Table of Contents
Frequently Asked Questions
Can I offer custody alongside exchange or brokerage?
No. Activity 6619.84 cannot be combined with any other activity. Offering both custody and another virtual asset service requires two separate entities, each with its own VARA approval, which is a deliberate structural separation rather than a procedural hurdle.
Does providing wallet software count as custody?
It depends on control. If the client alone holds the keys and you only supply software, that is generally not custody. If you control or safeguard the keys on the client's behalf in any way, the activity falls under 6619.84 and needs the license.
Can a custodian lend out client assets?
No. Lending and borrowing is activity 6619.86, and custody cannot be combined with it. Client assets held under a custody license are safeguarded, not deployed, and any lending programme requires a separate licensed entity.
What are the core obligations of a licensed custodian?
Segregation of client assets from the firm's own, secure key generation and storage, provable records of holdings, controlled transaction authorisation, and tested recovery arrangements. VARA's rulebooks set the detailed requirements for each of these areas.
Is custody the same as the trustee and fiduciary code?
No. Trustee, fiduciary and custody services on a fee or contract basis is activity 6619.04, which covers conventional finance and is designated as a Designated Non-Financial Business or Profession. Activity 6619.84 is the virtual assets code and sits under VARA.
Can a foreign custodian license in Meydan Free Zone?
Yes. Meydan Free Zone permits full foreign ownership without a local partner and completes setup digitally. VARA approval is required in the same way for foreign-owned and UAE-owned applicants, as is the standalone entity structure.
How to Start a Virtual Assets Custody Services Business with Meydan Free Zone
Custody is the business of holding what belongs to someone else and being answerable for it. In virtual assets that means controlling private keys on a client's behalf, keeping them secure, keeping client holdings segregated from the firm's own, and being able to prove at any moment exactly what is held and for whom. Activity 6619.84 is the license for that work in Dubai.
The assets exist. Assets under management across VARA-regulated entities exceeded AED 9.6 billion in 2025[1], against transaction volumes of almost AED 2.5 trillion[2], and more than three million investors and traders are serviced from the emirate[1]. Every one of those holdings sits somewhere, and institutional capital will not sit anywhere unregulated.
Custody is treated as the most sensitive activity in the virtual assets group, and the rules show it. VARA was established under Dubai Law No. 4 of 2022 as the world's first dedicated virtual assets regulator[3], and it has drawn custody off on its own: activity 6619.84 cannot be combined with any other activity. A custodian custodies, and does nothing else.
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Billions in Regulated Assets Requiring Safekeeping
A Dubai-licensed custodian operates in a market where assets under management across regulated entities exceeded AED 9.6 billion in 2025, where almost AED 2.5 trillion in transactions passed through regulated firms, and where thirty-nine of the fifty licensed providers were classified as fully operational at the end of that year.
Sources: Virtual Assets Regulatory Authority (2025), Emirates News Agency (WAM), Dubai Government Media Office
Who Is This Activity For?
6619.84 - Virtual Assets Custody Services
This activity sits within the broader class of other activities auxiliary to financial service activities, which covers firms that support financial markets without taking positions in them. Activity 6619.84 is the safekeeping member of the virtual asset group inside it.
Under code 6619.84 you are licensed to hold and administer virtual assets on behalf of clients, which in practice means controlling or safeguarding the private keys that give access to those assets. The defining obligation is that the assets are not yours. They must be segregated from the firm's own holdings, they must be recoverable, and their existence must be demonstrable to the client and to the regulator.
Beyond this activity, Meydan Free Zone also supports related licences such as Virtual Assets Exchange Services, Virtual AssetsBroker-Dealer Services, and Virtual Assets Transfer and Settlement Services.
A Virtual Assets Custody Services license typically covers:
- Safekeeping of virtual assets on behalf of clients
- Control, generation and safeguarding of client private keys
- Segregation of client holdings from the firm's own assets
- Cold, warm and hot storage architecture and the controls governing movement between them
- Transaction signing and authorisation on client instruction
- Client reporting, reconciliation and proof of holdings
- Business continuity, key recovery and disaster recovery arrangements
- Asset servicing such as handling forks, airdrops and staking rewards where permitted
Service Scope
Institutional Custody
Holding assets for funds, exchanges, corporate treasuries and other regulated firms. These clients arrive with auditors, insurers and internal risk committees, and they buy the operational controls as much as the storage. Contracts are long and the barrier to entry is genuine security engineering rather than marketing.
Key Management and Wallet Infrastructure
Providing the cryptographic machinery of custody: multi-party computation, hardware security modules, threshold signing and multi-signature governance. Where the firm controls or safeguards client keys, the activity is custody regardless of how the technology is packaged or marketed.
Custody with Asset Servicing
Safekeeping combined with the administrative work around it: reconciliation, statements, corporate action handling, and the reporting an auditor will ask for. This model competes on record quality rather than storage alone, and it is where traditional fund administration expertise transfers most directly.
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WHAT THIS ACTIVITY EXCLUDES
It is important to note what activity 6619.84 does not cover, and the boundaries here are firmer than anywhere else in the group because custody cannot be combined with anything. Executing or transmitting client orders is 6619.83, Virtual Assets Broker-Dealer Services. Operating a trading venue is 6619.85, Virtual Assets Exchange Services. Advising clients on holdings is 6619.82. Lending out client assets, or running any lending or borrowing product, is 6619.86 and is emphatically not part of a custody license. Managing assets with discretion is 6619.87. Moving assets and settling transactions for third parties is 6619.88. Trading on the firm's own account is 6619.81. Trustee, fiduciary and custody services in conventional finance sit under 6619.04, which is a separate code with its own Designated Non-Financial Business or Profession status.
In short: if you hold the keys and answer for the assets, you are in. If you trade them, lend them, match them or advise on them, you are not, and you cannot do those things from the same entity.
Licensing & Compliance
Third-Party Approval:
You need approval from the Virtual Assets Regulatory Authority (VARA) before your business license is issued. This activity cannot be combined with any other activity.
Anti-Money Laundering Compliance:
This business activity is exempt from AML compliance requirement.
References
[1] Arabian Business, Dubai VARA reports $681bn in virtual asset volumes, reporting VARA figures for 2025, November 2025. arabianbusiness.com
[2] AGBI, Tokenisation fuels Dubai's virtual asset growth, says regulator, citing Dubai Government Media Office, July 2026. agbi.com
[3] The Official Portal of the UAE Government, Regulation of digital properties, on Dubai Law No. 4 of 2022 and the establishment of VARA. u.ae
[4] Emirates News Agency (WAM), VARA issues 50th VASP licence as Dubai's regulated virtual assets market continues to grow, 2 July 2026. bignewsnetwork.com
[5] Virtual Assets Regulatory Authority, Licence Applications, on the two-stage licensing process and submission through a Dubai free zone authority. vara.ae
