Does VARA regulate the DIFC?

No. The Dubai virtual-asset framework excludes the Dubai International Financial Centre, which has a separate DFSA regime. If your operations touch both the DIFC and other parts of Dubai, ask qualified counsel to confirm which requirements apply to each activity and entity.

What is Threat-Led Penetration Testing (TLPT)?

TLPT is an intelligence-led red-team exercise that simulates realistic threat actors against critical live systems. Under VARA’s Technology and Information Rulebook, VARA may require it where necessary and proportionate, taking account of factors such as the VASP’s exposure and the criticality of its activities. Where required, the rulebook calls for an external tester.

How long does VARA readiness take?

Timing depends on the activities in scope, your existing controls, and the remediation and testing required. A technical gap assessment gives your team a clearer view of the work and sequencing; we avoid promising a licensing timeline because VARA makes the decision.

Can you work alongside our lawyers and compliance consultants?

Yes. QuillAudits focuses on the technical security workstream, including assessment, security testing, remediation, and evidence. Your lawyers and compliance advisors lead legal interpretation, company structuring, financial-crime obligations, and regulatory submissions.

Who issues the VARA license?

VARA alone makes licensing decisions and issues licenses. QuillAudits can support technical readiness and evidence preparation, but cannot guarantee or grant a license.

TVL Protected: $3B+Projects Secured: 1500+Years in Web3 Security: 7+

VARA compliance readiness for Web3 in Dubai

VARA compliance readiness maps your Web3 activities, security controls and technical evidence to applicable requirements for your Dubai licensing workstream.

Dubai licensing starts with a clear security picture.

VARA regulates virtual-asset activities across Dubai’s mainland and free zones, except the DIFC. We help Web3 teams understand the technical evidence their operating model needs, alongside qualified legal and compliance advisors.

Activity-based scope

Start with the activity.

The applicable license categories and rulebooks depend on the virtual-asset activities you plan to carry out. Map the service model before building the evidence around it.

Technical evidence

Show how controls work.

VARA’s Technology and Information Rulebook covers security governance, testing, and audit evidence. Security work should produce clear findings, remediation records, and artifacts that can be reviewed.

Ongoing readiness

Keep the program current.

The regulatory framework can change. Assign owners to controls and evidence, and keep a review cycle so updates can be assessed against your systems and operations.

VARA Compliance Readiness Services

QuillAudits supports the technical security workstream: assessment, testing, remediation, and evidence. Your legal and compliance advisors lead corporate structuring, financial-crime obligations, and legal interpretation.

01 / Readiness

From gap to an evidence-led plan.

Technical readiness before your application moves forward.

Technical activity mappingDocument the services and systems in scope to inform licensing conversations with your legal and compliance advisors.
Security gap assessmentReview controls against the relevant VARA requirements and identify gaps, owners, and evidence needed for remediation.
Security program supportDevelop practical security policies, wallet and key-management controls, and incident-response procedures for your team.
Technical testing and evidenceSmart contract audits, infrastructure and application testing, and support for threat-led testing where required.

Outcome: a prioritized technical remediation plan with findings, owners, and supporting evidence.

02 / Application & Ongoing

Support the file. Maintain the controls.

Technical support through review and ongoing operation.

Application evidence supportOrganize technical documents and explain assessment results in a format your team and advisors can use.
Independent security testingVARA’s Technology and Information Rulebook requires qualified, independent third-party vulnerability assessments and penetration tests at least annually and before new systems, applications, or products. Smart contract audits apply where relevant to the VASP’s business and activities.
Remediation and retestingPrioritize findings, verify fixes, and retain a clear record of what changed and when.
Ongoing control reviewsReview security evidence and regulatory changes with your team so the program stays aligned as operations evolve.

Boundary: VARA makes all licensing decisions. Legal advice and regulatory submissions remain with your qualified counsel and authorized representatives.

What you receive

Practical technical outputs your team, counsel and compliance advisors can use throughout the readiness workstream.

VARA technical control mapping matrix
Technical security gap assessment report
Prioritized remediation plan with owners and recommended timelines
Smart contract, application and infrastructure testing reports, where included in scope
Organized technical evidence pack for your licensing workstream
Retesting results and an ongoing readiness plan

Final deliverables depend on the agreed engagement scope. Legal advice and regulatory submissions remain with your qualified counsel and authorized representatives.

The four compulsory rulebooks, mapped to real controls.

VARA lists four compulsory rulebooks for VASPs, alongside requirements for the activities each VASP is licensed to perform. The precise scope depends on the business and its authorizations.

01 / VARA Rulebook

Company

Covers: Governance, company structure, outsourcing, and wind-down planning.
Technical support: Technical control evidence, security governance, and input on technology outsourcing risks.

02 / VARA Rulebook

Compliance and Risk Management

Covers: Compliance management, AML/CFT obligations, client money, and client virtual assets.
Technical support: Technical risk and control mapping to support the work of your compliance officer and counsel.

03 / VARA Rulebook

Technology and Information

Covers: Technology governance, security controls, personal data, and confidential information.
Technical support: Security assessments, smart contract audits where relevant, penetration testing, and remediation evidence.

04 / VARA Rulebook

Market Conduct

Covers: Marketing, client agreements, complaints handling, investor classifications, and public disclosures.
Technical support: Technical review of security statements and product evidence for your legal and compliance review.

See the current requirements in the official VARA compulsory rulebooks.

From initial scope to ongoing readiness.

Begin with a security baseline. Once scope and gaps are understood, set owners and milestones for remediation, testing, and evidence.

01 / Scope
Map the activity.
Document your services, systems, and planned operating model with your legal and compliance advisors.
02 / Assess
Find the gaps.
Review relevant technical controls and security evidence, then prioritize findings by risk and effort.
03 / Remediate
Close them.
Implement agreed improvements, run the required security work, and record remediation evidence.
04 / Prepare
Support the file.
Organize the technical evidence and test results for use by your team and authorized advisors.
05 / Operate
Keep it current.
Review controls, systems, and evidence over time as your operations and the applicable framework evolve.

Questions VASPs ask before starting.

VARA’s marketing rules cover marketing virtual assets or virtual-asset activities in or targeting the UAE, including activity by foreign entities. Whether a license is required depends on the services and facts of the business. Ask qualified UAE counsel to confirm applicability. We can help map the technical services and security controls involved.