Dubai Law No. (4) of 2022 Regulating Virtual Assets

The statute applies to virtual asset services provided across the Emirate of Dubai, including special development zones and free zones, but it expressly excludes the DIFC. That boundary matters because the DIFC operates under its own financial services regulator and rulebook. The Dubai law should therefore be read as a Dubai-level framework rather than a federal UAE virtual asset statute.

The law also sits alongside later federal and VARA materials. Cabinet Decision No. 112/2022 delegated certain federal virtual asset competencies to VARA for the Emirate of Dubai and its free zones. VARA subsequently issued its Virtual Assets and Related Activities Regulations 2023 and related rulebooks, which implement the licensing, supervision, market conduct, AML/CFT, marketing, and enforcement architecture built on the 2022 law.

The law defines “Virtual Asset” broadly as a digital representation of value that may be digitally traded, transferred, used as an exchange or payment tool, or used for investment purposes. It also covers virtual tokens and any other digital representation of value determined by VARA. The text separately defines virtual asset platforms, distributed ledger technology, virtual asset service providers, permits, wallets, and beneficiaries.

Law No. (4) of 2022 establishes VARA as a public corporation affiliated to the Dubai World Trade Centre Authority. VARA’s objectives include developing regulations for investor and dealer protection, curbing illegal practices in coordination with other entities, and creating rules and standards for virtual asset platforms, VASPs, and related matters.

The law states that no person may conduct a regulated virtual asset activity in the Emirate without a VARA permit. A person seeking to conduct an activity must establish the business in Dubai in an approved legal form and obtain VARA approvals before the relevant commercial licensing process. Activities requiring permits include virtual asset platform operation and management, exchanges between virtual assets and fiat currencies, exchanges between virtual assets, virtual asset transfers, safekeeping or management services, wallet-related services, and services related to offering and trading virtual tokens.

VARA’s statutory functions include regulating virtual asset issuance, offering, and disclosure processes; issuing permits to VASPs; classifying virtual assets and tokens; setting standards for trading; overseeing platforms, wallets, and distributed ledger technology; monitoring transactions; and coordinating on suspicious-transaction procedures under UAE AML/CFT legislation. VARA may also coordinate with the Central Bank of the UAE on matters affecting financial-system protection and stability.

The law gives VARA administrative and enforcement tools. It may suspend permit issuance, restrict or suspend internal VASP rules, suspend a VASP activity, or suspend or cease dealing in a virtual asset in exceptional circumstances. The law also contemplates fines, permit suspension for up to six months, permit revocation, inspection powers for nominated VARA employees, and a grievance process for affected parties.

Article 26 provides that implementing resolutions issued by the Board of Directors or Director General and published on VARA’s website have the binding force of legislation published in the Official Gazette. For that reason, the current VARA rulebook and related regulations are essential companion materials for understanding how the 2022 statute operates in practice.

This profile summarizes the law for reference and editorial research. It is not legal, tax, investment, or compliance advice. Editors should treat the Arabic official text as controlling, because the English translation of the law states that the Arabic text prevails in case of conflict.