Dubai VARA sets minimum reserve audit requirements for VASPs

Dubai’s Virtual Assets Regulatory Authority, or VARA, has issued a circular on reserve asset audits that sets out the minimum requirements for independent audits of virtual asset service providers, known as VASPs. Under the notice, a VASP must maintain reserves equal to at least 100% of customer liabilities throughout the full review period. Those reserves must be held in the same virtual assets on a 1:1 basis, with reconciliations carried out on a daily basis. The required audit scope also extends across hot, warm and cold wallets, third-party wallet infrastructure, and assets held with third-party custodians. In addition, the audit must verify whether customer assets are properly segregated, whether wallet control remains in place, and whether any assets have been used for restaking, lending, or other purposes. The circular lays out a baseline for how reserve-backed customer assets should be reviewed under VARA’s framework.