Aspect Dubai’s Law No. (4) of 2022 EU’s MiCA Regulation
Scope and Applies to all zones in Dubai, Applies to all EU member states.
Applicability excluding DIFC.
Jurisdiction Regulates virtual assets Regulates crypto-assets within
within Dubai. the EU.
Regulatory Virtual Asset Regulatory National regulators with EU
Authority Authority (VARA) guidelines.
Asset Categories Broad coverage of virtual Categories: Utility Tokens, Asset-
asset services (e.g., Referenced Tokens (ARTs), E-
exchanges, token trading). Money Tokens (EMTs).
Businesses Advisory Services Custodial Wallets
Regulated Broker-Dealer Exchanges for Crypto-to-
Services Crypto Transactions or
Custody Services Crypto-to-Fiat
Transactions
Exchange Services   EMT or ART Issuers
Lending & Borrowing   Crypto-Trading Platforms
Services
Management &   Crypto-Asset Advising
Firms
Investment Services
Transfer & Settlement Crypto-Portfolio Managers.
Services
Other Virtual Asset
Activities.
Regulation of Virtual Asset Service Crypto-Asset Service Providers
Service Providers Providers (VASPs) must (CASPs) must comply with MiCA
obtain VARA permits. requirements.
Licensing Businesses with over USD CASPs must register and meet
Requirements 250 million in 30 days must strict transparency and
register with VARA. operational standards.

 

Market Approach Focuses on fostering Emphasizes consumer
innovation, attracting protection, market integrity, and
businesses, and market transparency.
integrity.
Consumer VARA ensures market MiCA includes strict consumer
Protection integrity and investor protection measures to prevent
protection. market manipulation and insider
trading.
Innovation vs. Heavy focus on attracting Balances innovation with
Protection Focus innovation and investment. stringent consumer protection
and market stability.
Market Localized framework for Aims to harmonize the crypto-
Harmonization Dubai’s jurisdiction. asset market across the EU.
Detailed Broader regulation, covering Detailed guidelines for different
Regulations for various virtual asset crypto-assets and services.
Assets services.
Global Facilitates global Aims to create a unified
Cooperation cooperation through VARA. regulatory environment across
the EU.