VARA Releases Activity Rulebooks v2.0

The Riffle

Dubai is once again proving itself a leader in digital asset regulation with the launch of VARA’s Rulebooks v2.0, representing a crucial advance in establishing a transparent, innovation-friendly, and globally consistent framework for Virtual Assets (VAs) and Real-World Asset (RWA) tokenization.

Here are the highlights from Rulebooks v2.0:

Technology Oversight

• Firms are now required to share cyber threat intelligence, conduct penetration tests, and adhere to a fresh tech risk governance model.

• The regulatory reach extends to smart contracts, private key management, and third-party tech services.

Custody Regulations

• Virtual asset custodians face stricter standards, including asset segregation, stronger cybersecurity protocols, and mandatory off-chain recordkeeping.

• Omnibus wallet systems are now formally acknowledged, subject to robust control and reconciliation requirements.

Regulatory Sponsorship

• Licensed VASPs can back innovative startups under regulated circumstances.

• Sponsored firms must function within their sponsor’s compliance structure.

RWA Tokenization

• Comprehensive requirements exist for audits, disclosures, and redemption processes related to tokenized real-world assets like property.

• The rules aim to protect asset authenticity, investor visibility, and provide structured pathways for exits.

Marketing & Promotions

• Only approved entities may promote virtual assets from or within Dubai, reflecting a considerable tightening of promotional guidelines.

• There’s increased responsibility regarding how investment offerings and products are communicated to the public.

Compliance & Reporting

• There’s heightened focus on real-time data submission, annual compliance attestations, and greater accountability at the board level.

• Businesses must now undertake regular risk reviews addressing AI risks, sanctions, and international data transfers.

Token Classifications & Issuance

• A new class for Asset-Referenced Virtual Assets (ARVAs) has been introduced.

• Category 2 VA issuances no longer demand pre-approval, shifting full compliance responsibility to licensed distributors.

• Token structures, ownership rights, and whitepaper disclosures have clearer regulatory guidance.

Margin Trading & Qualified Investors

• Investor classification standards have been refined to consider experience, liquidity, and risk awareness.

• New measures limit retail client leverage while elevating the requirements for qualified investor access.

Conclusion

VARA’s Rulebooks v2.0 mark a decisive step in shaping a secure, transparent, and innovation-ready environment for virtual assets in Dubai. With refined frameworks across custody, compliance, marketing, tokenization, and investor protection, the update reinforces Dubai’s position as a global leader in digital asset regulation—ensuring responsible growth while enabling cutting-edge innovation.