What VARA Expects A Virtual Asset Reserve Audit To Show

Dubai’s Virtual Assets Regulatory Authority (VARA) has clarified how independent audits should verify that customers’ virtual assets, such as bitcoin, are safeguarded. Its circular of 6 October 2026 follows a review of reserve reports submitted in 2025.¹

For anyone keeping virtual assets with a provider, the underlying question is straightforward: does the provider hold the assets it owes its customers, and are those assets properly protected?

What backing customer assets means

VARA’s existing rules require VARA-licensed providers to maintain reserves covering 100% of their liabilities to customers, in the same virtual asset, at all times. If a provider owes customers ten bitcoin, it must hold ten bitcoin to back that obligation. Holding another token worth the same amount does not satisfy the requirement. Providers must reconcile reserves daily, checking holdings against what they owe, and obtain an independent audit at least every six months. The report goes to VARA with the