Dubai’s Virtual Assets Regulatory Authority has hit a round number that matters. VARA has now issued its 50th license to a virtual asset service provider, a milestone that would have seemed wildly ambitious when the regulator was established just four years ago.

But here’s the thing. Licensing and actually operating are two different things. Only 39 VASPs were fully operational at the end of 2025, which means a meaningful chunk of licensed firms are still in the process of transitioning from approved-on-paper to open-for-business.

The gap between licensed and operational

VARA maintains a distinction that not every crypto regulator bothers with. It separates fully active licenses, which permit a firm to conduct…