Legal Insights
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As the UAE continues to establish itself as a global hub for cryptocurrency and Virtual Assets, social media influencers must adapt to navigating a highly regulated environment. The Virtual Assets Regulatory Authority and other UAE regulatory bodies enforce strict consumer protection, transparency, and ethical marketing requirements to maintain market integrity.
Failure to comply with these regulations can result in severe penalties, including fines, legal action and bans from promotional activities. Given these high stakes, influencers must fully understand and adhere to UAE regulations to operate legally and preserve their credibility in the evolving Crypto & Web3 ecosystem.
Crypto-Specific Content Regulations for Influencers
VARA Marketing Regulations
Dubai’s Virtual Assets Regulatory Authority (VARA) issued Marketing Regulations* to ensure that virtual asset promotions are conducted ethically and transparently. The Marketing Regulations apply to all marketing activities related to Virtual Assets or VA Activities within or targeting the UAE. These regulations cover both domestic and foreign entities, regardless of whether they are licensed by VARA. The Marketing Regulations are supplemented by a Guidance that provides practical applications of these rules.
(* The Regulations on the Marketing of Virtual Assets and Related Activities 2024)
What is considered Marketing?
VARA defines marketing broadly, covering any promotional activity related to Virtual Assets, including:
- Advertisements, invitations, and promotional offers
- Social media campaigns, influencer endorsements, and paid sponsorships
- Traditional and digital media promotions, such as banners, billboards, video content, and podcasts
- Events that encourage client engagement with Virtual Asset platforms
Furthermore, the regulations completely prohibit the marketing of privacy tokens, as well as any services related to these assets.
Who Can Market What?
Under VARA’s regulations, only licensed Virtual Asset Service Providers (VASPs) and their authorized representatives may market regulated Virtual Asset activities (e.g., exchange, broker-dealer, and asset management services). If a VASP is not licensed in the UAE, it cannot market in the UAE, and no UAE-based entity or individual (including marketing agencies and Key Opinion Leaders (KOLs)) may promote it.
This restriction applies only to regulated activities and does not extend to marketing of the Virtual Assets themselves. KOLs may promote Virtual Assets listed on UAE-licensed exchanges (e.g., Binance AE) as long as they adhere to VARA’s Marketing Regulations.
For companies operating outside the UAE, these regulations apply only if their marketing specifically targets UAE-based audiences. Marketing is deemed to be “in or targeting the UAE” if it includes:
- UAE-specific imagery or branding
- References to AED currency
- Local dialects or cultural elements
- Influencers with a substantial UAE-based following
- Advertisements placed in UAE media, newspapers, or public spaces
Even if a campaign is geo-blocked, it remains subject to UAE laws if it can reasonably be accessed by UAE residents.
Marketing Requirements
VARA enforces strict transparency, fairness, and accountability in Virtual Asset marketing. Influencers must avoid misleading claims such as “risk-free investments” or “guaranteed profits” and refrain from employing urgency tactics like “Limited time offer” or “Buy now before prices rise.” Past performance must not be portrayed as indicative of future success, and product or service comparisons must be factual and balanced.
All marketing content must prominently display clear and visible risk disclaimers across all formats. In video content, disclaimers should remain on-screen long enough to be read, while social media disclaimers must be clearly legible and not obscured by formatting tricks or hashtags.
Marketing platforms, including social media networks, search engines, and media outlets, must ensure that marketing content complies with UAE laws.
Marketing of Virtual Assets: What is Allowed?
Influencers can share educational and informational content about Virtual Assets, explaining their functionality, technology, and general market trends. Such content must be presented in a neutral, fact-based manner, without urging followers to buy, sell, or invest.
Influencers are allowed to publish reviews, analysis, and market insights about Virtual Assets, provided they include prominent disclaimers stating that Virtual Assets can be volatile, may lose value, and do not offer financial protection. Sponsored content and collaborations with Virtual Asset projects or platforms are permitted, but must be clearly disclosed as paid promotions, ensuring transparency for the audience. Additionally, influencers may engage in discussions, interviews, and live streams to provide insights on industry developments, regulatory updates, and technological advancements related to Virtual Assets.
Influencers should avoid directing their audience to purchase specific Virtual Assets but may provide neutral comparisons, factual overviews, and discussions about the broader digital asset ecosystem. Any promotional campaigns that include incentives, such as giveaways or airdrops, must obtain VARA’s approval and ensure that recipients explicitly consent to receiving Virtual Assets.
Compliance
Influencers must maintain detailed records of their marketing activities for a minimum of two years, including promotional content, audience demographics, and engagement data. VARA may audit these records at any time to ensure compliance.
Importantly, influencers are not eligible for exemptions that apply to journalistic, educational, or private communications. Therefore, they must comply with VARA’s regulations and may only promote virtual asset activities if officially appointed by a UAE-licensed VASP.
Non-compliance with VARA’s marketing regulations may result in:
- Fines ranging from AED 500,000 to AED 10,000,000
- Temporary or permanent suspension of marketing activities
- Significant reputational damage, which may impact future opportunities in the crypto and media industries.
The UAE’s regulatory authorities rigorously enforce compliance, and breaches can have long-lasting professional consequences for influencers.
Practical Tip:
To remain compliant with VARA’s regulations, businesses and influencers should:
- Thoroughly review marketing materials to ensure they align with VARA’s transparency and disclosure guidelines.
- Incorporate risk disclaimers prominently in all promotional content.
- Maintain detailed records of marketing activities and partnerships.
Other Regulations
The UAE Central Bank (UAECB) has issued the UAE Payment Token Services Regulations, which govern Payment Tokens, defined as Virtual Assets designed to maintain a stable value (i.e., stablecoins). Under these regulations, individuals and entities are prohibited from promoting Payment Token Services, including the issuance, custody, transfer, and conversion of Payment Tokens, unless they have obtained the necessary license or registration from the UAECB or have been appointed by a licensed party to act on their behalf.
These restrictions also extend to Means of Payment, which has a broader definition than Payment Tokens. It includes any Virtual Asset that functions as a store of value or a medium of exchange. As a result, promotions related to Means of Payment are only permitted if they involve:
- Dirham Payment Tokens issued by Licensed Payment Token Issuers, or
- Foreign Payment Tokens issued by Registered Foreign Payment Token Issuers, which are lawfully used in Virtual Asset transactions.
Any other form of promotion related to Means of Payment is strictly prohibited, including by entities otherwise licensed to engage in Virtual Asset activities (e.g., licensed VASPs).
Additionally, the regulations entirely prohibit the promotion of Algorithmic Stablecoins and Privacy Tokens, along with any related services. This restriction applies universally, including to entities already licensed for other Virtual Asset activities by the Securities and Commodities Authority (SCA) or any Local Licensing Authority (e.g. VARA).
The UAE Central Bank may require proof of compliance from any individual or entity at any time, including one-time evidence submissions or regular reporting obligations, based on regulatory requirements. Failure to comply may result in substantial administrative and financial penalties, with the severity based on the nature and extent of the violation.
Notably, these promotional restrictions do not apply within the financial free zones of Dubai International Financial Center (DIFC) and Abu Dhabi Global Markets (ADGM).
General Media Content Rules
Influencers in the UAE must adhere to Federal Media Law**, which establishes strict content guidelines for media activities. Key provisions include:
- Religious & Cultural Sensitivity – Content must not disrespect Islamic beliefs, other religions, or UAE traditions.
- Political Content Restrictions – Any material that could harm UAE foreign relations or governance is strictly prohibited.
- Public Morality Standards – Content must not incite violence, disrupt public order, or conflict with societal values.
- False or Misleading Information – Spreading fake news, rumors, or deceptive claims is punishable by law.
- Privacy Protections – Influencers must respect personal privacy and avoid defamatory content.
(** Article 17 of Federal Decree-Law No. 55 of 2023 on Media Regulation)
Consequence of Violating Content Standards
Violations of UAE media laws may lead to severe penalties, including fines, imprisonment, or temporary bans from social media.
For instance, an influencer who uploaded a video of himself impersonating an Emirati citizen while visiting a showroom was fined AED 300,000 and sentenced to six months in jail. In another case, an influencer posted a video of himself driving a car at dangerously high speeds, resulting in a fine of AED 100,000 and a three-month jail sentence.
These examples underscore the serious consequences of breaching the UAE’s media content regulations, which are strictly enforced to maintain public order and respect for cultural and legal standards.
Licensing Requirements for Crypto Influencers in the UAE
Valid Trade License or Freelance Permit
Influencers operating in the UAE are required to obtain a valid trade license or a freelance permit to legally conduct their business activities.
This license can be acquired by setting up a company in a Free Zone or by registering with the relevant economic department, such as the Department of Economic Development (DED) in Dubai or the Abu Dhabi Department of Economic Development (ADDED) in Abu Dhabi.
For those in Abu Dhabi, ADDED offers a freelancer license through its online portal, TAMM. The trade license or freelance permit ensures that influencers comply with the UAE’s regulations and are authorized to offer their services, whether as part of a company or as independent freelancers.
NMC Permit
Influencers in the UAE must secure a permit from the National Media Council (NMC) to legally advertise on social media platforms. This requirement is mandated by Federal Law***, which stipulates that individuals engaging in media activities for commercial purposes must obtain the appropriate license.
Obtaining this permit is crucial for compliance with UAE regulations, as failure to do so can result in fines.
(***Article 13 of Chairman Of The Board Resolution No. (3) Of 2018 On Organizing E-Media Activities)
Tax Obligations
Influencers in the UAE are subject to specific tax obligations, including Value Added Tax (VAT) and Corporate Tax (CT), which must be meticulously managed to ensure compliance with local regulations.
- Corporate Tax: Starting from June 1, 2023, all businesses and individuals carrying out a business activity in the UAE are also required to register for Corporate Tax (CT) with the Federal Tax Authority ( FTA) (irrespective if they are established in a Free Zone or not). If their annual income exceeds AED 375,000, they are subject to a 9% corporate tax on profits and capital gains above this threshold.
Regardless of whether their income exceeds this threshold, businesses must file annual corporate tax returns to declare their earnings and any applicable tax liabilities. Failure to comply can result in significant penalties, including fines and legal consequences. - VAT: Businesses earning over AED 375,000 annually must register for VAT with the FTA and charge 5% VAT on all taxable income, including payments in cash or kind.
In addition to charging VAT, influencers are obligated to file VAT returns a quarterly basis. Timely and accurate filing is crucial to avoid penalties.
Why Influencers Must Be Extra Vigilant
Successfully navigating the UAE’s regulatory landscape as a crypto influencer demands diligence, transparency, and adherence to legal and ethical standards. Non-compliance can lead to severe and lasting consequences, including hefty fines, legal action, and reputational damage. Beyond legal risks, failing to follow regulations can undermine audience trust, a critical factor for long-term success in the digital space.
By staying informed, securing the necessary licenses, maintaining proper documentation, and ensuring that all promotional activities align with UAE regulations, influencers can protect themselves while building a credible and sustainable presence in the industry. A proactive approach to compliance not only safeguards your career but also enhances your professional reputation in an evolving and highly scrutinized market.
Whether you’re a crypto KOL, marketing agency or project founder, staying compliant is non-negotiable.
We’re here to help you protect your reputation and grow with confidence.
