UAE Trends and Developments Contributed by: Irina Heaver and Zainab Kamran, NeosLegal
The pilot phase, which ran from May 2025 to February 2026, attracted investors from more than 50 nationali- ties and channelled over AED18.5 million in tokenised property investments, with one property fully funded in under two minutes. On 20 February 2026, the DLD activated Phase 2 of the project, moving the initiative beyond the pilot stage by introducing a regulated 24/7 secondary market within the Prypco Mint App. The DLD has stated that tokenised assets are pro- jected to represent up to 7% of Dubai’s real estate market by 2033, equivalent to approximately AED60 billion (USD16 billion). With Phase 2 now operational, that target is increasingly viewed as a credible trajec- tory rather than an aspirational projection. VARA ’ s framework for RWA tokenisation : ARVAs and the 2026 Guidance The DLD tokenisation project was made possible by VARA’s introduction in May 2025 of a new category of regulated virtual assets, Asset-Referenced Virtual Assets (ARVAs), commonly known as RWA tokens, through an amendment to its Virtual Assets Issuance Rulebook. An ARVA is a digital token whose value is directly linked to one or more real-world assets or their income streams. By holding an ARVA, investors gain a digital claim to tangible or intangible assets such as real estate, commodities, private credit or intellec- tual property. To issue ARVAs, companies must first secure a Category 1 VASP licence from VARA and adhere to all relevant regulatory requirements. Ctrl Alt, a Dubai-based blockchain infrastructure developer, became the first to receive a VARA licence for VA Issu- ance services and contributed to the DLD initiative by developing the framework for minting real estate tokens on-chain. On 9 April 2026, VARA published its Guidance on Vir- tual Asset Issuance, a non-binding companion docu- ment to the May 2025 Rulebook that nonetheless carries significant practical weight during licensing review. The Guidance interprets the existing Rulebook rather than introducing new legislation, but introduces several developments of material commercial signifi- cance for RWA issuers. Most importantly, VARA con- firmed that direct-ownership ARVAs, where ownership of the underlying asset transfers with the token, do not require Reserve Assets, with the full reserve regime
applying only to stable-value ARVAs that maintain a peg or fixed price relative to a reference asset. For tokenised real estate, commodity and art products structured on a direct-ownership basis, this distinc- tion removes an entire compliance workstream. The Guidance also introduces a mandatory five-part legal opinion framework for ARVA issuers, covering author- ship and qualification, independence and objectiv- ity, scope, assumptions and limitations, and ongo- ing validity, with a requirement for the opinion to be updated whenever the token structure or applicable law changes materially. Equally significant is VARA’s first explicit acknowl- edgement that tokenised real-world assets qualify- ing as financial instruments may also fall within the regulatory perimeter of the UAE CMA, creating a potential dual-regulation scenario for tokenised secu- rities, sukuk, fund units and similar instruments. The Guidance further refines requirements relating to risk disclosures, white paper accessibility, governance disclosure for Category 1 issuers, and the eligibility of broker-dealer licence holders to issue Category 2 tokens without obtaining a separate issuance licence. Together, the DLD secondary market rollout and the April 2026 Guidance mark a shift from regulatory framework alone to a maturing operational ecosys- tem in which tokenised property trades on a regulated secondary market under a clarified and increasingly sophisticated set of issuance rules. Sovereign Bitcoin : mining and allocation at state scale Beyond regulation, the UAE has quietly emerged as one of the most significant sovereign-adjacent partici- pants in the Bitcoin ecosystem, combining industrial- scale mining with direct institutional allocation. On the production side, Citadel Mining, ultimately controlled by International Holding Company (IHC) through its subsidiary 2pointzero, operates an 80,000 square metre Bitcoin mining facility on Al Reem Island in Abu Dhabi, developed in partnership with the pub- licly listed Phoenix Group. According to on-chain anal- ysis published by Arkham Intelligence, the facility has produced approximately 9,300 BTC since 2022, with
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