Table of Contents
Frequently Asked Questions
Can my exchange hold client assets?
Not under this license. Custody is activity 6619.84 and cannot be combined with exchange services, so a venue must appoint a separately licensed custodian. This separation of venue and safekeeping is a deliberate structural requirement rather than a formality.
Can the exchange trade on its own platform?
No. Trading on own account is activity 6619.81, Virtual Assets Proprietary Trading, and it cannot be combined with any other activity. A venue operator taking positions on its own market would require a wholly separate licensed entity.
Does an over-the-counter desk need the exchange license?
If you are bringing counterparties together and matching their interest, yes, that is venue activity under 6619.85. If you are executing client orders into someone else's market instead, that is broker-dealer activity under 6619.83.
What is required for listing assets on a venue?
VARA expects published listing standards, documented review of each asset before admission, ongoing monitoring and a defined delisting process. Tokenised instruments carry additional diligence because the operator must verify what the token actually represents.
Which activities can an exchange be combined with?
Advisory, broker-dealer, lending and borrowing, management and investment, and transfer and settlement may all be combined with exchange services. Only proprietary trading and custody are excluded, and VARA assesses each combination on its own merits.
Can a foreign exchange operator set up in Meydan Free Zone?
Yes. Meydan Free Zone permits full foreign ownership without a local partner and completes setup digitally. VARA approval is required before the license is issued, and the requirement is identical for foreign-owned and UAE-owned applicants.
How to Start a Virtual Assets Exchange Services Business with Meydan Free Zone
An exchange does not trade. It operates the place where others do. Buyers and sellers arrive with orders, the venue matches them under published rules, and the operator earns fees on the volume that crosses. Activity 6619.85 is the license for running that venue in virtual assets from Dubai.
The market has already chosen the jurisdiction. VARA was processing more than two hundred and fifty license applications and had welcomed three hundred global first-time entrants as of its 2025 reporting[1], against transaction volumes of almost AED 2.5 trillion across regulated entities in that year[2]. By July 2026 fifty firms held full virtual asset service provider licenses[3].
Exchange is the most operationally demanding activity in the group. VARA was created under Dubai Law No. 4 of 2022 as the world's first dedicated virtual assets regulator[4], and a venue operator carries obligations that no other participant does: fair and orderly markets, published rules, surveillance, listing standards and resilience. The license reflects the responsibility.
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A Licensing Pipeline Drawing Global Market Entrants
A Dubai-licensed exchange operates in a market that welcomed three hundred global first-time entrants and had more than two hundred and fifty license applications in processing, against regulated transaction volumes of almost AED 2.5 trillion in 2025 and a serviced base of more than three million investors and traders.
Sources: Virtual Assets Regulatory Authority (2025), Dubai Government Media Office, Emirates News Agency (WAM)
Who Is This Activity For?
6619.85 - Virtual Assets Exchange Services
This activity sits within the broader class of other activities auxiliary to financial service activities, which covers firms that service financial markets without taking principal positions in them. Activity 6619.85 is the venue-operating member of the virtual asset group inside it.
Under code 6619.85 you are licensed to operate a virtual asset trading platform: to bring buyers and sellers together, to match their orders under published rules, and to run the systems and surveillance that keep the venue orderly. The boundary is neutrality. You provide the market. You do not advise participants, hold their assets as custodian, or take the other side of their trades.
Beyond this activity, Meydan Free Zone also supports related licences such as Virtual Assets Broker-Dealer Services, Virtual Assets Custody Services, and Virtual Assets Transfer and Settlement Services.
A Virtual Assets Exchange Services license typically covers:
- Operation of a virtual asset trading platform or order book
- Matching of buy and sell orders between platform participants
- Publication and enforcement of trading rules, fee schedules and market hours
- Listing, review and delisting of virtual assets traded on the venue
- Market surveillance, abuse detection and orderly-market controls
- Participant onboarding, access management and connectivity provision
- Trade reporting, transaction records and post-trade data services
- System resilience, capacity management and business continuity arrangements
Service Scope
Spot Order Book Platforms
The familiar shape: a central limit order book where participants post bids and offers and the venue matches them by price and time priority. The operator competes on liquidity, uptime and fee structure, and the regulatory weight sits in surveillance and listing governance.
Over-the-Counter and Block Matching
Bringing counterparties together for larger trades away from a public book, whether by request for quote, negotiated matching or scheduled auction. The absence of a visible order book does not change the classification: operating the meeting point is exchange activity.
Tokenised Asset Marketplaces
Secondary trading venues for tokenised instruments, including real-world assets, fractionalised property and tokenised commodities. Alongside matching, the operator carries listing responsibility for verifying what the token actually represents, which is a heavier diligence burden than listing a liquid crypto-commodity.
WHAT THIS ACTIVITY EXCLUDES
It is important to note what activity 6619.85 does not cover. Acting for clients in the market, rather than operating the market, is 6619.83, Virtual Assets Broker-Dealer Services. Holding participant assets is 6619.84, Virtual Assets Custody Services, which cannot be combined with exchange activity, so a venue must appoint a separately licensed custodian. Advising participants on what to trade is 6619.82. Lending and borrowing products are 6619.86, and discretionary portfolio management is 6619.87. Settlement and transfer services for third parties fall under 6619.88. Trading on the venue's own account is 6619.81, Virtual Assets Proprietary Trading, which cannot be combined with anything. Operating a conventional securities or commodities exchange sits under 6611 and falls to the Capital Market Authority.
In short: if you are running the market, you are in. If you are trading on it, advising on it, or holding what changes hands, you are not.
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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 Virtual Assets Proprietary Trading in Crypto-commodities or Virtual Assets Custody Services.
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] Emirates News Agency (WAM), VARA issues 50th VASP licence as Dubai's regulated virtual assets market continues to grow, 2 July 2026. bignewsnetwork.com
[4] 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
[5] Virtual Assets Regulatory Authority, Licence Applications, on the two-stage licensing process and submission through a Dubai free zone authority. vara.ae
