Dubai VARA clarifies VASP reserve asset audit requirements: maintain 100% customer liability reserve coverage throughout

The Dubai Virtual Assets Regulatory Authority (VARA) has issued a circular on the audit of reserve assets, clarifying the minimum requirements for independent audits of Virtual Asset Service Providers (VASP). VASP must maintain reserves of no less than 100% of customer liabilities throughout the review period and hold the same virtual assets in a 1:1 ratio, conducting daily reconciliations.

The audit scope must cover hot wallets, warm wallets, cold wallets, third-party wallet infrastructure, and third-party custodial assets, and verify customer asset segregation, wallet control, and whether there is any re-staking, lending, or other usage scenarios.