The Dubai Virtual Assets Regulatory Authority (VARA) has issued public disclosure guidance drawing on a thematic review launched in June 2026, which identified incomplete, insufficiently specific, inaccessible or outdated disclosures among licensed virtual asset service providers (VASPs). Some providers treated disclosures as a licensing deliverable rather than a continuing compliance obligation. Disclosures must reflect each provider’s operating model and the cumulative requirements applicable to its licensed activities. Good governance practices include assigning responsibility for disclosures, maintaining a register mapping requirements to published information, and testing completeness, accuracy and accessibility. Material business changes should trigger an assessment of whether disclosures need updating. For broker dealers, generic pricing descriptions failed to explain how quoted prices were determined. Good practice explains reference price sources and how spreads, markups or other adjustments are determined, without requiring disclosure of proprietary algorithms. Some providers also failed to explain order routing or demonstrate that they had assessed liquidity source concentration. Disclosures must identify any liquidity source receiving 20% or more of routed client orders. Information about individual virtual assets was sometimes missing, limited to selected assets or difficult to locate. Good practice provides structured information for every asset offered, covering the prescribed metrics. Broad claims that client assets were protected or segregated also lacked supporting explanations. Disclosures should distinguish the arrangements for client money and client virtual assets, explaining segregation, ownership protection and relevant service providers’ roles. Third party disclosures sometimes omitted relevant providers or covered only client assets. Applicable disclosures must also cover the VASP’s proprietary accounts, funds and virtual assets maintained by third parties, identifying those parties and explaining their roles.
Dubai Virtual Assets Regulatory Authority issues public disclosure guidance after review identifies gaps at licensed providers
The Dubai Virtual Assets Regulatory Authority has published good practice guidance after a review found incomplete, generic and outdated disclosures among licensed virtual asset service providers. It emphasizes ongoing disclosure controls, clearer pricing explanations and identification of liquidity sources receiving 20% or more of routed client orders. Providers should also address gaps in information about individual assets, client asset protection and third party holdings, including their own accounts and assets.