VARA Company Rulebook - Part IV Outsourcing
VARA Company Rulebook, Part IV - Outsourcing Management
Notes
Version date is taken from the PDF filename. CMA's new federal remit over virtual assets (from 2026) may affect VARA's scope; not analysed.
Regulator page
Who it applies to: Virtual asset service providers licensed in Dubai, including its free zones other than the DIFC.
VARA Company Rulebook, Part IV - Outsourcing Management
Version date is taken from the PDF filename. CMA's new federal remit over virtual assets (from 2026) may affect VARA's scope; not analysed.
VARA Technology and Information Rulebook
Third-party technology controls elsewhere in the T&I Rulebook were not reviewed. The Compliance and Risk Management Rulebook may add further duties.
Mapped from our source-by-source research, checked on 3 November 2026. High-confidence items were checked on an official page; Secondary source means law-firm or other secondary sources only; To be confirmed means reported but not verified.
The VASP stays fully accountable. Outsourcing that would materially impair internal controls or VARA oversight is prohibited. The MLRO, CISO and DPO roles may be outsourced, but VARA can require in-house staff.
Risk-assess each arrangement, including materiality. Due diligence covers capacity, financial soundness, reputation, regulatory status, reliance on subcontractors and virtual-asset expertise.
Notify VARA before any cross-border outsourcing, and promptly if an overseas authority seeks access to VASP information.
Notify VARA in advance of any new or materially changed Material Outsourcing. VARA may object, and its concerns must be resolved first.
Written contracts with mandatory terms. Material outsourcing adds service levels, contingency testing, regulator cooperation, exit assistance, insurance, and specified data and processing locations. Client data is returned or destroyed on exit.
For material outsourcing, the VASP, VARA and appointed bodies get full access to premises, systems, data and staff. Pooled audits and certifications cannot replace the VASP's own audit right.
Sub-outsourcing terms are required. The provider notifies planned changes, and the VASP may object or terminate.
Keep an Outsourcing Policy and a register with provider, scope, location, dates, contacts, materiality, and whether personal or confidential data is involved.
Give VARA access to compliance information within the timelines VARA sets.
Notify VARA of a material breach of a Material Outsourcing agreement, or a development that could significantly affect operations, finances or reputation.
Report a material cybersecurity event, or an event that triggers the BCDR plan and materially affects operations, with its nature, scope, impact and mitigation, and whether other authorities were told.
After notifying a data regulator or data subjects of a personal-data incident, notify VARA and give a summary (or a copy, if the regulator is in the UAE).
Mapped from the built-in summary. Each line shows whether the feature is live in the product today.
This is a summary for orientation, not legal advice. Always rely on the official text, and take advice on your own situation. For federal legislation, the Arabic text prevails.