Guide, reviewed
RWA tokenization regulation in the UAE: VARA, DFSA, FSRA and the Land Department
RWA tokenization is legal in the UAE, but the rulebook depends on where the issuer is based and what the token represents. Dubai outside the DIFC falls under VARA, the DIFC under the DFSA, ADGM under the FSRA and the rest of the country under federal regulators; tokenized Dubai property also involves the Dubai Land Department, which opened its pilot on 19 March 2025.
Key points as of , sources listed at the end
Key takeaways
- Five financial regulators cover tokenization in the UAE, one per zone or subject: VARA, the DFSA, the FSRA, the federal Capital Market Authority and the Central Bank of the UAE. The Dubai Land Department keeps the property register.
- VARA's Marketing Regulations apply to anyone who markets virtual assets in or to the UAE, licensed by VARA or not. Marketing records must be kept for 8 years.
- A VARA licence lists specific activities. Issuing a token that represents a real-world asset is Category 1 VA Issuance, a separate permission: 2 of the 58 licensed firms on the public register held it on 12 October 2026 (our count).
- The Dubai Land Department opened its tokenisation pilot on 19 March 2025 and announced the Property Token Ownership Certificate on 29 May 2025.
- Check the register before you rely on any licence claim, including ours: Mantra Finance FZE holds VARA VASP Licence VL/25/02/001, and MANTRA Chain Association holds no licence.
- This guide is general information and not legal advice.
Framework set on , source Cabinet Decision No. 111 of 2022
The UAE regulatory map at a glance
Which regulator applies depends on two things: where the company is established and what the token is. The UAE has two financial free zones with their own regulators, the Dubai International Financial Centre (DIFC) and Abu Dhabi Global Market (ADGM). Dubai outside the DIFC has the Virtual Assets Regulatory Authority (VARA). Federal rules cover the rest.
Cabinet Decision No. 111 of 2022, issued on 12 December 2022, drew those lines. It covers virtual assets across the UAE and its free zones, but not the financial free zones, not digital securities under the securities regulator's own rules and not payment tokens under the Central Bank.
This page is one of the MANTRA Chain guides to tokenization. If the subject is new to you, read what RWA tokenization is first.
Schematic, as read , sources in the table below
Last verified , re-verified at least every 90 days
| Where | Regulator | What it regulates | Main source | Public register |
|---|---|---|---|---|
| Dubai, outside the DIFC | Virtual Assets Regulatory Authority (VARA) | Virtual assets and virtual asset activities. Issuing an asset-referenced token needs a VARA licence. | Virtual Asset Issuance Rulebook, Annex 2 | VARA public register |
| DIFC | Dubai Financial Services Authority (DFSA) | Investment Tokens: security and derivative tokens marketed, issued, traded or held in or from the DIFC. | DFSA media release of 25 October 2021 | DFSA public register on dfsa.ae, address not confirmed |
| ADGM | Financial Services Regulatory Authority (FSRA) | Digital securities: a token with the features of a security is regulated as a security. | ADGM announcement of 5 September 2019 | FSRA public register |
| UAE outside the financial free zones | Capital Market Authority (CMA), named the Securities and Commodities Authority in the 2022 decision | Virtual asset activities and their providers nationwide, with licensing in Dubai delegated to VARA. | Cabinet Decisions No. 111 and No. 112 of 2022 | CMA list of licensed companies |
| Payment tokens, UAE-wide | Central Bank of the UAE | Payment token issuance, conversion, and custody and transfer. | Payment Token Services Regulation, C 2/2024 | Not confirmed |
| Dubai property | Dubai Land Department | The property register and the Property Token Ownership Certificate in its pilot. The token itself is under VARA's rules. | Land Department announcement of 19 March 2025 | None of its own. The pilot platform's licence is on the VARA register. |
| Last verified . A dashed value could not be opened and awaits confirmation. | ||||
Terms used in this guide
- RWA
- Real-world asset. In VARA's rulebook: a stake in a financial instrument or arrangement, a physical asset or an intangible right, but not the token itself.
- ARVA
- Asset-Referenced Virtual Asset: a token that represents ownership of an RWA, a right to income from one, or a value kept stable against or backed by one.
- FRVA
- Fiat-Referenced Virtual Asset: a token that aims at a stable value against a currency and is not issued as a means of payment in the UAE.
- VASP
- Virtual asset service provider: an entity that VARA has authorised to carry on virtual asset activities in Dubai.
Fuller entries are in the glossary: VASP and ARVA.
Rulebooks read , source rulebooks.vara.ae
RWA tokenization in Dubai: VARA
RWA tokenization in Dubai, outside the DIFC, is regulated by VARA, which Dubai Law No. 4 of 2022 set up to regulate virtual assets and their service providers. Three texts matter most: the Virtual Asset Issuance Rulebook, its Annex 2 and the Marketing Regulations of 2024.
What VARA regulates
VARA oversees virtual assets and virtual asset activities in every zone of Dubai, free zones included, except the DIFC. Cabinet Decision No. 112 of 2022 delegates to it the federal securities regulator's licensing and supervision powers inside the emirate. Anyone who wants to carry on a listed activity in or from Dubai needs a VARA licence first.
Issuance: Category 1 and asset-referenced virtual assets
A token that represents a real-world asset is an asset-referenced virtual asset in VARA's terms, and issuing one is Category 1 VA Issuance. The rulebook sorts every issuance into three groups:
- Category 1. Fiat-referenced and asset-referenced tokens. The issuer needs a VARA licence, and VARA must approve each ARVA before it is issued.
- Category 2. Any other token that is not exempt. No licence is needed, but all placement and distribution must go through a firm licensed by VARA for Broker-Dealer Services.
- Exempt. Non-transferable tokens and redeemable closed-loop tokens.
Annex 2 adds duties for ARVA issuers. At least once a month they publish on their website the number and value of tokens in public circulation. Every six months they commission an independent audit of those figures, and every year an audit of their financial statements. A direct right of ownership must be legally established and move with the token. A right of redemption must be free of fees. A token that claims a stable value needs reserve assets, held with licensed custodians and kept apart from the issuer's own funds.
Licensed activities
A VARA licence is a list of named activities, and a firm may do only what its list says. VARA defines eight licensed activities. One licence can combine several, but custody must sit in a separate legal entity with its own licence.
Issuance is the rare one. On 12 October 2026 the public register showed 58 licensed firms: 2 listed Category 1 VA Issuance and 43 listed Broker-Dealer Services (our count). Under the rulebook, a broker-dealer or exchange licence on its own does not cover issuing an asset-referenced token.
Marketing rules that apply to everyone
VARA's Marketing Regulations apply to all marketing of virtual assets or virtual asset activities "in or targeting the UAE", by any entity, domestic or foreign, licensed by VARA or not. Marketing is defined widely: advertisements, social posts, events, airdrops and educational content such as articles all count. It must be fair, clear and not misleading. For a token, the main rules are these:
- It must carry a prominent disclaimer that virtual assets may lose their value in full or in part and are extremely volatile, and say clearly that an investor can lose everything invested and has no financial protection.
- It must not state or imply that an investment is low risk or that returns are assured.
- An offer limited to certain classes of investor must be shown only to those classes.
- Records of all marketing must be kept for at least eight years.
An ARVA has two more. Its marketing must say that the token is not covered by any investor protection or deposit guarantee scheme, and the word stablecoin is reserved for an approved, reserve-backed ARVA that tracks a single asset. This site's own wording is in the MANTRA Chain risk disclosure.
Pilot launched , source Dubai Land Department
Is real estate tokenization legal in Dubai? The Land Department pilot
Yes: real estate tokenization is legal in Dubai within the Dubai Land Department's pilot and under VARA's rules for the token. The Land Department launched the pilot phase of its Real Estate Tokenisation Project on 19 March 2025. A property token is an asset-referenced virtual asset, so the issuance and marketing rules above apply to it. The register entry of the pilot's platform says as much: its licence condition refers to the tokenisation of ARVA authorised by the Dubai Land Department.
Who does what in the pilot
- Dubai Land Department
- Runs the project, keeps Dubai's property register and issues the Property Token Ownership Certificate.
- VARA
- Regulates the token and the platform. The register entry of Prypco FZE, whose listed website is the Prypco Mint platform, shows a VASP Licence for Broker-Dealer Services, issued on 24 May 2025, for retail and qualified investors.
- Dubai Future Foundation
- A partner in the project through the Real Estate Sandbox.
- Central Bank of the UAE
- Named as a collaborator in the Land Department's announcement of 29 May 2025.
Key dates
- The Land Department launches the pilot phase with VARA and the Dubai Future Foundation.
- VARA issues the platform's licence, as shown on the public register.
- The Land Department announces the Property Token Ownership Certificate, after the first tokenised project sold within one day.
- The Land Department's projection for the tokenised property market: AED 60 billion, or 7% of Dubai's real estate transactions. A projection, not a measured figure.
What the certificate records, how it relates to the property register and the figures of the first project are set out in how real estate tokenization works: the title and the Land Department certificate.
Releases read , sources DFSA rulebook site, adgm.com and the federal regulators
DIFC: the DFSA and investment tokens
Inside the DIFC the regulator is the DFSA, and it treats tokenized securities and derivatives as Investment Tokens. It launched that framework on 25 October 2021 as the first phase of its digital assets regime. An Investment Token is a Security Token or a Derivative Token: in short, a security or derivative issued, transferred and stored on distributed ledger technology, or a token with substantially the same rights, purpose or effect.
The framework applies to anyone who markets, issues, trades or holds such tokens in or from the DIFC, and to authorised firms that deal in, advise on or arrange deals in them. On 17 March 2025 the DFSA invited expressions of interest in a Tokenisation Regulatory Sandbox for firms tokenising investments such as equities, bonds, sukuk and fund units; by 16 June 2025 it had received 96. The DFSA regulates other crypto tokens under a separate Crypto Token regime, which it updated on 12 January 2026.
The DFSA's rules on offers, trading venues and custody for Investment Tokens were not read for this guide. A VARA licence does not reach into the DIFC: VARA's own rulebook defines its territory as every zone of Dubai except the DIFC.
ADGM: the FSRA and digital securities
In Abu Dhabi Global Market the regulator is the FSRA, and its rule is short: a token with the features of a security is regulated as a security. The FSRA published its Guidance for Digital Securities activity in ADGM on 5 September 2019. The version linked from ADGM's digital assets page on 12 October 2026 is dated 24 February 2020.
Under that guidance the FSRA decides case by case whether a token has the features of a security and, if so, deems it one. An offer to the public then needs an approved prospectus unless it is an exempt offer. The guidance names three kinds: an offer directed only at professional clients that are not natural persons, one directed at fewer than 50 persons in any 12 months, and one where each investor pays at least USD 100,000.
Federal regulators
Two federal bodies sit above the zones: the securities regulator, which now uses the name Capital Market Authority, and the Central Bank of the UAE.
Securities regulator
Cabinet Decision No. 111 of 2022 makes the federal securities regulator the licensing authority for virtual asset activities across the UAE, outside the financial free zones. The decision calls it the Securities and Commodities Authority. The authority's own website now uses the name Capital Market Authority (CMA) and traces itself to the same founding law, Federal Law No. 4 of 2000. Nobody may carry on a virtual asset activity in the UAE without a licence from the authority or from a local licensing authority such as VARA, and the penalties the decision provides for include fines of up to AED 10,000,000.
On 13 April 2026 the CMA announced a Virtual Assets Framework with five modules and eight regulated activities. One module covers trading facilities, including facilities for tokenized securities. The framework's own text was not read for this guide.
Central Bank of the UAE and payment tokens
A token used as a means of payment belongs to the Central Bank, not to VARA or the CMA. Its Payment Token Services Regulation, circular C 2/2024, has been in force since 31 August 2024 and covers three services: payment token issuance, conversion, and custody and transfer.
This is why the word stablecoin should not be used loosely for a property or commodity token. In Dubai, Annex 2 allows the term in marketing only for an approved, reserve-backed ARVA that tracks one asset. A token built to be spent moves into the Central Bank's regime. A token that gives a share in a building is an asset-referenced token, not a payment instrument, and should be described that way.
Compiled , sources the rulebooks and guidance cited above
RWA tokenization platforms in the UAE: which licence each role needs
An RWA tokenization platform in the UAE is not one regulated thing: the word covers an issuer, a distributor or exchange, a custodian and the technology underneath. Each role needs its own permission, from the regulator of the zone where it operates.
As of , a dashed value was not read from a primary source
| Role | Dubai, VARA | DIFC, DFSA | ADGM, FSRA |
|---|---|---|---|
| Issuer | Category 1 VA Issuance licence, plus approval of each ARVA. | Investment Token framework. Offer rules not read | Approved prospectus or exempt offer for a token deemed a security. |
| Exchange or broker-dealer | Exchange Services or Broker-Dealer Services. | DFSA authorisation to deal in or arrange Investment Tokens. Venue rules not read | Financial Services Permission; trading on recognised exchanges and multilateral trading facilities. |
| Custodian | Custody Services, in a separate legal entity. | Not read | Financial Services Permission for providing custody. |
| Technology provider or blockchain | Not one of the eight listed activities; the provider must check whether it carries on one. | Not read | Not read |
| Last reviewed . Dubai means Dubai outside the DIFC. General information, not legal advice. | |||
Issuer
The issuer carries the heaviest permission, and in Dubai each token needs its own approval. VARA may revoke an issuance licence if the token is not issued within six months of approval.
Exchange or broker-dealer
Selling, arranging or listing a token is a licensed activity of its own. A distributor that places a Category 2 token also takes on the duty to check that its issuer follows the rulebook.
Custodian
Asset-referenced tokens raise two custody questions: who holds the clients' tokens, and who holds the underlying asset or reserve. Where reserves exist, Annex 2 requires a custodian that is validly licensed to hold them.
Technology provider or blockchain
Operating a public blockchain is not one of the eight activities VARA lists. VARA adds that no virtual asset activity is exempt and that providers of distributed ledger technology must work out whether anything they do falls within the eight. MANTRA Chain Association states in the site Terms that it only operates the blockchain and does not provide or offer products or services. It is not licensed by VARA, and this site says so on every page; a separate MANTRA Group company, Mantra Finance FZE, holds VARA VASP Licence VL/25/02/001.
Worked example, illustrative numbers
A company in a Dubai free zone wants to tokenize a pool of equipment leases worth AED 5,000,000 as 50,000 tokens of AED 100 each, with holders sharing the lease income. None of this is a real offer.
- The token gives a right to income from a real-world asset, which fits the rulebook's definition of an ARVA. The company needs a VARA licence for Category 1 issuance and VARA's approval of this token.
- If 30,000 tokens are sold in the first month, the next monthly disclosure shows 30,000 tokens and AED 3,000,000 in public circulation.
- In a year it commissions two independent audits of the circulation figures and one audit of its financial statements.
- A campaign last run in October 2026 stays on file until at least October 2034.
- In ADGM the first question would be whether the token is a security. An exempt offer could be limited to fewer than 50 persons in 12 months or require at least USD 100,000 from each investor.
How the chain itself applies an issuer's rules is covered on the RWA tokenization platform page. The roles and licences for property are tabled on real estate tokenization in Dubai.
Register read , source VARA public register entry VL/25/02/001
Reading a real register entry: Mantra Finance FZE
The VARA register entry for Mantra Finance FZE shows one VASP Licence, reference VL/25/02/001, issued on 19 February 2025 for three activities. The entry is read below line by line, as it stood on 12 October 2026.
What the entry says
As printed on , source register entry for Mantra Finance FZE
| Field | Entry | How to read it |
|---|---|---|
| VASP name | Mantra Finance FZE | The legal entity that holds the licence. It is not MANTRA Chain Association, which operates the blockchain. |
| Reference | VL/25/02/001 | The licence number. A claim to be licensed by VARA should carry it. |
| Website | www.mantrachain.io | The website the register lists. The site's Terms name MANTRA Chain Association as its operator, so the footer names both companies. |
| Licence type | VASP Licence | A full licence. Firms with only an in-principle approval sit on a separate tab and may not operate. |
| Licensed activities | Exchange Services; Broker-Dealer Services; Management and Investment Services | The complete list. Anything not named here is not licensed. |
| Licence issued | 2025/02/19 | 19 February 2025. |
| Licence condition | Institutional, Qualified and Retail Investors may be served, including with DeFi products and services under the DeFi Limited Licence (our summary) | Who the firm may serve. Its marketing has to match these classes. |
| Status | Active | Check it on the day you rely on it. |
| CMA Registration Number | CMA-VASP-1101000-0026 | Printed with the register's own label. The entry does not say what the number confers. |
| Entry VL/25/02/001, last verified . Licensing or registration with VARA does not imply endorsement of any product. | ||
What it does not say
Not on the entry
- No Category 1 VA Issuance. Mantra Finance FZE is not licensed to issue asset-referenced tokens. RWA tokens distributed through it are issued by other, named issuers: the Green Velocity 1 Token, for example, is by Pyse, and MANTRA Finance announced a pause in subscriptions to it on 16 March 2026.
- No other company. The entry does not name MANTRA Chain Association, MANTRA Chain or the MANTRA coin. The licence does not make the blockchain or its coin a regulated product. The companies are set out on the page about MANTRA Chain and its entities.
- No other zone. A VARA licence, VL/25/02/001 included, covers Dubai outside the DIFC. It is not a DFSA or FSRA permission.
See how compliance works on the platform
The platform page sets out the token standards, how an issuer's rules travel with a token and which company is licensed for what.
How to check a licence on the VARA public register
Checking a VARA licence takes four steps on the public register, which listed 58 licensed firms on 12 October 2026.
- Open the register. Go to the VARA public register. It has two tabs: licensed firms, and firms with an in-principle approval, which VARA says may not start operations or serve clients.
- Search the legal name. Use the company's legal name, not its brand: Mantra Finance FZE, not MANTRA. A name that is on neither tab is not on VARA's list of licensed firms.
- Compare the reference number and the activities. The reference, for example VL/25/02/001, should match the one the firm prints, and the service it sells should be on its list of activities.
- Check the status and the conditions. The status should read Active, and the licence condition says which classes of investor the firm may serve.
Do the same on the FSRA register for an ADGM firm and on the DFSA's register for a DIFC firm. A licence in one zone does not carry into another.
Regulation read , source Official Journal of the European Union
How the UAE approach compares with the EU
The EU regulates crypto-assets with one regulation for all member states; the UAE regulates by zone. Regulation (EU) 2023/1114, known as MiCA, has applied in full since 30 December 2024. It covers crypto-assets that are not financial instruments and, with some exemptions, requires an offeror to draw up, notify and publish a crypto-asset white paper, which under Article 6 must say on its first page that no competent authority has approved it. A token that qualifies as a financial instrument stays under EU securities law. The UAE draws that line zone by zone: the DIFC and ADGM apply securities rules to security-like tokens, while VARA's definition of a real-world asset is wide enough to include a stake in a financial instrument. MANTRA publishes a MiCA Article 6 white paper for its coin, described in the MiCA white paper summary on the token page. No MANTRA company claims authorisation as a crypto-asset service provider in the EU.
Common mistakes in UAE tokenization marketing
Six wording mistakes are worth checking for in tokenization marketing aimed at the UAE. Each can be tested against a public source.
- Stating a licence more broadly than the register. A licence belongs to the named company and covers the listed activities.
- Naming a regulator without the licence number. Give the number and link the register entry.
- Calling a certificate a title deed. The Land Department's document is the Property Token Ownership Certificate.
- Using stablecoin loosely. In Dubai marketing the term is reserved for an approved, reserve-backed token that tracks one asset.
- Promising returns. VARA's rules bar any statement or hint that returns are assured.
- Assuming a Dubai licence covers the DIFC or ADGM. Each zone has its own regulator and register.
How this site words its own claims is shown on the page of MANTRA licences and regulatory disclosures.
Frequently asked questions
Is RWA tokenization legal in the UAE?
Yes. RWA tokenization is legal in the UAE when the issuer and the firms that sell or hold the token have the permissions their zone requires. In Dubai outside the DIFC that means VARA's rules, including a Category 1 licence for issuing an asset-referenced token. The DIFC and ADGM apply their own rules for tokenized securities.
Who regulates property tokens in Dubai?
VARA regulates the token and the platform, and the Dubai Land Department keeps the property register. In the Land Department's pilot, launched on 19 March 2025, the platform's VARA licence refers to tokenisation authorised by the Land Department, which also issues the Property Token Ownership Certificate.
Does a VARA licence allow a company to issue RWA tokens?
Only if the licence lists Category 1 VA Issuance. A VARA licence names specific activities, and issuing an asset-referenced token is a separate one that also needs VARA's approval of each token. On 12 October 2026 we counted 2 of 58 licensed firms on the public register with that activity.
Is MANTRA licensed by VARA?
One MANTRA Group company is: Mantra Finance FZE holds VARA VASP Licence VL/25/02/001 for three activities, Exchange Services, Broker-Dealer Services and Management and Investment Services. MANTRA Chain Association, which operates the blockchain, is not licensed by VARA, as set out in MANTRA licences and regulatory disclosures.
Do VARA marketing rules apply to foreign companies?
Yes. VARA's Marketing Regulations apply to all marketing of virtual assets or virtual asset activities in or targeting the UAE, by domestic and foreign entities, licensed or not. A firm is outside them only if it is not located in Dubai, carries on no virtual asset activity there and does no marketing in or aimed at the UAE.
What is the difference between VARA, the DFSA and the FSRA?
They regulate different places. VARA covers virtual assets in all of Dubai except the DIFC. The DFSA regulates financial services in and from the DIFC, where tokenized securities are Investment Tokens. The FSRA regulates ADGM in Abu Dhabi, where a security-like token is treated as a security. A licence from one does not cover the others.
Sources read
Sources
- Virtual Assets Regulatory Authority, public register, entry for Mantra Finance FZE (VL/25/02/001), vara.ae. The full register and the Licensed Activities page were read on the same site.
- Virtual Assets Regulatory Authority, Virtual Asset Issuance Rulebook, Part I and Annex 2, rulebooks.vara.ae.
- Virtual Assets Regulatory Authority, Regulations on the Marketing of Virtual Assets and Related Activities 2024, Introduction and Part I, rulebooks.vara.ae.
- Dubai Land Department, announcement of the pilot phase of the Real Estate Tokenisation Project, 19 March 2025, dubailand.gov.ae.
- Dubai Land Department, announcement of the Property Token Ownership Certificate, 29 May 2025, dubailand.gov.ae.
- Dubai Financial Services Authority, media release of 25 October 2021 on the regulatory framework for Investment Tokens, on the DFSA rulebook site, dfsaen.thomsonreuters.com. The releases of 17 March 2025, 16 June 2025 and 12 January 2026 were read there too.
- ADGM Financial Services Regulatory Authority, announcement of 5 September 2019 on the Guidance for Digital Securities activity in ADGM, adgm.com, with the guidance version VER02 of 24 February 2020.
- Regulation (EU) 2023/1114 of 31 May 2023 on markets in crypto-assets, Official Journal L 150, 9 June 2023, publications.europa.eu.
All eight were read on 12 October 2026. The federal documents are linked where they are cited: the Cabinet Decisions of 2022, the Capital Market Authority's announcement of 13 April 2026 and the Central Bank's regulation C 2/2024. MANTRA's own statements come from the site Terms (mantrachain.io/terms, last updated 14 November 2024).
Disclaimer
For information only. Not investment advice. This guide describes the rules in general terms and is not legal advice: rules change, and the regulator's own text and a lawyer admitted in the relevant zone are the authorities to rely on.