Dubai’s Virtual Assets Regulatory Authority (VARA) released new guidance on Thursday clarifying how token issuers should structure, disclose, and distribute virtual assets in the emirate, with a sharper focus on stablecoins and real-world asset (RWA) tokens.
The document does not introduce new laws but instead interprets VARA’s existing Virtual Asset Issuance Rulebook. It outlines three distinct issuance pathways and clearly defines the responsibilities of each party involved.
The framework differentiates between Category 1 issuances—such as fiat-referenced and asset-referenced tokens—Category 2 issuances, which must be distributed through a VARA-licensed intermediary, and exempt virtual assets with limited functionality. Rather than applying a one-size-fits-all approach, the rules are tailored to reflect varying levels of risk across different token types.
VARA describes the system as a purpose-built framework designed specifically for virtual assets, in contrast to models that rely on traditional securities or payments laws for token issuance. The guidance also emphasizes the role of licensed distributors in Category 2 issuances, assigning them responsibility for due diligence and ongoing compliance checks.
This move is part of Dubai’s broader effort to develop a specialized regulatory framework for crypto assets, rather than forcing them into existing legal categories. It follows closely on the heels of VARA’s recent expansion of its exchange rulebook to include crypto derivatives.
Although presented as guidance, VARA’s general counsel Ruben Bombardi noted that a dedicated issuance regime offers tangible advantages over conventional securities frameworks. These include greater regulatory clarity—particularly since many virtual assets do not fit neatly into traditional classifications—and improved transparency, helping investors and users make more informed decisions about risks and asset characteristics.

Bombardi said the framework delivers a “more tailored approach to issuance,” offering “a single, dedicated reference point” for how virtual assets can be issued, disclosed, and distributed within Dubai’s licensed regime.
He also pointed to several elements that VARA believes set Dubai apart globally. These include specific provisions for asset-referenced virtual assets, covering requirements for reserve assets, redemption rights, and legal structuring, as well as a disclosure-driven model built around whitepapers and separate risk statements that must be “clear, accurate, and accessible” to users.
Bombardi added that while the framework could attract interest from international regulators and standard-setting bodies, VARA’s primary focus is on delivering practical clarity for market participants operating in Dubai.

