Stablecoins and ARVAs in Dubai: Issuance, Licensing, and the New 2025 Framework

Dubai became the first jurisdiction globally to codify virtual asset issuance in regulatory text. The 2025 Virtual Asset Issuance Rulebook, published by VARA on 19 May 2025 with compliance required by 19 June 2025, established a complete framework for the issuance of stablecoins and asset-referenced tokens in or from Dubai. The framework opens the door to regulated tokenisation of real-world assets at a scale not previously available in the region.
For founders considering a stablecoin launch, a real estate tokenisation, or any other form of asset-referenced token issuance from the UAE, the new framework is the primary reference point. This guide explains how it works.

The three categories of issuance

The Issuance Rulebook establishes three categories of virtual asset issuance, each with different regulatory requirements.
Category 1 covers Fiat-Referenced Virtual Assets (FRVAs) and a new category of Asset-Referenced Virtual Assets (ARVAs). Category 1 issuances are, without exception, deemed to be carried out in the course of a business, and licensed VASPs must obtain approval from VARA before issuing an FRVA or an ARVA. Category 1 is the most regulated category and is where stablecoins and real-world asset tokens sit.
Category 2 covers issuances that are neither Category 1 nor exempt. No VARA licence or prior approval is required for the issuer itself, but placement or distribution must be carried out through or by a VARA Licensed Distributor. The distributor is responsible for ensuring that the issuer complies with the Issuance Rulebook. This category captures many utility tokens and similar issuances.
Exempt Virtual Assets cover non-transferable virtual assets and redeemable closed-loop virtual assets. No issuance-stage VARA requirements apply. The exempt category captures internal corporate tokens, certain loyalty programs, and similar limited-purpose virtual assets.

What ARVAs actually cover

ARVAs are defined to cover any virtual asset (other than an FRVA) which represents or purports to represent, directly or indirectly, current or future ownership of any Real-World Asset (RWA). The definition is intentionally broad and captures a wide universe of tokenisation use cases.
Real-World Assets include any interest in any financial instrument, any physical or tangible asset, and any intangible asset. The scope captures commodities (gold, silver, oil tokens), real estate (tokenised property, fractional ownership), traditional financial instruments (tokenised securities, bonds), and other tangible or intangible assets that have value separate from the token itself.
The breadth of the definition means that many token projects that previously operated in regulatory grey zones now fall squarely within Category 1 regulation. Founders evaluating any token model with claims to real-world asset backing should assume Category 1 applies until specialist advice confirms otherwise.

Category 1 requirements

Issuance of an FRVA or an ARVA requires a VARA Category 1 issuance licence. The licensing process includes the standard fit-and-proper, business plan, AML, technology, and governance review applicable to all VARA licences, plus specific requirements for the issuance activity.
Token-specific requirements include a detailed whitepaper meeting specified content standards, a risk disclosure statement enumerating specific hazards associated with the virtual asset (including liquidity risks, technological vulnerabilities, and regulatory uncertainties), minimum capital of AED 1.5 million or 2% of reserves, whichever is higher, monthly independent audits of reserve assets, ongoing supervisory reporting, and reserve asset governance that separates reserve custody from operational treasury functions.
VARA reviews the whitepaper and risk disclosure statement during the licensing process and maintains ongoing oversight of disclosure accuracy. Compliance with the Issuance Rulebook does not constitute regulatory endorsement of the virtual asset itself; the disclosure-led approach shifts compliance focus to information transparency and accuracy rather than substantive product approval.

Reserve asset requirements

FRVAs and ARVAs must maintain sufficient reserve assets to honour redemption requests. The reserve asset provisions are central to the credibility of the framework and have been designed with reference to the failure patterns observed in stablecoin failures globally.
Reserves must be held in identifiable, high-quality assets, with governance structures that separate reserve custody from operational treasury functions. The issuer cannot use reserve assets for operational purposes. Audits must be conducted by independent auditors at the monthly frequency, with reports submitted to VARA and made available in summary form to token holders.
Redemption mechanics, including timeframes and pricing methodologies, must be documented and operated as specified. Failure to honour redemption requests is among the most serious supervisory breaches a Category 1 issuer can commit.

Where ARVAs can be distributed

Dubai-authorised exchanges and broker-dealers are expressly permitted to distribute and list Asset-Referenced Virtual Assets. This is a significant practical development: tokenised real estate, commodities, or investment funds can be issued and traded onshore in Dubai through licensed market infrastructure.
The distribution rules apply to both the issuer and the distributor. Where an exchange or broker-dealer lists an ARVA, it takes on responsibilities for verifying that the underlying issuance complies with the Issuance Rulebook. This creates a chain of compliance that supports the overall integrity of the market.

Real-world asset tokenisation in practice

Real-world asset tokenisation has moved from theory to practice in Dubai. The Dubai Land Department launched a real estate tokenisation pilot, conducted exclusively in dirhams in its initial phase, with the broader vision of supporting fractional ownership, transparency, and global participation in Dubai real estate.
Other tokenisation use cases gaining traction in the UAE include precious metals tokenisation, art and collectibles tokenisation, private credit tokenisation, and trade finance tokenisation. Each use case has its own regulatory texture under the Issuance Rulebook, but all benefit from the underlying legal certainty that the 2025 framework provides.

Frequently Ask Question

Can I issue a stablecoin from Dubai?

Yes, under VARA’s 2025 Virtual Asset Issuance Rulebook. Fiat-Referenced Virtual Assets (FRVAs) are Category 1 issuances requiring a VARA Category 1 issuance licence, a detailed whitepaper, a risk disclosure statement, minimum capital of AED 1.5 million or 2% of reserves whichever is higher, monthly independent audits, and ongoing supervisory reporting. The framework is detailed but workable for well-prepared issuers.

What is an ARVA under the VARA framework?

An Asset-Referenced Virtual Asset is any virtual asset, other than a Fiat-Referenced Virtual Asset, which represents or purports to represent current or future ownership of any Real-World Asset. The definition covers tokenised commodities, real estate, financial instruments, and other tangible or intangible assets. ARVAs are Category 1 issuances subject to the same licensing requirements as FRVAs.

What is the minimum capital for a stablecoin or ARVA issuer?

AED 1.5 million or 2% of reserves, whichever is higher. The capital is in addition to the reserve assets backing the issued tokens. The total financial commitment for a stablecoin or ARVA launch substantially exceeds the headline capital requirement, since reserve assets, operational capital, and licensing costs all add to the total.

Can foreign issuers list their stablecoin or ARVA on a Dubai exchange?

Dubai-authorised exchanges can list FRVAs and ARVAs, but only where the underlying issuance complies with the VARA Issuance Rulebook. Foreign-issued tokens face a specific compliance assessment before they can be distributed through Dubai-authorised infrastructure. The distribution rules create a chain of compliance that captures cross-border issuances reaching the UAE market.

What real-world assets can be tokenised under the Dubai framework?

The definition of Real-World Asset is intentionally broad: any interest in any financial instrument, any physical or tangible asset, and any intangible asset. This covers commodities (gold, silver, oil), real estate (including fractional ownership models), traditional financial instruments, art and collectibles, private credit, trade finance, and many other use cases. Each specific tokenisation model has its own regulatory texture within the framework.

How often must stablecoin reserves be audited?

Monthly. The Issuance Rulebook requires independent audits of reserve assets at the monthly frequency, with reports submitted to VARA. Audits must be conducted by qualified independent auditors. The reserve asset governance must separate reserve custody from operational treasury functions, which means issuers cannot use reserve assets for operational purposes.

Speak to Lexorium Legal Consultancy

Lexorium Legal Consultancy advises crypto founders, financial institutions, and tokenisation platforms on stablecoin and ARVA issuance in Dubai under the 2025 VARA Issuance Rulebook. We support the licensing application, the whitepaper and risk disclosure preparation, the reserve asset structuring, and the ongoing compliance framework.
If you are evaluating a stablecoin or asset-referenced token launch from Dubai, get in touch with Lexorium Legal Consultancy at the conceptual stage. The structuring choices made early in the project largely determine the operational efficiency of the eventual licence.