Licensing Guides
The rules for Binance P2P merchants serving UAE users in AED changed on 21 September 2026. Standard and non-P2Pro merchants can no longer advertise AED trades to UAE users; approved corporate P2Pro merchants now serve this market.
For existing merchants, continuing to offer AED trades to UAE customers now depends on meeting the corporate, licensing and onboarding requirements for P2Pro approval. Binance lists an applicable proprietary trading license, a VARA NOC, completed corporate verification and a corporate bank account among those requirements.
The challenge is determining how those requirements apply to your existing business. A merchant may already have a UAE company, trade with its own capital and hold a commercial license—but still need to establish whether its permissions cover the way orders are initiated and settled.
This guide explains the requirements, the distinction between proprietary trading and regulated services, and the decisions to resolve before changing your setup or submitting a P2Pro application.
Binance’s published requirements establish a corporate route for merchants:
| Requirement | Published requirement |
|---|---|
| Legal entity | An eligible UAE company |
| Commercial license | An applicable proprietary trading license, such as DMCC or equivalent |
| Regulatory documentation | A valid VARA NOC for the applicable P2Pro activity |
| Platform onboarding | Completed KYB and an eligible corporate account |
| Banking | A valid corporate bank account |
| Additional requirements | Permissions applicable to the merchant's activities and trading volume |
Individual and non-corporate users are not eligible to apply for P2Pro status.
For an existing merchant business, these requirements are connected. The company applying, the activity described in its licensing documents, the verified platform account and the settlement arrangements should present a consistent picture of the operation.
The practical starting point is to identify which parts of the current setup remain suitable and which need to change.
The first decision is whether the proposed licensing route fits the business you intend to continue.
VARA’s official FAQ distinguishes trading own funds without clients from buying or selling Virtual Assets with a third party at that third party’s initiation. It excludes the latter from its description of proprietary trading.
For an advertisement-led P2P operation, that distinction deserves attention before an application is prepared. Using your own capital does not, by itself, settle the activity classification.
Start with a completed trade and establish:
Then compare that transaction model with the proposed permissions.
This makes the licensing discussion specific. The question becomes: what permissions does the actual P2P operation require?
The answer should guide the commercial activity, regulatory documentation and platform application.
Three separate decisions need to be resolved:
| Decision | What needs to be established | What should not be assumed |
|---|---|---|
| Commercial licensing | Whether the company's licensed activity matches the proposed business | That the activity name alone resolves the regulatory position |
| Regulatory scope | Whether the applicable documentation covers the actual activities | That an NOC provides unrestricted permission for additional services |
| Platform approval | Whether Binance has accepted the company for the intended merchant operation | That obtaining documents guarantees acceptance |
VARA distinguishes the proprietary trading NOC route from a VASP license. Its framework provides separate permissions for regulated activities, including Broker-Dealer and Exchange Services.
The distinction matters when planning a merchant business. Each document should be read for what it permits, rather than treated as a general authorization to conduct Virtual Asset transactions.
Where the proposed model includes regulated services, the relevant VARA licensing requirements need to be examined alongside the commercial activity on the trade license.
The objective is alignment: the business described to the commercial licensor, regulator, bank and platform should be the same business.
Before incorporating another entity, review the company you already have.
The useful questions are whether its licensed activity fits the intended operation, whether its regulatory documents address that activity, and whether its account arrangements can accommodate the proposed settlement process.
A new company will not resolve an unclear transaction model. Equally, an existing company should not be assumed suitable simply because it already holds a trade license.
The review should identify a concrete outcome: use the existing entity, amend its arrangements, or consider a different structure. That decision should follow the activity assessment.
The following table is a practical assessment tool. It is not an additional official submission checklist.
| Review area | Question to resolve | Evidence to examine |
|---|---|---|
| Operating entity | Which company will conduct the trading? | Entity documents and ownership records |
| Activity scope | What does the company do in each transaction? | Transaction narrative and flow diagram |
| Permissions | Does the documented scope cover the proposed operation? | Commercial license and regulatory documents |
| Platform account | Is the account associated with the intended operating entity? | Corporate verification records |
| Settlement | Which accounts receive and send payments? | Account ownership and settlement instructions |
| Reconciliation | Can each payment be matched to a trade and asset movement? | Completed transaction records |
| Exceptions | How are mismatched payments, refunds and disputes handled? | Procedures and exception records |
| Business changes | Who reviews permissions when the operation changes? | Assigned responsibility and review triggers |
The most important gaps may sit between documents.
A business plan might describe treasury investment, while transaction records show an advertisement-led dealing operation. A banking explanation might describe one settlement process, while the platform application describes another.
These differences should be resolved before submission. A reviewer should be able to reconstruct a representative transaction from the records and reach the same understanding of the business presented in the application.
A corporate bank account is part of the operating structure. Its ownership, disclosed purpose and actual use should be considered alongside the platform account and trading activity.
Binance’s Merchant Guidelines require payment-account names to match the verified personal or corporate name. They also instruct merchants not to release Virtual Assets where a counterparty’s bank-account name does not match their verified platform name.
For merchants changing their account arrangements, review the details used in daily execution:
Updating an account in an application is only one part of changing the settlement process. Staff instructions and transaction records should reflect the intended arrangement consistently.
Banking should also be addressed as a separate workstream. Establish what activity has been disclosed and what documentation the bank requires, rather than assuming an account opened for another purpose is suitable for the proposed operation.
Corporate onboarding preparation should explain the operation clearly and support that explanation with evidence.
A working file can bring together the ownership structure, trading activity, source of trading capital, account arrangements and representative transactions. These are preparation recommendations; the final submission requirements should be confirmed through the relevant onboarding process.
The business description should explain how the company earns revenue and how a trade moves from order to settlement.
If the operation includes materially different transaction types, describe them separately. For example, the process for a standard platform order may differ from a negotiated transaction or an arrangement conducted for another party.
The application narrative should make those differences visible. It should also agree with the records and explanations used in licensing and banking discussions.
Binance states that existing balances, withdrawals, escrow and dispute processes continue, with no forced liquidation. Non-AED flows and AED activity between non-UAE participants remain unchanged.
For merchants considering another market, the decision should still include a review of the relevant jurisdiction, platform rules and settlement arrangements.
An unaffected platform feature does not, by itself, establish that a proposed business model satisfies every applicable regulatory requirement.
Crypto businesses looking beyond P2P can see how KOLL supports Web3 and DeFi firms on licensing in Dubai and Abu Dhabi.
Preparation should follow the decisions that affect everything else.
Document the entity, accounts, assets, counterparties and transaction flows. Include exceptions and any activity conducted outside the platform.
Establish the proposed commercial and regulatory scope before committing to a structure based on an assumed classification.
Identify which documents, permissions and account arrangements can be used, and which need amendment or replacement.
Make sure the business description agrees with the ownership records, banking explanation and transaction history.
Use the current application process to establish the documents and account arrangements required for review. Treat submission and approval as separate milestones.
Align payment instructions, reconciliation, exception handling and staff responsibilities with the intended corporate operation.
This sequence is a preparation framework, not an official approval timetable. Its purpose is to identify unresolved dependencies before they delay the application or require the proposed setup to be reconsidered.
No. They are distinct regulatory routes. The relevant route and document scope must be assessed against the activities the business conducts.
It is a relevant fact, but it is not a complete activity assessment. Order initiation and whether the operation provides services to other parties also need examination.
That depends on its activity, permissions and account arrangements. Review these before deciding whether to use, amend or replace the existing structure.
Approval should remain a separate decision in the implementation plan. Do not treat possession of documents or submission of an application as confirmation of acceptance.
Management should understand the trading model, proposed permissions, settlement structure and outstanding approval dependencies. Those answers provide a stronger basis for a decision than a document checklist alone.
For merchants seeking to retain access to UAE customers, the priority is establishing what the current operation needs to qualify—and which arrangements must change.
Resolve the activity classification first, then align the commercial license, VARA documentation, corporate verification and banking arrangements with the same trading model. This avoids building an application around a license that has not been assessed against the intended activity.
Need a proprietary trading license and VARA NOC for your proposed P2P operation? Speak with a KOLL licensing expert to assess the appropriate route and the requirements for your existing setup.
Disclaimer. KOLL is not affiliated with Binance.
