Ruben Bombardi, the VARA General Counsel and Head of Regulatory Enablement, noted that the Virtual Assets Regulatory Authority (VARA) published its Guidance on the Virtual Asset Issuance Rulebook, setting out in practical terms how virtual assets are “created, disclosed, and brought to market” in Dubai.
They added that as the General Counsel and Head of Regulatory Enablement of VARA, they have been closely involved in “shaping the legal and policy architecture behind this work.”
Ruben Bombardi also stated:
“What this Guidance does, in substance, is move the regulatory perimeter upstream. For a long time, the focus in this space has been on how assets are traded. This framework focuses on how they originate. It introduces a structured, but deliberately differentiated, approach to issuance. Some models, particularly those referencing underlying real world assets or maintaining stable value, require full licensing, governance frameworks, and in certain cases reserve asset backing.”
Bombardi added:
“Others can come to market through licensed distributors, with responsibility for due diligence and ongoing validation sitting firmly within the regulated perimeter. And at the edges, there remains room for limited-function assets where secondary markets cannot form.”
Interestingly, these developments indicate that regulatory authorities are recognizing the different nuances in the increasingly technical crypto and web3 and crypto space. Only those regulators that realize crypto is a meaningful innovation and is fundamentally different in many aspects from TradFi will be the ones that excel in the digital assets and blockchain age.
Ruben Bombardi also mentioned:
“Across all of this sits a simple but consequential shift: disclosure is no longer treated as a formality. Whitepapers and Risk Disclosure Statements are enforceable instruments, carrying real accountability, designed to ensure that market participants understand what they are engaging with before capital is deployed. That matters, because most structural risks in virtual assets are not created at the point of trading. They are embedded at issuance, in how rights are defined, how value is derived, and how information is presented to the market.”
Bombardi concluded:
“This Guidance is ultimately about addressing that reality. It is about ensuring that innovation in tokenisation and digital asset design is matched by clarity, discipline, and transparency from the outset, rather than retrofitted after the fact. It also reflects a broader regulatory approach that we have applied consistently: test where necessary, differentiate where appropriate, and codify where there is sufficient evidence to support durable rules.”