An Existing Licence Can Be a Shorter Route Than a New One

Chairman's Resolution No. (16/Chairman) of 2026 has one operative article. It provides that entities licensed by the Central Bank — except insurance companies — may practise any of the activities stipulated in the Chairman of the Authority's Board of Directors' Resolution No. (04/Chairman) of 2026 Concerning the Regulation of Virtual Assets Service Providers and the Alternative Trading System Operator.

It was approved by the Authority's board at its ninth meeting of the ninth round on 9 June 2026 and issued in Abu Dhabi on 25 June 2026. Article 2 provides for publication in the Official Gazette and states that it is in force on the date of issuance. There is no transition period in the text, because there is nothing being transitioned — the permission simply exists from the day it was issued.

Resolution 04 of 2026 is the instrument behind the virtual-assets framework the Authority announced in April 2026: five modules covering general requirements, conduct of business, the alternative trading system, anti-money-laundering, and prudential requirements, over an activity set spanning dealing as principal and as agent, custody and arranging custody, arranging investment deals, providing investment advice, portfolio management, and operating a multilateral trading facility. The alternative trading system module is not virtual-asset-only; the Authority states that it extends to conventional multilateral trading facilities for securities and to facilities dedicated to tokenised securities. Businesses interested in these activities might consider how a trade licence works in the UAE.

Almost all commentary on entering a UAE virtual-asset activity is a comparison of applicant routes: which regulator, which entity, which zone, which sequence. Resolution 16 says something structurally different. For one class of participant, the route may not be an application at all, making how onshore and zone options differ less relevant for them.

The UAE Government portal enumerates the licence types issued by the Central Bank — banks, conventional and Islamic; finance companies; exchange business; stored value facilities; retail payment services; card schemes; large-value and retail payment systems; monetary intermediaries; open finance; insurance companies and representative offices among them. That enumeration is the Government portal's, not the Central Bank's own publication, so treat it as an index rather than as the regulator's text. What it gives you is the shape of the population Resolution 16 speaks to, and it is a large, mostly incumbent population that has already been through an authorisation process. For guidance on navigating these options, consider consulting Velarozone's advisers.

The exclusion is as informative as the permission. Insurance companies are named out. Nobody else is. A drafter who considered who was in the room and named the single class that is not has told you the permission was deliberate rather than incidental.

The operative words are that entities licensed by the Central Bank may practise. That is the whole test as drafted, and everything a group would want to know next is unaddressed.

The definitions of the activities Resolution 16 points at live in Resolution 04 of 2026, and that instrument is not among the items on the Authority's published regulations listing; the regulations search on its own site is not available to an unauthenticated reader. The activity names are public. The perimeters, carve-outs and any transition arrangements behind them are not.

That matters more than it sounds. Anyone telling you confidently that a given business model falls inside "arranging custody" rather than "arranging investment deals" is telling you something they cannot have read, because the definitions are not in public circulation. The honest position is that the activity names are known, the boundaries are not, and a specific model has to be put to the Authority rather than mapped from a press release.

There is a second hazard on the same site. The Authority still publishes its earlier guidelines, which describe a six-licence regime issued under 2021 and 2023 instruments. Both documents are live. A group that maps its plan onto the older list is mapping onto a regime that has since been replaced, and that is a surprisingly common way to arrive at a well-argued answer to the wrong question.

Resolution 16 is only useful if the Capital Market Authority is the regulator for the activity in question. The federal split is the Authority's own, stated in its guidelines: virtual assets divide into those for investment purposes and those for payment purposes, and virtual assets for payment purposes, including stored value facilities, are subject to the jurisdiction of the Central Bank. The guidelines then confine every subsequent reference to virtual assets to those for investment purposes. A token can change regulator without a line of its code changing, because what moves is the use.

The framework also does not apply to digital securities or digital commodity derivative contracts — those are treated as securities under the legislation regulating traditional securities — nor to service tokens and non-fungible tokens that do not represent investment-purpose assets, nor to software for mining or creating assets, nor to loyalty programmes.

Then the geography. The guidelines state that they apply to virtual assets used as an investment instrument in the state with the exception of the financial free zones. Ordinary commercial free zones are inside the perimeter; financial free zones are not, and the two share a word without sharing a regime. In Dubai, the Authority's own joint statement with VARA records that virtual asset service providers operating in or from Dubai require a licence from VARA and can be registered by default with the SCA to service the wider UAE, while those operating out of any other emirate must be licensed by the Authority. Consistently with that, the Authority's open-data page for virtual asset service providers publishes no register of its own; it points the reader at VARA's public register.

So Resolution 16 does its work inside the federal perimeter. It is not a passport into Dubai's regime and it does not reach the financial free zones.

The lever above concerns investment-purpose activity. The question institutional clients ask most often is the other one: a dirham-referenced payment token, and who authorises it.

What is verifiable is the negative, and it is verifiable twice. On the Capital Market Authority's own reading, payment-purpose assets sit outside its perimeter and with the Central Bank. VARA says the same thing from the other direction: the issuance of a fiat-referenced virtual asset that purports to maintain a stable value in relation to the value of the dirham shall not be approved under its issuance rulebook and remains under the sole and exclusive regulatory purview of the Central Bank, as do all activities relating to a UAE central bank digital currency.

What is not verifiable from a source we are willing to publish on is the positive: the name of the Central Bank authorisation, its reserve and redemption terms, its transition arrangements, its article numbering. The Government portal's enumeration of Central Bank licence types names no payment-token category, and absence from a portal list is not evidence about a regulator's rulebook — it is only a reason not to assert. We would rather say that plainly than restate a summary of a regulation we have not read at its own source. If a provider quotes you article numbers, ask them where they read them.

It is not which zone. It is: what does the group already hold, in which entity, and under which regulator? Resolution 16 is the reason that ordering is not merely tidy — for one population it changes what the project is.

None of the questions above is answered by a form, and several of them are not answered by any published text. The resolution grants a permission in a single sentence and leaves the architecture to be worked out against a specific group's assembly: which entity, which regulator's consent, which prudential consequence, which side of the investment and payment boundary.

If you hold a Central Bank licence and are looking at a virtual-asset activity, start with what you already have rather than with what you would have to build. Bring us the licence, the entity chart and the plan, and we will tell you whether the shorter route is open to your group and what it would cost you structurally to use it. This is structuring commentary rather than legal advice, and it is not an opinion on how any regulator will read a particular set of facts.