Dubai’s Virtual Assets Regulatory Authority (VARA) has issued guidance that clarifies how virtual assets should be structured, disclosed and distributed under its existing Virtual Asset Issuance Rulebook. The guidance interprets existing rules rather than creating new law and defines three distinct issuance pathways, assigning specific responsibilities to issuers, distributors and other involved parties for each route.
The three pathways are: Category 1, which covers fiat‑referenced and asset‑referenced virtual assets; Category 2, which requires distribution through a VARA‑licensed intermediary; and exempt virtual assets with limited functionality that fall outside the full issuance regime. Rather than treating all tokens the same, the framework separates higher‑risk, widely referenced instruments from offerings that must pass through licensed distributors and from minimal‑function tokens that are exempt.
Under the new guidance, licensed distributors in Category 2 offerings carry explicit duties for pre‑issuance due diligence and ongoing validation of compliance. Issuers must meet disclosure standards and structural expectations set out for each category, while other participants have defined roles and obligations depending on the chosen issuance path.
VARA presents the framework as a purpose‑built issuance regime tailored to virtual assets, positioning it as an alternative to applying generic securities or payments law approaches to token launches, including stablecoins and real‑world‑asset (RWA) structures. The move is part of Dubai’s wider effort to build a bespoke crypto rulebook; it follows VARA’s recent expansion of its exchange rulebook to cover exchange‑traded crypto derivatives.
Ruben Bombardi, VARA’s general counsel, said the tailored regime improves regulatory clarity because many virtual assets do not fit neatly into existing legal categories and that clearer disclosure helps investors understand risks. VARA also highlighted specific expectations for asset‑referenced tokens — including reserve asset arrangements, redemption rights and legal structuring — and emphasized a disclosure‑led approach centered on clear whitepapers and separate risk disclosure statements. VARA expects the guidance to be of interest to foreign regulators and standard setters while immediately giving market participants in Dubai greater practical clarity.