The Virtual Assets Regulatory Authority (VARA) has introduced a comprehensive update regarding the amendment process for Virtual Asset Service Provider (VASP) licences in the Dubai Virtual Assets & Related Activities Regulation (DVARA) regime. This update is critical for businesses operating in the virtual assets sector under the UAE framework. Staying informed helps avoid compliance issues, delays, or disruption in operations.
What Is the VASP Licence Amendment and Who It Affects
A VASP licence amendment refers to the formal process by which a licensed virtual assets company submits changes to its operational, ownership or regulatory-related details to VARA for approval.
Purpose:
Ensures VARA’s register remains current and accurate in line with evolving business structures and regulatory standards.
Helps maintain full compliance by licensed entities in the virtual assets ecosystem.
Who Needs It:
Entities holding a VASP licence under the DVARA regime in Dubai.
Companies that have obtained regulatory approval from VARA for any virtual asset activities and need to amend a condition or detail of their licence.
Businesses intending to expand, restructure or diversify their virtual services—such as adding Decentralised Finance (DeFi) offerings, token issuance, custody services—or change ownership, shareholding, or other critical corporate data.
When and Why an Amendment Is Required
An amendment becomes necessary when there is any material change in your business that impacts your initial VARA-licence submission or ongoing obligations, including:
A change in ultimate beneficial ownership (UBO) or corporate structure.
Expansion or modification of virtual asset services (for example, adding token services, custody or exchange operations).
Change in jurisdiction, share capital, or key management principals.
Relocation of registered office or principal place of business to another free zone or jurisdiction within Dubai’s virtual assets framework.
Amendment to risk-management systems, AML/CTF controls or service segments previously approved by VARA.
Failing to submit timely amendments can result in non-compliance, suspension of licence, enforcement action or additional regulatory scrutin
Amendment Process
VARA has laid out a streamlined process via its online portal. Below are the key steps:
Step 1: Log in to the VARA Licensing Portal
Access your company’s account on the VARA authorised platform using your credentials. Ensure your initial licence data is up to date.
Step 2: Select “Licence Amendment Request”
Within your dashboard, choose the option to submit an amendment request for your VASP licence.
Step 3: Prepare and Upload Supporting Documents
Gather the relevant updated documents, such as:
A revised corporate structure chart and UBO affidavit.
Updated business plan or service-scope amendment describing the new virtual asset activities.
Revised share-capital documents or board resolution (if applicable).
AML/CTF policy update, if your amendment relates to compliance systems.
Updated trade licence or free-zone registration slip (if applicable).
Where relevant, KYC/AML oversight documentation showing change in key management or operators.
Step 4: Submit the Original Licence Documentation (if required)
In certain cases, VARA may ask you to submit the original licence or related documentation for verification. Check the portal for any instructions.
Step 5: Review and Approval
VARA will review your submission. The review timing may vary depending on the complexity and completeness of your documentation. It is advisable to engage a regulatory-compliance advisor experienced in virtual assets to ensure your submission meets all standards.
Key Points to Remember
Validity & Coverage: Ensure the amendment covers all aspects of your licence—services, geography, share structure, management.
Timely Submission: Submit the amendment before you begin operating changed services or after structural change occurs. Avoid running altered operations without the amended licence.
Track Status: Use the portal to monitor your amendment’s progress and respond promptly to any requests from VARA.
Compliance Scope: Licensed VASPs must maintain compliance not only with VARA’s rules but with AML/CTF obligations, risk-management frameworks and governance expectations.
Engage Experts: The virtual assets regulatory environment is complex and evolving—professional guidance helps in avoiding costly errors.
Conclusion
The latest VARA update on the amendment process for VASP licences underlines the importance of maintaining accurate, current, and compliant operational records. Whether it’s a shift in ownership, addition of new virtual asset services, or change in management or structure, submitting a proper amendment is key to uninterrupted licence validity and business continuity in Dubai’s virtual assets market.
For tailored support with your VASP licence amendment, regulatory compliance or virtual assets advisory, contact The Alchamii’s expert team today.
