Founders ask what a licence costs as if the answer were a single number. It is not. A regulator can charge you on entry, charge you every year, lock up your capital, or tax your turnover, and each regime mixes those levers differently. The mix matters more than the headline, because it decides who can afford to enter and who gets squeezed out.
This week I told ITWeb Africa that Nigeria’s proposed rules will bring institutional capital in — and that licensing fees, audits and capital requirements may push some smaller operators to merge or exit. That is not a Nigerian story. It is the same trade-off Dubai and Islamabad have already made. Here is how the three compare for the activity most founders start with: running an exchange.
Exchange licensing costs at a glance
| Dubai (VARA) | Pakistan (PVARA) | Nigeria (SEC) — proposed | |
|---|---|---|---|
| Entry fee | AED 100,000 application fee | Set by Rules under Reg 11; non-refundable processing fee | NGN 30m registration, plus NGN 300,000 application and NGN 100,000 processing |
| Recurring fee | AED 200,000 annual supervision fee, per activity | Annual supervisory and renewal fees set by Rules | 0.025% of adjusted turnover |
| Minimum capital | Higher of AED 1.5m or 25% of fixed annual overheads (AED 800,000 / 15% under a qualifying custody arrangement) | PKR 500m, maintained at all times | NGN 2bn, plus a fidelity bond of at least 25% of that figure |
| Local substance | Dubai-licensed entity | Company under the Companies Act, 2017, minimum three directors | Nigerian incorporation, registered office, resident CEO or principal officer |
Indicative USD equivalents: AED 100,000 ≈ USD 27,000; AED 1.5m ≈ USD 408,000; PKR 500m ≈ USD 1.8m; NGN 2bn ≈ USD 1.4m; NGN 30m ≈ USD 21,000. Exchange rates move; the local-currency figure is the binding one.
Dubai: fee-heavy, capital-proportionate
VARA’s Schedule 2 (Supervision and Authorisation Fees) charges AED 100,000 to apply for Exchange Services and AED 200,000 a year to supervise them. Each additional VA activity attracts an extension fee and its own annual supervision fee, so a business that wants exchange, broker-dealer and custody pays three supervision fees, not one. VARA also reserves the right to impose additional supervision fees by risk profile.
Capital is where Dubai is gentler than its reputation. The floor scales with your fixed annual overheads, so a lean operator posts something close to the minimum rather than a number designed for a tier-one exchange. The real cost in Dubai is recurring: fees per activity, plus the compliance headcount VARA expects to see on the ground. See our VARA licensing guide for the full process.
Pakistan: a fixed capital floor, fees still to come
Pakistan went the other way. Schedule I of the Pakistan Virtual Asset Services Regulations, 2026 (S.R.O. 1419(I)/2026, notified 21 August 2026) fixes minimum paid-up capital by category: PKR 15m for advisory, PKR 75m for broker-dealer, PKR 200m for custody, PKR 300m for token issuance, and PKR 500m for exchange, lending and borrowing, derivatives and mining-related services. Reg 10(3) requires that capital to be maintained at all times, not just shown at application.
The fee quantum — processing, licensing, annual supervisory and renewal — is left to Rules under Reg 11 rather than written into the Regulations. Operators budgeting for PVARA should therefore plan around the capital number and treat fees as a variable until the Rules are confirmed. The downside of operating without a licence is fixed: section 54(1) of the Virtual Assets Act, 2026 carries up to five years’ imprisonment and a fine of up to PKR 50m. Our PVARA licensing guide covers the NOC and licence timelines.
Nigeria: a high floor, plus a turnover levy
On 20 August 2026 the Securities and Exchange Commission published an exposure draft of its Rules on Digital and Virtual Asset Operations, Custody and Markets under the Investments and Securities Act, 2025, to replace the 2022 digital asset rules. The draft is not yet final, but the architecture is clear.
Capital by category
Digital asset exchanges and custodians: NGN 2bn. Digital asset platform operators, offering platforms and real-world asset tokenisation platforms: NGN 500m. Virtual asset service providers: NGN 200m. Every category must also carry a fidelity insurance bond of at least 25% of its minimum capital.
Fees that grow with you
Registration is NGN 30m per category. After full registration, exchanges pay a supervisory fee of 0.025% of adjusted turnover and other entities 0.015%. Firms in the SEC’s Accelerated Regulatory Incubation Programme (ARIP) pay lower rates while they are in it, after an NGN 200,000 assessment fee and an NGN 2m application fee. A turnover-based levy is a different animal from a flat fee: it costs a start-up little in year one and a scaled exchange a great deal.
Reach and substance
The draft captures business carried on in Nigeria or targeted at persons resident in Nigeria, which brings offshore platforms with Nigerian users inside the perimeter. It requires local incorporation, a registered office and a resident chief executive or principal officer. Retail investors would be capped at NGN 1m per issuer and NGN 10m across digital asset offerings in any 12 months.
What the comparison tells an operator
Capital is the real gate. Fees are recoverable from revenue; locked capital is not. On exchange services, Pakistan’s floor is roughly four times Dubai’s minimum in dollar terms, and Nigeria’s proposed floor sits between the two before the fidelity bond is added. That is the number that decides whether a seed-stage team can apply at all.
Every regime has a lower rung. PKR 15m for advisory in Pakistan and NGN 200m for a VASP in Nigeria are realistic entry points. The sound sequence for most early-stage businesses is to license the narrowest category the model actually needs, then extend once revenue justifies the next capital tier.
Licensing in one hub does not buy access to the others. Nigeria’s targeting test and Pakistan’s criminal penalty for unlicensed activity mean a Dubai licence is not a passport. Market access is licensed market by market.
Expect consolidation. Where the floor is fixed and high, operators below it have three choices: raise, merge or partner with a licensed entity. Regulators in all three markets have accepted that trade-off in exchange for institutional confidence. Founders should plan for it rather than be surprised by it.
If you are deciding where to license first, or how to sequence licences across markets, speak to Esquare Legal. We work across the jurisdictions where the decision usually gets made.
Figures as published by VARA, PVARA and the SEC Nigeria exposure draft as at October 2026. The Nigerian rules are proposed and may change before adoption. This note is general information, not legal advice.