- Dubai’s VARA has clarified that token launches fall into three issuance buckets, with different licensing and distribution requirements attached to each.
- Stablecoins and asset-referenced tokens sit in the most tightly controlled category, while some other tokens can be issued through licensed distributors or qualify as exempt.
Dubai has tightened the practical rulebook around token launches, giving stablecoin issuers, RWA projects and other virtual asset teams a clearer sense of which path they actually need to follow.
The guidance does not create a new law. Instead, it interprets VARA’s existing Virtual Asset Issuance Rulebook, which has been in its current version since June 19, 2025, and breaks token issuance into three categories with different prior requirements.
Three buckets, but not one-size-fits-all treatment
Under the framework, Category 1 covers fiat-referenced virtual assets, asset-referenced virtual assets and any other token types VARA may designate over time. Those issuances require a VARA licence, and the rulebook makes clear that stablecoin-style and RWA-style tokens fall into this higher-supervision tier.
Category 2 applies to tokens that are neither Category 1 nor exempt. These do not require prior approval from VARA, but all placement and distribution must be handled by a licensed distributor. VARA also assigns that distributor responsibility for validating that the issuer complies with the issuance rulebook.
Then there are Exempt VAs, which include non-transferable tokens and redeemable closed-loop assets. These can be issued without prior approval, though issuers still remain subject to VARA supervision and enforcement.
Stablecoins and RWAs face heavier disclosure and governance expectations
What stands out is that VARA is not treating all tokens as if they carry the same risks. Its annexes for fiat-referenced and asset-referenced virtual assets build in extra layers around disclosures, reserve assets, redemptions, audits, reporting, marketing and capital requirements.
That gives Dubai a more segmented issuance regime. The message is fairly plain. If a token looks like money or references real-world assets, the disclosure and governance bar rises with it.
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