Three regulators can touch one post
A single Instagram reel in which a Dubai creator recommends a crypto exchange can fall under three rulebooks at once:
- VARA, Dubai's Virtual Assets Regulatory Authority, for anything marketing virtual assets in or to the UAE;
- SCA, the federal Securities and Commodities Authority, for the person making financial recommendations. Since 1 January 2026 it operates as the Capital Market Authority (CMA) under Federal Decree-Laws 32 and 33 of 2025 and took over the SCA's rules and licences (Latham & Watkins); the Finfluencer licence below is still widely called the "SCA licence";
- NMA, the National Media Authority, for advertising on social media in general.
Nobody coordinates them for you, so start with the table below.
Who regulates what
| Your situation | VARA Marketing Regulations | SCA Finfluencer licence | NMA Advertiser Permit + Art. 33 |
|---|---|---|---|
| Crypto exchange or token project advertising to UAE users | Yes, licensed by VARA or not | No (company) | Sector approval for financial ads |
| Mainland creator recommending a coin, stock, fund or trading app | Yes, if virtual assets | Yes | Yes, if paid, gifted or unpaid promotion |
| Creator in DIFC or ADGM giving financial recommendations | Yes, if virtual assets to the UAE | No, excluded; DFSA/FSRA rules instead | Yes |
| Bank or fintech app ad, no crypto | No | Only for creators making recommendations | Sector approval for financial ads |
| Journalist or educational explainer, no promotion | Exemptions may apply | Republishing approved information is exempt | No permit if no advertising |
| Foreign firm, no UAE activity, not targeting the UAE | No | No | No |
Sources: Linklaters on VARA, Hadef & Partners on SCA Resolution 10/2025, Executive Regulation Art. 33. Exemptions are narrow; check the text before relying on one.
VARA: what crypto marketing must and must not do
VARA's Marketing Regulations took effect on 1 October 2024 and replaced the 2022 administrative orders. They apply to everyone marketing virtual assets in or targeting the UAE, VARA-licensed or not, and the definition includes airdrops and educational content (Linklaters). Firms marketing to the UAE must be a VARA-licensed VASP or act for and be approved by one.
Every crypto ad must:
- be fair, clear, not misleading, and clearly identifiable as marketing;
- carry a prominent disclaimer that virtual assets may lose their value in full or in part and are subject to extreme volatility;
- state the risks clearly.
It must not:
- say or imply the investment is safe, low risk or guaranteed;
- include a call to buy or sell the asset;
- send tokens to a wallet without prior consent;
- promote anonymity-enhanced cryptocurrencies at all.
Fines run up to AED 10 million, doubled for a repeat within a year. The amounts per violation are in Schedule 1 of the regulations.
SCA: the Finfluencer licence
The SCA launched the region's first Finfluencer licence in May 2025 under Chairman Resolution No. 10 of 2025, effective 21 May 2025 (Hadef & Partners). It covers any natural person on the mainland who gives the public recommendations to buy, sell or hold financial products, virtual assets or regulated services, in the UAE or abroad, on social media, blogs, podcasts or seminars. Issuers and SCA-licensed firms that hire finfluencers are in scope too.
Key points:
- registration, renewal and legal consultation fees are waived for three years;
- applicants must meet qualification thresholds (for example a recognised analyst credential or demonstrated experience) and disclose conflicts and affiliations;
- paid partnerships must be disclosed, and promoting unlicensed platforms is off-limits (Gulf News);
- the SCA asks the public to check a finfluencer's status before acting on their content.
NMA: the layer everyone forgets
Financial ads are one of five categories in Article 33(10) of the Media Law's Executive Regulation that need the relevant authority's approval before publication. Skipping it costs AED 10,000 under Cabinet Resolution 42/2025. The creator also needs the ordinary NMA Advertiser Permit, and every post needs an ad label. See our ad disclosure guide.
A compliant crypto caption, before and after
Before: "🚀 $XYZ is about to 10x. I bought today, link in bio, don't miss it!" Breaks: implies returns, call to buy, no risk warning, no ad label.
After: "Ad · Paid partnership with @exchange (VARA-licensed). How their staking product works, in 60 seconds. Virtual assets may lose their value in full or in part and are subject to extreme volatility. Not investment advice."
The "after" version still needs the creator to hold the right licences. The caption fixes the content, not the permit.
What nobody tells you
- Education is not a loophole. VARA's definition of marketing includes articles, papers and presentations. An "educational" thread that ends with a referral link is marketing.
- "Not financial advice" doesn't switch off the SCA. If the content tells people what to buy, the disclaimer doesn't change what it is.
- The brand carries the risk too. Hadef & Partners advises firms to check registration, approve content before it goes out and keep records, because firms can be held responsible for promoting through non-compliant finfluencers.
Vladimir Chernyshev, GM: for fintech clients, the brief should start with the disclaimer and the list of banned phrases, not with the hook. Write the risk warning into the video itself, on screen, so it survives reposts and cuts.
Related: media law fines, checking an influencer's permit.
