A business operating in Dubai may need more than one Virtual Asset activity to deliver its model. VARA allows a Virtual Asset Service Provider to apply for multiple activities under a single overarching licence, subject to approval.
That flexibility does not remove the requirements attached to each activity. It also does not mean that every activity can always sit within the same legal entity. Custody Services are treated differently and generally require a separate legal entity with a standalone licence.
There is one narrow exception: a custodian may apply to provide VA Transfer and Settlement Services through the same entity. The exception is not automatic and depends on VARA being satisfied that all relevant requirements, including strict operational segregation, are met.
Can one VARA licence cover several activities?
Yes. VARA identifies eight regulated Virtual Asset activities and states that a VASP can apply to combine multiple activities under one overarching licence. The firm must obtain VARA approval for every activity before it begins providing that service in or from Dubai.
The practical question is therefore not only which label best describes the business. The applicant must map each function in its operating model to the relevant activity and ensure that the requested licence scope covers the services it will actually perform.
A combined application can simplify the licensing architecture for a multi-service business. It does not create a general permission to add services later without approval, and it does not override activity-specific structural rules.
What happens to the rules when activities are combined?
A VASP licensed for more than one activity must meet the requirements for each activity in full and maintain compliance at all times. Combining activities does not dilute, merge or replace those obligations.
This cumulative approach matters for planning. A business should not assess capital, governance, systems, staffing and compliance requirements in isolation for each activity and assume that the highest single requirement will necessarily be enough. The combined model should be tested against the full set of applicable obligations.
Why is Custody Services treated differently?
Custody Services are the principal structural exception to the ability to aggregate activities. VARA states that a VA Custodian must be established as a distinct legal entity with a standalone licence.
Rule III.B.5 of the Custody Services Rulebook requires a VASP providing Custody Services to be a separate legal entity from any member of its group that provides services relating to other VA activities. A custody department within a company carrying on other regulated activities is therefore not enough to satisfy the legal-entity separation requirement.
For a group that intends to combine trading, brokerage, management or other services with custody, this affects the structure from the outset. The group may need separate regulated entities, distinct permissions and an operating model that preserves the required separation while still allowing the wider business to function coherently.
What is the Transfer and Settlement exception?
Rule III.B.6 creates a limited exception to the separate-entity rule. A VASP providing Custody Services may apply to VARA for a licence to provide VA Transfer and Settlement Services through the same entity.
VARA may grant that permission only if it is satisfied that all relevant requirements are met. The rule specifically requires policies and procedures that achieve necessary segregation between the custody operation and the transfer and settlement operation.
The exception should be read narrowly. It permits an application; it does not guarantee approval. It relates specifically to VA Transfer and Settlement Services and should not be treated as a general route for combining custody with any other regulated Virtual Asset activity in the same entity.
What operational segregation is required?
The legal-entity analysis is only part of the structure. Rule III.B.7 requires sufficient operational and physical segregation between individuals handling Custody Services and those involved in other core businesses and operations, including other Virtual Asset activities conducted by the group.
The rule also requires a separate team dedicated to Custody Services. Those individuals must not have conflicting duties or access to information that may create conflicts of interest.
Where a custodian also seeks permission for Transfer and Settlement Services, the business should be able to show how responsibilities, access rights, systems, information flows and escalation procedures preserve the required separation. The evidence should match the actual operating model rather than exist only in policy documents.
What should be decided before a VARA application?
Map the activities
Identify each service, the party performing it and the relevant VARA activity. Include supporting functions that may become regulated when delivered to clients or other group entities.
Design the legal-entity structure
Decide which activities can be placed under one licence and whether Custody Services require a separate entity. If the custody entity is also intended to provide Transfer and Settlement Services, record why the limited exception is relevant.
Build a cumulative requirements matrix
List the general and activity-specific obligations that apply to each entity. Use the matrix to identify overlapping requirements, additional controls and dependencies between permissions.
Document segregation
Set out the custody team, reporting lines, access controls, system permissions, premises arrangements, conflicts controls and information barriers. Confirm that the documented model can be implemented in practice.
Sequence the application and launch
Plan which entities and activities must be approved before the service can launch. A combined commercial proposition should not assume that every permission will be granted at the same time or on the same conditions.
Key takeaway
VARA permits a VASP to apply for several activities under one overarching licence, but every activity remains subject to approval and its full requirements.
- Custody Services generally require a separate legal entity and standalone licence.
- The only express exception considered here allows a custodian to apply for VA Transfer and Settlement Services in the same entity, subject to VARA approval and strict segregation.
Frequently asked questions
Can a VARA licence include more than one activity?
Yes. A VASP may apply for multiple activities under one overarching licence, but VARA must approve each activity before it is carried out.
Does one licence always mean one legal entity?
No. Custody Services generally require a distinct legal entity with a standalone licence, even where the wider group provides other Virtual Asset services.
Can a VARA custodian also provide Transfer and Settlement Services?
A custodian may apply to provide VA Transfer and Settlement Services through the same entity under the limited exception in Rule III.B.6. Approval is subject to VARA being satisfied that all relevant requirements are met.
Is the custody exception automatic?
No. It is an application route, not an automatic permission. VARA must approve the additional activity and the custodian must implement strict segregation between the two operations.
Do combined activities reduce compliance obligations?
No. The applicable activity-specific rulebooks operate cumulatively unless VARA states otherwise, and the VASP must meet the requirements for every licensed activity in full.
Is a separate custody department sufficient?
No. VARA requires the custodian to be a separate legal entity from group members providing services relating to other Virtual Asset activities, subject only to the limited Transfer and Settlement exception.
Official sources
Virtual Assets Regulatory Authority (VARA)
VARA Rulebooks
- Custody Services Rulebook — Introduction.
- Custody Services Rulebook — III.B Segregation and Control.
Planning a VARA licence and operating structure
BLegal advises businesses on VARA activity classification, regulatory perimeter analysis, entity and licensing structures, and the preparation of licence applications and supporting compliance frameworks.
If your model combines several Virtual Asset services or includes custody, we can help you assess the structure before you commit to entities, systems and operating arrangements.
Last reviewed: 18 September 2026
Disclaimer. This article is provided for general information only and does not constitute legal or regulatory advice. The applicable framework depends on the specific token, activities, entity structure and jurisdictions involved. Regulatory requirements and interpretations may change. Businesses should obtain advice based on their particular circumstances before making structuring, licensing or commercial decisions.