UAE

Blockchain projects, DAOs and Web3 foundations use it to issue tokens and fund ecosystem development; the IOTA Ecosystem DLT Foundation, registered in November 2023, was the first.

• An ownerless legal person run by a council of two to 16 members, with at least one founder and an optional guardian
• May issue utility tokens and run governance through token voting and smart contracts; a white paper, and a tokenomics paper if it issues tokens, are filed on registration
• Minimum initial assets of USD 50,000, which may be paid in fiat currency or FSRA-recognised stablecoins but in no other form
• No physical presence is required, but it must have a registered ADGM company service provider unless the Registrar exempts it
• May not carry on activities that need FSRA permission; regulated business is done through a separately licensed subsidiary

Used to preserve and manage assets and plan succession, but not to conduct commercial activities; the DLT Foundation was created in 2023 for projects that issue tokens.

• A separate legal person with no shareholders, at least one founder and a council of at least two members; a guardian becomes compulsory once the last founder has died
• Minimum initial assets of USD 100
• The names of councillors, beneficiaries and any guardian are held confidentially by the Registrar, subject to disclosure to public authorities
• A non-exempt foundation must appoint an ADGM-licensed company service provider
• Overseas foundations can migrate into ADGM

The operating company of FSRA-authorised virtual asset firms and fiat-referenced token issuers such as Laser Digital (AD) Limited and Paxos Issuance MENA Ltd.

• The Registration Authority incorporates it and issues its commercial licence only after the FSRA has given in-principle approval
• At least one shareholder, individual or corporate, and at least one director who is a natural person
• At least one authorised signatory who is a UAE or GCC national or holds a UAE residence visa
• A registered office in ADGM under a lease valid for one year from the date of the commercial licence
• A foreign company can instead register an ADGM branch, whose activities must match the parent's; AMINA Bank AG holds its virtual asset permissions through one

A passive holding company used to ring-fence assets and liabilities, for example to hold a group's subsidiaries or to issue securities.

• Formed as a private company limited by shares or a Restricted Scope Company, with a commercial licence for special purpose vehicle activities only
• Cannot conduct operational business or hire staff
• Must show a connection to the UAE or the GCC, such as regional ownership, assets in the region, or securities listed or traded in ADGM
• A non-exempt SPV must appoint an ADGM company service provider; subsidiaries of FSRA-authorised firms are exempt
• The FSRA generally expects an issuer making an offer of digital securities to be incorporated in ADGM

Most firms on VARA's register are free zone companies, with names ending in FZE, FZCO or DMCC, among them Binance FZE, OKX Middle East Fintech FZE and Payward FZCO (Kraken).

• Two licences: the free zone authority incorporates the company and issues its commercial licence, and VARA issues the VASP licence; a commercial licence alone does not permit virtual asset activity
• The applicant files an Initial Disclosure Questionnaire through the free zone, and VARA's Approval to Incorporate, which does not permit operating, comes before the VASP licence
• The DWTC Free Zone offers FZCO, FZE and branch forms, with a one-year non-operational virtual assets licence until VARA grants its licence, then an operational licence
• The DMCC Crypto Centre had more than 800 member companies at the end of 2025

VASPs that want to operate on Dubai's mainland form a company licensed by the DET; licensees with LLC names include CoinCorner Virtual Assets Broker & Dealer Services L.L.C. and Daman Virtual Asset Brokerage LLC.

• The DET issues the commercial licence and VARA the VASP licence; DET branches have accepted applications for VARA-regulated activities since May 2023
• VARA says an LLC or free zone company is preferable and does not accept applications from sole proprietorships
• Virtual asset proprietary trading is a DET commercial licence that needs a no objection certificate from VARA
• As with free zone licensees, VARA licensees can be registered by default with the CMA to serve the rest of the UAE

Firms seeking a DFSA licence for crypto token services, such as trading venues, brokers, custodians and fund managers, set up a DIFC company or register a foreign company's branch.

• The DFSA requires a body corporate or partnership, formed in the DIFC or as a branch of a foreign entity from a jurisdiction with internationally compliant standards
• The DFSA's in-principle letter, generally valid for three months, comes first; the Registrar of Companies then incorporates the company and issues its licence, and DFSA authorisation follows
• The firm must operate from a place of business in the DIFC, with its lease registered
• A foreign company can instead register its branch as a Recognised Company

The DIFC's SPV: a passive holding company used to hold shares and other assets or for financing transactions, but not to run a business.

• Open to any applicant since the updated regulations were enacted on 24 July 2026, which removed the earlier qualifying requirements
• Cannot conduct commercial or operational activities or employ staff
• Must appoint a corporate service provider as its interface with the Registrar, unless it is an Exempt Prescribed Company
• May be used in connection with financial services only in compliance with DFSA-administered legislation
• USD 100 application fee and USD 1,000 annual licence fee