Dubai’s VARA Rulebooks 2.0:
What Businesses Need to Know for Dubai Crypto Compliance

Category	Rulebook 1.0	Rulebook 2.0
Token Classification	Broad, with limited specificity on RWAs	Clear taxonomy: FRVAs, ARVAs, Category 2, Exempt VAs
Pre-Approval of Tokens	Required for all Category 2 tokens	Removed – now self-assessed unless it qualifies as Category 1
RWA Tokens	No bespoke guidance	Defined as ARVAs, requiring a VARA license
Margin Trading	Lighter controls	Enhanced requirements for leverage, liquidation & risk management for VARA Margin trading rules
Collateral Wallets	No formal structure	Clearly defined standards and disclosure expectations
Supervision	Activity-based, developing	Strengthened – more robust supervisory & audit mechanisms
Compliance Timeline	N/A	All VASPs must comply by 19.06.2025

The operational impact of Rulebooks 2.0 is both immediate and substantial, particularly for firms already active in the sector. Here are some of the ways that both established and new market participants are expected to align with the updated requirements for Dubai crypto compliance:

• Existing VASPs are required to complete a comprehensive internal compliance review against VARA Rulebooks 2.0 before 19.06.2025.
• Firms engaged in margin trading, lending, or RWA tokenisation must update their internal policies, risk controls, and customer disclosures to meet the new standards for Dubai crypto compliance.
• All businesses must now ensure their virtual asset issuances are clearly categorised under the new token framework.
• New applicants will benefit from a more transparent licensing pathway but must meet higher expectations in terms of documentation, capital planning, and compliance architecture.
• Business models involving sensitive activities, such as custody, ARVA issuance, margin exposure, or lending services, will be subject to heightened scrutiny.
• Regulatory enforcement is expected to become stricter and more proactive, with non-compliance posing serious risks to reputation, operations, and long-term viability.

Asset protection lies at the heart of any financial system. In a decentralised architecture, that protection can’t rely on institutions, it must be built into the design of the system itself. Embedding trust into the infrastructure—from the code layer to the policy framework—is non-negotiable, especially when the assets of everyday users are at stake. This is fundamental to Dubai crypto regulation.

Centralised systems benefit from years of tested processes and institutional safeguards. Although Web3 infrastructures are evolving, there is still a long way to go. For users to migrate confidently from those systems into decentralised environments, they need to trust that their funds are secure, their data is protected, and there is recourse in the event of wrongdoing. None of this is possible without clear regulation and effective enforcement.

Companies that embed compliance into their business model—not as an add-on, but as a deliberately engineered capability—will be better positioned to earn the trust of users, partners, and institutional investors, and it is no different for companies falling under Dubai crypto regulation. Beyond speed and speculation, credibility for these organisations will become the true differentiator for sustainable success. In fact, strong governance and regulatory alignment are increasingly becoming competitive advantages, especially as traditional financial institutions and sovereign regulators focus their attention on the crypto ecosystem.

Dubai’s approach is already attracting attention. In recent years, the emirate has welcomed several leading firms in the virtual asset sector, many of which have shifted their regional headquarters to Dubai to benefit from its proactive and transparent regulatory environment. For the ecosystem to move from credibility to scale, however, adoption must accelerate. That adoption depends on trust, and it is compliance that builds this trust. The Dubai crypto rulebook update is all set to facilitate that.

At AKW Consultants, we provide comprehensive support to virtual assets businesses navigating the operational and regulatory demands introduced under VARA Rulebooks 2.0. Our services are designed to help firms align precisely with the updated classification, licensing, and risk management requirements set out in the new VARA regulatory framework. For established firms, we conduct rigorous third-party audits of their entire compliance architecture to assess alignment with Rulebooks 2.0 and identify any gaps or areas requiring remediation.

We assist VASPs in interpreting their business activities within the context of Rulebooks 2.0’s token taxonomy. For businesses engaged in real-world asset tokenisation, we offer end-to-end support with the ARVA licensing model introduced under Rulebooks 2.0. Our compliance advisory services are tailored to the enhanced expectations outlined in the rulebooks, particularly around margin trading, lending, custody, and collateral wallet operations.

As a regulatory liaison, AKW acts as a trusted interface between clients and VARA. We support businesses through licence amendments, periodic supervisory reviews, and external compliance inspections mandated under Rulebooks 2.0. In addition, we equip in-house compliance and risk teams with targeted training on the updated rulebook requirements, ensuring businesses remain both compliant and resilient over time.