copies, a business plan, an outline of your compliance setup, and shareholder declarations. VARA will want a much fuller submission later on.
- Step 3, get your trade license: Meydan Free Zone issues your license and your company legally exists in Dubai. Everything else is built on top of this.
- Step 4, apply to VARA: File your VASP application. Include your anti-money laundering policies, your technology setup, and your governance documents. VARA approves in stages, so build the time into your plan.
- Step 5, open your bank account: Several UAE banks and digital banking providers now take on licensed crypto firms. Having VARA approval granted, or clearly underway, improves your odds a lot.
- Step 6, set up day to day: Meydan Free Zone offers flexi-desk and physical office options. Visas are tied to your license package, so work out your headcount early.
A few services worth knowing about as you go: mResidency handles visas for you, your team and your family. mAccounting keeps your books clean, which helps at both bank and VARA stage. mCore, mAssist and mPlus cover the wider support once you are up and running.
How an Exchange Makes Money
There are four common income streams, and most platforms use more than one:
- Trading fees: a charge on each trade that goes through your platform.
- The spread: the gap between your buy price and your sell price.
- Conversion margins: a margin on swapping one currency or asset for another.
- Premium accounts: tiered plans with better rates, higher limits or extra tools.
Big institutional clients usually negotiate fees based on how much they trade. Retail platforms make their money on spread and transaction fees, at volume.
Who Your Customers Are
Retail traders. Everyday users buying and selling on your platform.
Institutions. Funds, family offices and trading desks that want regulated access to digital assets.
Remittance flows. Dubai sits between Europe, South Asia and Sub-Saharan Africa. All three regions have heavy crypto use and want regulated exchange access.
Web3 firms. Businesses that need a way to move between traditional currency and crypto.
The Tax Picture
The UAE charges no capital gains tax and no personal income tax. That is a real structural advantage over most other financial centres.
For qualifying crypto transactions, the Federal Tax Authority sets out how VAT is treated, which helps when you are pricing your service. Get advice on your own setup, because the treatment depends on what you sell and to whom.
If you are still weighing up the region, Invest in Dubai publishes sector data on financial services and the digital economy that backs up the longer term case.
Conclusion
Dubai gives you three things at once: clear rules, low tax, and real demand. VARA asks a lot of you, and that is the point. Meeting its standards is what earns you bank accounts, institutional clients and cross-border partners.
Meydan Free Zone is a practical way in. Simple setup, competitive license pricing, and a team that has walked fintech and crypto firms through this before.
Talk to the Meydan Free Zone team to check your activity scope, go through your compliance duties, and start your license application.
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