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United Arab Emirates -- Stablecoin Regulations Regulatory Overview

Published: 2026-04-26 Updated: 2026-08-23 Researched: 2026-08-23 Author: openrouter/nvidia/nemotron-3-ultra-550b-a55b:free Version 2 Sources cited in: English (13), Arabic (1)
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United Arab Emirates Stablecoin

Executive Summary

  • Cryptocurrency and stablecoin activity is legal in the UAE, but the regulatory landscape is fragmented across multiple free zones and mainland authorities, with the Financial Services Regulatory Authority (FSRA) in ADGM and the Dubai Financial Services Authority (DFSA) in DIFC serving as the primary financial regulators for digital assets in their respective jurisdictions. The Virtual Assets Regulatory Authority (VARA) was established in Dubai to regulate virtual assets outside financial free zones. Licensing is available and operational — multiple entities have secured approvals, including Circle, which obtained a license in ADGM for its stablecoin operations. The practical reality is a maturing but complex regime where stablecoin issuers must navigate free zone-specific rules, with ADGM's Fiat-Referenced Token framework being the most developed. Digital Assets Virtual Assets Regulatory Authority (VARA) - VARA Circle Advances UAE Expansion with ADGM License and Appoints Managing Director for Circle MEA

Regulatory Framework

Licensing Requirements

  • Financial services entities wishing to carry on virtual asset or stablecoin activities in ADGM must apply for a Financial Services Permission from the FSRA under the applicable financial services regulations. Digital Assets
  • A Fiat-Referenced Token (FRT) is defined in the Financial Services and Markets Regulations of ADGM, and the FSRA has implemented a dedicated framework for FRT issuance in the jurisdiction. Digital Assets
  • Under COBS 17.2A.1, an Authorised Person carrying on a Regulated Activity involving an FRT must only use Accepted FRTs — those which have been approved by the FSRA and included on the current Accepted FRT list. Digital Assets
  • An Authorised Person seeking inclusion of an FRT on the FSRA's Accepted FRT List must submit a request to its firm supervisor; the list may change from time to time. Digital Assets
  • The FSRA regulates spot virtual asset activities, including multilateral trading facilities, brokers, custodians, asset managers, and other intermediaries, all requiring authorisation. Digital Assets Guidance – Regulation of Virtual Asset Activities in ADGM (VER07.100625)
  • The FSRA was the first regulator globally to regulate platforms enabling trading of Virtual Assets as Multilateral Trading Facilities (MTFs), subjecting them to requirements on market surveillance, settlement, transaction monitoring, recording, transparency, and systems and controls. Digital Assets
  • Digital tokens exhibiting characteristics of a Security are deemed and regulated as Securities by the FSRA, requiring issuers to comply with the securities regime. Digital Assets
  • Derivatives over Digital Assets and Collective Investment Funds investing in Digital Assets are regulated as Derivatives and Units in a Fund by the FSRA; market operators and intermediaries dealing in such products must be licensed. Digital Assets
  • In the DIFC, firms conducting financial services involving Crypto Tokens must apply for a license from the DFSA, which has issued updated rules specifically for crypto token regulation. DFSA | DFSA issues updated rules on the regulation of Crypto Tokens in the DIFC DFSA | Crypto Token Regulation
  • In Dubai's mainland, virtual asset service providers must obtain a license from VARA, which maintains a full rulebook covering requirements for various virtual asset activities. Welcome to the VARA Rulebook | Virtual Assets Regulatory Authority (VARA)
  • The application process for FSRA authorisation requires submission of forms with detailed information; the FSRA Authorisation Team assesses operational, financial, and regulatory track record of the entity and shareholders, fitness and propriety of senior management, and resources, systems, and controls. Digital Assets
  • The FSRA application process involves five steps: contact the Authorisation Team, submit the completed application form with documentation and application fee, participate in interviews with the Authorisation Team, receive in-principle approval notification, and accept conditions to proceed with capitalisation and registration. Digital Assets
  • The DLT Foundations Framework in ADGM is the world's first framework for Blockchain Foundations and Decentralised Autonomous Organisations (DAOs), providing a governance vehicle for token issuers including stablecoin-related foundations. Digital Assets
  • A stablecoin issuer has actually been licensed in ADGM: Circle, a leading digital currency company, advanced its UAE expansion with an ADGM license and appointed a Managing Director for Circle MEA. Circle Advances UAE Expansion with ADGM License and Appoints Managing Director for Circle MEA
  • VARA has been actively licensing virtual asset service providers in Dubai under its regulatory regime, with the VARA Rulebook providing the relevant licensing requirements. Welcome to the VARA Rulebook | Virtual Assets Regulatory Authority (VARA) Virtual Assets Regulatory Authority (VARA) - VARA

AML/KYC Requirements

Enforcement Actions

  • The FSRA's Guiding Principles to Virtual Asset Regulation and Supervision include "enforcement" as one of the six key pillars, indicating the regulator's commitment to active enforcement of its virtual asset framework. Digital Assets
  • No specific enforcement cases against stablecoin issuers have been publicly documented, though the FSRA has publicly stated that its regulatory framework addresses risks relating to market abuse, and the Guiding Principles explicitly cover enforcement. Guidance – Regulation of Virtual Asset Activities in ADGM (VER07.100625)
  • ADGM's dispute resolution infrastructure, including the ADGM eCourts Platform, provides a venue for regulatory enforcement and civil disputes relating to virtual asset activities. Digital Assets
  • The regulatory cooperation MoU between ADGM's FSRA and GCGRA signals ongoing inter-agency enforcement coordination, though specific enforcement outcomes have not been publicly detailed. Digital Assets

Tax Treatment

Key Gaps & Risks

  • The UAE's fragmented regulatory structure creates compliance complexity: a stablecoin issuer may need to obtain separate licenses from ADGM/FSRA, DIFC/DFSA, and Dubai's VARA, each with its own rulebook, creating potential conflicts and inefficiencies. Digital Assets DFSA | The independent regulator of financial services of DIFC Welcome to the VARA Rulebook | Virtual Assets Regulatory Authority (VARA)
  • The distinction between a "Fiat-Referenced Token" (FRT) regulated by FSRA in ADGM versus "Crypto Tokens" regulated by DFSA in DIFC versus virtual assets under VARA's regime may create regulatory classification uncertainty for issuers operating across the UAE. Digital Assets DFSA | Crypto Token Regulation Welcome to the VARA Rulebook | Virtual Assets Regulatory Authority (VARA)
  • The FSRA's Accepted FRT list is dynamic and can change from time to time, creating ongoing compliance and reputational risk for stablecoin issuers that may be removed from the list. Digital Assets
  • The FSRA explicitly warns that inclusion on the Accepted FRT list does "not relieve potential FRT holders from the necessity of conducting their own assessment on the FRT issuer, including but not limited to assessing its creditworthiness and the composition of its reserves," placing due diligence burden on market participants. Digital Assets
  • The regulatory framework requires Authorised Persons to obtain FSRA approval for FRT use, but the process and criteria for approval are not fully detailed in the public-facing materials, creating uncertainty for applicants. Digital Assets
  • The FSRA's application process requires a "regulatory plan, setting out the planned regulated activities, internal controls and resources to address the related risks," but the depth of required detail and review timelines are not public, making the timeline uncertain for applicants. Digital Assets
  • The federal framework under Cabinet Decision No. 111/2022 delegates significant authority to VARA and free zone regulators, but the relationship between federal and free zone oversight in practice remains an area of ongoing development. Cabinet Decision No. 111/2022 - On the Regulation of ...
  • While Circle's ADGM license demonstrates that stablecoin licensing works in practice, it also highlights that VARA's and DFSA's crypto regimes are relatively newer and less tested compared to more established jurisdictions, presenting execution risk for license applicants. Circle Advances UAE Expansion with ADGM License and Appoints Managing Director for Circle MEA

Sources

Source Data

93%

The CBUAE licenses Dirham Payment Token issuers under the Payment Token Services Regulation (Circular No. 2/2024, in force 31 August 2024), and VARA's FRVA Rules state that tokens referencing the AED remain under the sole and exclusive regulatory purview of the CBUAE.

[primary] Payment Token Services Regulation (CBUAE Circular No. 2/2024, 7 June 2024) — full text
85%

The FSRA Accepted FRT list dated 1 September 2026 includes three Paxos-issued tokens: PYUSD (Paxos Trust Company, N.A.), USDP (Paxos Trust Company) and USDG (Paxos Digital Singapore). Acceptance permits use by ADGM Authorised Persons and is distinct from an FSRA permission to issue FRTs in ADGM.

[primary] FSRA Consolidated List of Accepted Fiat-Referenced Tokens (1 September 2026) [primary] ADGM — Business Areas: Digital Assets
90%

UAE virtual-asset and stablecoin activity is not unified under VARA: VARA regulates Dubai's mainland and free zones except the DIFC, the DFSA regulates the DIFC (GEN 3A), the FSRA regulates ADGM, and the CBUAE Payment Token Services Regulation governs payment-token services onshore, including for VARA- and SCA/CMA-licensed firms.

[primary] VARA Rulebooks — Laws & Regulations [primary] ADGM — Business Areas: Digital Assets [primary] Payment Token Services Regulation (CBUAE Circular No. 2/2024, 7 June 2024) — full text
88%

Within Dubai, VARA is the sole virtual-asset regulator for the mainland and free zones except the DIFC, where the DFSA regulates Crypto Tokens under GEN 3A; this is not a UAE-wide framework, as the FSRA regulates ADGM and federal CMA and CBUAE rules apply onshore.

[primary] VARA Rulebooks — Laws & Regulations [primary] ADGM — Business Areas: Digital Assets [primary] Payment Token Services Regulation (CBUAE Circular No. 2/2024, 7 June 2024) — full text
85%

The Financial Services Regulatory Authority (FSRA) is the financial services regulator of Abu Dhabi Global Market (ADGM), the international financial centre of Abu Dhabi, and grants the Financial Services Permissions that ADGM digital asset businesses require.

[primary] ADGM — Business Areas: Digital Assets [secondary] Circle Advances UAE Expansion with ADGM License (third-party release hosted by ADGM, 9 Dec 2025)
90%

VARA's governing law is Dubai Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai, not federal Cabinet Resolution No. 111 of 2022; VARA regulates virtual assets across Dubai's mainland and free zones except the DIFC, and version 1 of its VA Issuance Rulebook is dated 7 February 2023.

[primary] VARA Rulebooks — Laws & Regulations
82%

Cabinet Decision No. 111/2022 on the Regulation of Virtual Assets and Their Service Providers is a federal instrument; the delegation of virtual-asset competencies is the subject of the separate Cabinet Decision No. 112/2022, and VARA's governing law is Dubai Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai.

[primary] VARA Rulebooks — Laws & Regulations
85%

ADGM states it was the first jurisdiction in the region to introduce a comprehensive regulatory framework for digital assets; the FSRA framework covers Virtual Assets, Fiat-Referenced Tokens, Digital Securities, and Derivatives and Funds of digital assets.

[primary] ADGM — Business Areas: Digital Assets [primary] FSRA Guidance – Regulation of Virtual Asset Activities in ADGM (VER07.100625)
90%

The DFSA's updated Crypto Token rules (GEN 3A, version in force from 12 January 2026) apply only to activities carried on in or from the DIFC; the rest of Dubai is regulated by VARA and ADGM by the FSRA.

[primary] VARA Rulebooks — Laws & Regulations
88%

The FSRA 'Guidance – Regulation of Virtual Asset Activities in ADGM' is in version VER07.100625 (10 June 2025) and covers the Virtual Asset Framework, Accepted Virtual Assets, capital, AML/CFT, technology governance, Fiat-Referenced Tokens and other stablecoins.

[primary] FSRA Guidance – Regulation of Virtual Asset Activities in ADGM (VER07.100625) [primary] ADGM — Business Areas: Digital Assets
90%

VARA's rulebook framework comprises Compulsory Rulebooks and activity Rulebooks for Advisory, Broker-Dealer, Custody, Exchange, Lending and Borrowing, VA Management and Investment, VA Transfer and Settlement, and VA Issuance, issued under the Virtual Assets and Related Activities Regulations 2023.

[primary] VARA Rulebooks — Laws & Regulations
93%

Financial services entities that wish to carry on Virtual Asset, Fiat-Referenced Token, Digital Securities or digital-asset derivative and fund activities in ADGM must apply to the FSRA for a Financial Services Permission.

[primary] ADGM — Business Areas: Digital Assets
93%

In ADGM, a Fiat-Referenced Token (FRT) is a digital asset meeting the FRT definition in the Financial Services and Markets Regulations: it references a fixed amount of a single fiat currency and is redeemable from its issuer on demand. Issuing an FRT is a distinct FSRA Regulated Activity (FSRA Guidance VER07.100625).

[primary] ADGM — Business Areas: Digital Assets [primary] FSRA Guidance – Regulation of Virtual Asset Activities in ADGM (VER07.100625)
95%

Under ADGM COBS 17.2A.1, an Authorised Person carrying on a Regulated Activity involving an FRT may use only Accepted FRTs approved by the FSRA; the list dated 1 September 2026 accepts nine FRTs (EURC, PYUSD, RLUSD, USD1, USDC, USDG, USDP, USDT, USDU), each only on specified networks.

[primary] FSRA Consolidated List of Accepted Fiat-Referenced Tokens (1 September 2026) [primary] ADGM — Business Areas: Digital Assets
93%

An ADGM Authorised Person seeking inclusion of an FRT on the FSRA Accepted FRT list submits the request to its firm supervisor. The FSRA states the list may change from time to time; the consolidated list dated 1 September 2026 accepts nine FRTs.

[primary] ADGM — Business Areas: Digital Assets [primary] FSRA Consolidated List of Accepted Fiat-Referenced Tokens (1 September 2026)
93%

The FSRA regulates spot virtual asset activities in ADGM, including those of multilateral trading facilities, brokers, custodians, asset managers and other intermediaries, all of which require FSRA authorisation.

[primary] ADGM — Business Areas: Digital Assets [primary] FSRA Guidance – Regulation of Virtual Asset Activities in ADGM (VER07.100625)
88%

The FSRA states it was the first regulator globally to regulate Virtual Asset trading platforms as Multilateral Trading Facilities, which must meet requirements on market surveillance, settlement, transaction monitoring and recording, transparency and other systems and controls.

[primary] ADGM — Business Areas: Digital Assets
92%

In ADGM, any digital token that exhibits the characteristics of a Security is deemed and regulated as a Security by the FSRA, so its issuance and trading fall under the ADGM securities regime for Digital Securities.

[primary] ADGM — Business Areas: Digital Assets [primary] FSRA Guidance – Regulation of Digital Securities Activities in ADGM (VER02.240220, 24 February 2020)
93%

In ADGM, Derivatives over Digital Assets and Collective Investment Funds investing in Digital Assets are regulated by the FSRA as Derivatives and Units in a Fund, and market operators and intermediaries dealing in them must be licensed by the FSRA.

[primary] ADGM — Business Areas: Digital Assets [primary] FSRA Guidance – Regulation of Virtual Asset Activities in ADGM (VER07.100625)
92%

Virtual asset service providers in Dubai's mainland and free zones other than the DIFC need a VARA licence for any of eight activities: Advisory, Broker-Dealer, Custody, Exchange, Lending and Borrowing, Management and Investment, Transfer and Settlement, and VA Issuance Category 1.

[primary] VARA — Licensed Activities [primary] VARA Rulebooks — Laws & Regulations
92%

For FSRA authorisation in ADGM, applicants submit the prescribed forms; the FSRA Authorisation Team assesses the operational, financial and regulatory track record of the entity and shareholders, the fitness and propriety of senior management and key appointment holders, and the entity's resources, systems and controls.

[primary] ADGM — Business Areas: Digital Assets
85%

ADGM describes its DLT Foundations Framework as the world's first framework for Blockchain Foundations and Decentralised Autonomous Organisations (DAOs), providing a governance vehicle while minimising centralisation.

[primary] ADGM — Business Areas: Digital Assets
85%

Circle Internet Group announced on 9 December 2025 that it holds an FSRA Financial Services Permission in ADGM to operate as a Money Services Provider; that permission is not an ADGM FRT-issuance licence. Circle-issued USDC and EURC appear on the FSRA Accepted FRT list dated 1 September 2026.

[primary] FSRA Consolidated List of Accepted Fiat-Referenced Tokens (1 September 2026) [primary] ADGM — Business Areas: Digital Assets [secondary] Circle Advances UAE Expansion with ADGM License (third-party release hosted by ADGM, 9 Dec 2025)
92%

VARA's public register listed 59 licensed VASPs, all with status Active, on 14 October 2026; the most recent licences, to Payward FZCO and Rain MENA FZE, were issued in October 2026.

[primary] VARA — Public Register of licensed VASPs
88%

ADGM states that the FSRA's spot virtual asset framework addresses the full range of associated risks, including market abuse and financial crime, investor protection, technology governance, and custody and exchange operations.

[primary] ADGM — Business Areas: Digital Assets [primary] FSRA Guidance – Regulation of Virtual Asset Activities in ADGM (VER07.100625)
85%

VARA's Rulebooks are issued under Dubai Law No. (4) of 2022 and the Virtual Assets and Related Activities Regulations 2023; Cabinet Decision No. 111/2022 is a federal instrument that VARA lists separately among Cabinet Resolutions.

[primary] VARA Rulebooks — Laws & Regulations
90%

The FSRA's Guiding Principles to Virtual Asset Regulation and Supervision set out its expectations and risk appetite through six pillars: regulation; authorisation; preventing financial crimes; supervision; enforcement; and international cooperation.

[primary] ADGM — Business Areas: Digital Assets
90%

UAE federal tax law addresses virtual assets: Corporate Tax under Federal Decree-Law No. 47 of 2022 applies from tax periods starting on or after 1 June 2023, and Cabinet Decision No. 100 of 2024 added a VAT exemption for transfers and conversions of Virtual Assets to the VAT Executive Regulation (Art. 42).

[primary] Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (EN translation) [primary] Executive Regulation of Federal Decree-Law No. 8 of 2017 on VAT, as amended by Cabinet Decision No. 100 of 2024
88%

ADGM and DIFC entities fall within the federal Corporate Tax Law (Federal Decree-Law No. 47 of 2022): a Qualifying Free Zone Person pays 0% only on Qualifying Income and 9% on other taxable income, and the amended VAT Executive Regulation exempts transfers and conversions of Virtual Assets.

[primary] Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (EN translation) [primary] Executive Regulation of Federal Decree-Law No. 8 of 2017 on VAT, as amended by Cabinet Decision No. 100 of 2024
95%

The UAE federal Corporate Tax Law, Federal Decree-Law No. 47 of 2022, applies to tax periods commencing on or after 1 June 2023, at 0% on taxable income up to a Cabinet-set threshold and 9% above it.

[primary] Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (EN translation)
90%

UAE VAT exempts the transfer of ownership and the conversion of Virtual Assets under Articles 42(2)(k)-(l) and 42(3)(e) of the VAT Executive Regulation, as amended by Cabinet Decision No. 100 of 2024 (effective 15 November 2024), including supplies made on or after 1 January 2018; the VAT definition of Virtual Assets excludes digital representations of fiat currencies.

[primary] Executive Regulation of Federal Decree-Law No. 8 of 2017 on VAT, as amended by Cabinet Decision No. 100 of 2024
88%

A stablecoin business active in several UAE zones needs separate authorisations: the FSRA in ADGM (FRT issuance is a Regulated Activity), the DFSA in the DIFC (GEN 3A), VARA elsewhere in Dubai (FRVA issuance is Category 1 VA Issuance), and a CBUAE licence or registration for payment-token services onshore (PTSR Art. 2(1)).

[primary] FSRA Guidance – Regulation of Virtual Asset Activities in ADGM (VER07.100625) [primary] Payment Token Services Regulation (CBUAE Circular No. 2/2024, 7 June 2024) — full text
95%

The FSRA Consolidated List of Accepted FRTs dated 1 September 2026 names nine tokens (EURC, PYUSD, RLUSD, USD1, USDC, USDG, USDP, USDT, USDU), each accepted only on specified networks; the FSRA states the list is subject to change and does not imply acceptance for serving clients outside ADGM.

[primary] FSRA Consolidated List of Accepted Fiat-Referenced Tokens (1 September 2026) [primary] ADGM — Business Areas: Digital Assets
95%

The FSRA states that inclusion on the Accepted FRT list does not relieve potential FRT holders from conducting their own assessment of the FRT issuer, including its creditworthiness and the composition of its reserves.

[primary] ADGM — Business Areas: Digital Assets
90%

Before applying to the FSRA, an applicant meets the FSRA Authorisation Team with a regulatory plan setting out planned regulated activities, internal controls and resources; the process then runs through application and fee, interviews, in-principle approval, satisfaction of conditions, and issue of the Financial Services Permission.

[primary] ADGM — Business Areas: Digital Assets

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References

This article was generated by openrouter/nvidia/nemotron-3-ultra-550b-a55b:free .

Primary Sources

SCA. (n.d.). SCA. Retrieved April 26, 2026, from https://sca.gov.ae

CBUAE. (n.d.). CBUAE. Retrieved April 26, 2026, from https://centralbank.ae ar

(mof.gov.ae, 2025). (n.d.). (mof.gov.ae, 2025). Retrieved April 26, 2026, from https://www.mof.gov.ae/wp-content/uploads/2025/09/The-Crypto-Asset-Reporting-Framework-Guidance-document-EN.pdf

(coinpedia.org, 2025). (n.d.). (coinpedia.org, 2025). Retrieved April 26, 2026, from https://coinpedia.org/cryptocurrency-regulation/cryptocurrency-regulations-dubai/

Secondary Sources

adgm.com. (n.d.). Digital Assets. Retrieved September 9, 2026, from https://www.adgm.com/business-areas/digital-assets

vara.ae. (n.d.). Virtual Assets Regulatory Authority (VARA) - VARA. Retrieved September 9, 2026, from https://www.vara.ae/en/

adgm.com. (n.d.). Circle Advances UAE Expansion with ADGM License and Appoints Managing Director for Circle MEA. Retrieved September 9, 2026, from https://www.adgm.com/media/announcements/circle-advances-uae-expansion-with-adgm-license-and-appoints-managing-director-for-circle-mea

dfsa.ae. (n.d.). DFSA | The independent regulator of financial services of DIFC. Retrieved September 9, 2026, from https://www.dfsa.ae/

adgm.com. (n.d.). ADGM | Financial Services Regulatory Authority. Retrieved September 9, 2026, from https://www.adgm.com/financial-services-regulatory-authority

rulebooks.vara.ae. (n.d.). Cabinet Decision No. 111/2022 - On the Regulation of .... Retrieved September 9, 2026, from https://rulebooks.vara.ae/sites/default/files/en_net_file_store/VARA_EN_339_VER1.pdf

adgm.com. (n.d.). Guidance – Regulation of Virtual Asset Activities in ADGM (VER07.100625). Retrieved September 9, 2026, from https://www.adgm.com/documents/legal-framework/guidance-and-policy/fsra/guidance-virtual-asset-activities-in-adgm-20231218.pdf

dfsa.ae. (n.d.). DFSA | DFSA issues updated rules on the regulation of Crypto Tokens in the DIFC. Retrieved September 9, 2026, from https://www.dfsa.ae/news/dfsa-issues-updated-rules-regulation-crypto-tokens-difc

dfsa.ae. (n.d.). DFSA | Crypto Token Regulation. Retrieved September 9, 2026, from https://www.dfsa.ae/crypto

dfsa.ae. (n.d.). New DFSA explainer: Regulation of Crypto Tokens | DFSA. Retrieved September 9, 2026, from https://www.dfsa.ae/news/new-dfsa-explainer-regulation-crypto-tokens

Edit History

2026-04-26 — fix-grade-d-pipeline: upgraded — Auto-upgraded from D to A using primarySources sources
2026-09-09 — refresh-from-research: refreshed — Refreshed from _processed/ae-stablecoin.md (researched 2026-08-23); grade A → A

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