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The Five Frameworks You Need to Understand

THE UAE DIGITAL ASSET REGULATORY FRAMEWORK (2026)

From 1 January 2026, the UAE's digital asset regulatory architecture is structured across five authorities. Here is what each covers and why it matters to your business.

CMA – Capital Markets Authority (Federal)

The former Securities and Commodities Authority (SCA) was replaced by the Capital Markets Authority (CMA) on 1 January 2026 under Federal Decree-Law No. 32 and No. 33 of 2025. This is not a rebrand. It is a structural overhaul of the federal capital markets framework — and it brings virtual assets explicitly within the federal regulatory perimeter for the first time.
Under Decision No. 4/R.M/2026, issued in February 2026, the CMA established a comprehensive federal VASP licensing framework covering eight licensed virtual asset activities. The new framework:

CBUAE – Central Bank of the UAE (Payment Tokens / Stablecoins)

The Central Bank of the UAE regulates stablecoins and payment tokens through the Payment Token Services Regulation (PTSR), issued under Circular No. 2/2024, effective from 31 August 2024. This framework applies across the UAE, including to VARA-licensed entities, but excludes DIFC and ADGM, which have their own frameworks.

The PTSR governs:

Key regulatory requirements under the PTSR:

VARA – Virtual Assets Regulatory Authority (Dubai Mainland & Free Zones excluding DIFC)

VARA is the dedicated regulator for virtual asset activities across the emirate of Dubai (excluding the DIFC). Operating under VARA Rulebook Version 2.0 (published May 2025), VARA licenses VASPs across a range of activities including exchange, brokerage, custody, lending, staking, and investment management of virtual assets.


VARA's two-stage licensing process- MVP Licence (Minimum Viable Product) and FMP Licence (Full Market Product)- governs how businesses enter and scale within Dubai's virtual asset market. VARA compliance requirements include governance documentation, AML/CFT programmes, technology risk policies, and ongoing supervisory obligations including the Travel Rule, which became binding in practice from February 2026.
Important jurisdictional note: The CMA's federal framework operates alongside VARA, not instead of it. A Dubai-based VASP may be subject to both VARA and CMA requirements simultaneously, depending on its activities.
Who this affects: Crypto exchanges, trading platforms, custodians, brokers, virtual asset investment managers, Web3 consumer platforms, and digital asset lenders operating in or from Dubai mainland.

DFSA – Dubai Financial Services Authority (DIFC)

The DFSA regulates digital assets within the DIFC under its Investment Token and Crypto Token frameworks. Investment Tokens — digital assets constituting investments under DIFC law — are regulated financial instruments. Enhanced governance standards came into force from 12 January 2026, and a ban on privacy tokens on DIFC exchanges was announced in January 2026.

The DFSA framework is well-suited to: institutional digital asset businesses, security token issuances, tokenised funds and investment structures, digital asset managers serving professional and institutional clients, and businesses requiring the DIFC courts, legal system and international brand alongside digital asset activity.

FSRA – Financial Services Regulatory Authority (ADGM)

The FSRA within ADGM operates the most comprehensive single-regulator digital asset framework in the UAE, with an updated Financial Regulatory Toolkit (FRT) framework in force from 1 January 2026. The FSRA covers custody, exchange, brokerage, OTC derivatives, lending, staking and institutional digital asset structures under a unified rulebook.

The FSRA framework is well-suited to: institutional custody providers, exchanges with derivatives capabilities, hedge funds with digital asset strategies, and businesses requiring a single, comprehensive regulatory framework for complex activities including structured products and institutional asset management.

WHAT WE DO

Our Digital Asset Legal Services

We advise across all five UAE digital asset regulatory frameworks and deliver the legal work required to implement that advice. Our role does not stop at high-level guidance; we structure, draft and prepare the underlying documentation needed to move matters forward.

WHO WE WORK WITH

Who We Work With

Virtual Asset Service Providers (VASPs)

Exchanges, custodians, brokers and OTC desks navigating VARA, CMA, CBUAE, DFSA or FSRA licensing- or managing multi-regulator obligations simultaneously.

Stablecoin Issuers and Payment Token Businesses

Businesses building AED-backed or foreign payment token products, requiring CBUAE PTSR licensing, reserve documentation and integration with broader VARA or CMA obligations.

Digital Asset Fund Managers

Fund managers running or planning crypto, digital asset or tokenised asset strategies — whether in DIFC, ADGM, or under a VARA and CMA-regulated structure.

RWA Tokenisation Platforms and Issuers

Businesses tokenising real-world assets- real estate, private equity, commodities, trade finance receivables, requiring multi-framework regulatory analysis, legal structuring and offering documentation.

Family Offices, Treasury Vehicles and Principal Investors

Family offices, proprietary investment vehicles and strategic investors seeking exposure to virtual assets, tokenised products or digital asset funds, and requiring advice on structuring, governance, custody, risk allocation and regulatory treatment.

Foundations, DAOs and Ecosystem Structures

Foundations, protocol vehicles, grant entities and DAO-linked structures requiring advice on legal form, governance, token-related rights, treasury arrangements and jurisdictional suitability within the UAE.

Banks, Payment Firms and Financial Institutions

Traditional financial institutions, fintechs and payments businesses assessing digital asset products, stablecoin use cases, tokenised offerings or regulated market entry, and requiring advice that bridges existing financial regulation with emerging virtual asset frameworks.

Web3 and Blockchain Startups

Early-stage and growth-stage businesses building wallets, infrastructure, DeFi-adjacent products, token ecosystems, blockchain-based applications, AI x Web3 products and other emerging technology ventures that require early regulatory analysis, product structuring and commercially workable legal documentation.

Ready to Navigate UAE Digital Asset Regulation?

Whether you're pursuing a VARA licence, structuring a stablecoin, or launching a digital asset fund, we help you move forward with confidence.

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