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.