Regulatory Tracker
Status of regulatory frameworks affecting tokenized assets in MENA and globally
Last reviewed 6 October 2026
VARA
ActiveVirtual Assets Regulatory Authority
Dubai, UAE
VARA is Dubai's dedicated virtual asset regulator, established in 2022. It provides licensing for virtual asset service providers, tokenization platforms, and RWA issuers operating in Dubai. VARA compliance is required for any tokenized asset offering in the Emirate.
Key Points
- •Licensing required for VASPs
- •Covers tokenized securities
- •KYC/AML mandatory
- •Stablecoin issuance framework
- •Marketing tokenized real estate in or from Dubai needs a VARA licence or approval (VARA alert, Feb 2026)
DFSA
ActiveDubai Financial Services Authority
DIFC, Dubai
The DFSA regulates financial services in the Dubai International Financial Centre (DIFC), an independent financial free zone. It oversees investment funds, securities, banking, and increasingly digital assets and tokenized securities within DIFC.
Key Points
- •DIFC jurisdiction
- •Securities tokenization framework
- •Fund tokenization rules
- •Crypto token regime
SEC
EvolvingSecurities and Exchange Commission
United States
The SEC regulates securities in the US, including tokenized securities. Most major institutional RWA products (BlackRock BUIDL, Ondo USDY, Franklin BENJI) are registered or exempt under SEC rules. The SEC's stance on crypto-native RWA remains in flux.
Key Points
- •Reg D / Reg S exemptions common
- •Accredited investor requirements
- •Howey test for token classification
- •ETP approval expanding
MiCA
LiveMarkets in Crypto-Assets Regulation
European Union
MiCA is the EU's comprehensive crypto regulation framework, fully in force since December 2024. It establishes rules for crypto-asset issuers and service providers across all EU member states, providing regulatory clarity for tokenized assets operating in Europe.
Key Points
- •Unified EU framework
- •CASP licensing
- •Stablecoin (EMT/ART) rules
- •Passporting across EU
FCA
Coming 2027Financial Conduct Authority — UK cryptoasset regime
United Kingdom
The UK is replacing its light-touch crypto oversight with a full regime. Under the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, operating a trading platform, dealing, arranging, safeguarding, staking and issuing stablecoins become regulated activities from 25 October 2027, including for overseas firms serving UK consumers. Until then the FCA's reach is financial promotions and anti-money-laundering registration. Firms that want transitional arrangements must apply between 30 September 2026 and 28 February 2027; existing registrations do not convert automatically (FCA PS26/18).
Key Points
- •New regime in force 25 October 2027
- •Application window 30 Sep 2026 – 28 Feb 2027
- •Covers overseas firms serving UK consumers
- •Crypto financial promotion rules already apply today
- •Perimeter guidance: PERG 18 (PS26/18)
This information is for informational purposes only. Consult a licensed legal advisor before making any investment decisions.