Spotlight·Virtual Assets

From first assessment to a VARA licence you can operate under.

We help virtual asset businesses prepare for, progress through and operate under a VARA licence. Finance, business planning, regulatory and compliance work runs as one programme, so that everything VARA reads tells the same story.

VARA reads the business plan, projections, capital position and compliance framework as one case. Most applicants have them prepared separately, by advisers who rarely see each other's work. We build them together, so the numbers support every commitment the policies make.

Scope. Nuvira provides management consultancy. We advise and prepare; we do not provide legal services, act as your Compliance Officer or MLRO, or represent you before VARA. Licensing decisions rest solely with VARA, and no outcome or timeline is guaranteed. Nuvira is not affiliated with or endorsed by VARA.

The Licensing Path

Five stages, one consistent story.

01

Readiness

Activities, category and Rulebooks confirmed.

02

Disclosure Questionnaire

Model, owners, management, funding.

03

Initial approval

Incorporate and hire. No virtual asset activity yet.

04

Full application and review

Documents, query rounds, conditions.

05

Licensed operation

Launch and ongoing supervision.

The Challenge

Where licensing stalls.

01

The wrong starting point

Activities mapped to the wrong licence category or Rulebook mean rework before VARA has engaged at all.

02

A file that contradicts itself

Business plan, financial model, capital position and policies written by different hands and never reconciled.

03

Query rounds that drain management

Information requests come in more than one round, and every answer must stay consistent with what was already submitted.

04

Approval is not the finish line

Licence conditions, reporting and Rulebook changes have to become part of how the business runs.

Our Services

Support matched to where you are.

Engage us for one stage or across the whole journey. Scope follows your proposed activities, licence category and the VARA requirements in force at the time.

Pillar 01 · Prepare

Pre-application readiness and gap assessment

Relevant if you areConsidering a VARA licence, or deciding whether you are ready to file.
  • Review of business model and proposed activities against VARA's activity categories and the Rulebooks that apply
  • Readiness assessment across governance, compliance, staffing, systems and documentation
  • Review of business plan, financial model and capital readiness against applicable requirements
  • Support preparing the information required for the Initial Disclosure Questionnaire
  • Prioritised gap-closure roadmap with owners, dependencies and indicative timelines
Outcome

A clear view of where you stand, what has to be fixed, and in what order.

Pillar 02 · Apply

Application support and regulatory engagement

Relevant if you areBuilding the full application, before or after initial approval.
  • Programme management of the licensing workstream through to grant, coordinating management, finance, technology and other advisers
  • Business plan, financial model and projections built to support the application
  • Capital and prudential position modelled against applicable Rulebook requirements
  • Mapping of Rulebook requirements to your operating model
  • Design and review of governance, risk, AML/CFT and customer due diligence frameworks
  • Drafting responses to VARA information requests for your submission, and tracking open items
Outcome

An application in which the plan, the numbers and the compliance framework agree.

Pillar 03 · Maintain

Post-licence compliance support

Relevant if you areLicensed and launching, or adding activities and products.
  • Support meeting licence conditions before and after launch
  • Compliance calendars and obligation trackers for reporting and submissions
  • Periodic compliance health checks and gap assessments
  • Review and update of policies, procedures and controls
  • Impact assessment of Rulebook and regulatory change
  • Reassessment of obligations as activities, products or the operating model change
Outcome

A compliance framework the business can run, long after the day of approval.

On timelines. VARA licensing is iterative and typically runs six to eight months on average, depending on your activities, licence category and the completeness of the file, with expectations that develop as the review progresses. Our role is continuity and structure across that period, so your leadership team can keep building the business.

Start with where you stand. A first conversation usually establishes which activities and Rulebooks apply to you.

Start a conversation