MiCA vs VARA vs MAS: key differences in crypto rules

LegalBison published a study in May 2026 comparing the EU Markets in Crypto-Assets regulation (MiCA), Dubai’s Virtual Assets Regulatory Authority (VARA) framework and Singapore’s licensing under the Monetary Authority of Singapore (MAS). The report details differences in what activities require authorization, how licenses can be used across borders, capital and liquidity requirements, and rules for retail customers.

MiCA creates a single Crypto-Asset Service Provider (CASP) authorization that covers ten service types, including custody, trading, portfolio management and advice. A CASP authorized in one EU member state can notify its home regulator and operate across the 27 EU countries and three EEA states. MiCA sets minimum capital tiers of EUR 50,000, EUR 125,000 and EUR 150,000 by class and requires firms to hold the higher of the applicable minimum or one quarter of prior-year fixed overheads. The study notes the MiCA transitional period for CASPs ends July 1, 2026.

VARA issues activity-specific licenses with separate rulebooks and capital thresholds for custody, exchange, brokerage and advisory services. Capital requirements under VARA are expressed in UAE dirhams and can be higher than MiCA’s minimums. VARA also requires firms to meet a Net Liquid Assets test, maintaining current liquid assets at least 1.2 times monthly operating expenses, reconciled daily and reported monthly, and to hold insurance for hot-wallet exposures.

Singapore’s framework splits oversight between the Payment Services Act for payment-related tokens and the Financial Services and Markets Act for Digital Token Service Providers (DTSPs). MAS applies DTSP rules mainly to firms with a Singapore nexus or those operating from Singapore. The DTSP base capital requirement is SGD 250,000 and MAS guidance states that firms should hold a buffer that realistically covers six to 12 months of operating expenses; MAS treats this as an entry threshold rather than a deposit-insurance style prudential buffer.

Passporting differs across the three regimes. MiCA’s CASP license allows cross-border passporting across the EU and EEA. VARA licenses apply to activity conducted in or targeting Dubai and do not provide automatic recognition in other jurisdictions. MAS does not offer cross-border passporting under the DTSP regime and limits its scope to Singapore-connected activities while restricting what licensed and unlicensed firms may offer to Singapore residents.

Consumer protection rules vary. MiCA imposes conduct obligations typical of financial services, including suitability checks for advice and portfolio management, best execution duties and specific disclosure and withdrawal rights for certain token offers; retail buyers of tokens other than asset-referenced tokens and e-money tokens may have a 14-day withdrawal right, while holders of ARTs and EMTs have a permanent redemption right against the issuer. VARA requires investor classification into Retail, Qualified and Institutional segments, sets client-agreement and complaints-handling requirements, and issued marketing guidance covering social media and influencer activity. MAS maintains a restrictive approach to retail participation, limits advertising of digital payment token services in public spaces and sets high entry standards for DTSP licensing.

Operational requirements also differ. MiCA requires a place of effective management in the EU and at least one EU-resident director, along with governance, business continuity and AML obligations aligned to EU rules. VARA requires a Dubai legal entity, clear ownership and approval for material structural changes, a chief information security officer, a specified technology governance framework and that paid-up capital be secured in UAE trust accounts or via approved surety bonds. Singapore requires a permanent place of business or registered office, a local representative present for defined periods each month, penetration testing and independent technology audits before licence grant, and MAS interviews with key management during assessment.

The study highlights that firms seeking licenses in multiple jurisdictions must meet different tests of substance, financial buffers and conduct standards at the same time. LegalBison framed its findings as informational and not legal advice.