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Virtual Assets Regulatory Authority (VARA) Audit Methodology

Release: Version 1.0

Document​

FieldDescription
NameVirtual Assets Regulatory Authority (VARA) Audit Methodology
CreatorsHacken OU
SubjectVARA; Dubai compliance; Technology and Information Rulebook; cyber risk management; crypto licensing; audit methodology;
DescriptionA structured compliance methodology developed to support virtual asset service providers (VASPs) in meeting the cybersecurity and information security requirements of the VARA Technology and Information Rulebook. This methodology includes readiness assessment, gap analysis, documentation support, and risk-based implementation for Web2 and Web3 environments.
AuthorDmytro Yasmanovych | Compliance Services Lead, Hacken OU
DateOct 15th, 2025
RightsHacken OU

Intro​

Purpose of the document​

This methodology outlines Hacken’s approach to helping VASPs achieve and maintain compliance with the Technology and Information Rulebook issued by the Virtual Assets Regulatory Authority (VARA), Dubai. It focuses on cyber and operational risk preparedness as part of the mandatory licensing framework.

Why Hacken​

Hacken’s cybersecurity and compliance team brings deep regional expertise across Web3, virtual asset custody, and infrastructure security. We help clients not only pass compliance checks — but also build resilient, VARA-aligned operations grounded in industry best practice.

What is VARA?​

The Virtual Assets Regulatory Authority (VARA) is the regulatory body governing virtual assets within the Emirate of Dubai. Its Technology and Information Rulebook sets mandatory requirements around:

  • Cybersecurity governance
  • ICT infrastructure management
  • Logging, monitoring, and incident detection
  • Backup, recovery, and availability
  • Vendor and third-party security
  • Web2 and Web3 risk management

Compliance is required as part of any licensing under the VARA regime for all regulated VASP activities.

Hacken’s VARA Audit Methodology​

Hacken follows a five-phase audit methodology, optimized to align with the structure and obligations of the VARA Technology and Information Rulebook.

1. Scoping & Readiness Assessment​

The process begins with determining whether the entity is adequately prepared for a VARA compliance engagement.

Readiness Criteria:

  • Entity has identified responsible personnel for security, IT, and governance.
  • Security policies and procedures are at least partially in place.
  • Organizational awareness of VARA Rulebooks and licensing requirements exists.
  • Risk ownership and system architecture (Web2/Web3) are defined.
  • Key systems and third-party services are known and documented.

Deliverable:
📄 Readiness Assessment Report — includes status scoring, critical gaps, and a Remediation Plan. If unprepared, Hacken may pause the audit and support the client in implementing foundational controls.

2. VARA Gap Assessment​

A full clause-by-clause analysis is conducted against the VARA Technology and Information Rulebook using:

  • Interviews with security, tech, and management stakeholders.
  • Evidence requests (policies, technical setups, contracts, recovery logs).
  • Documentation analysis across ICT, risk, and governance domains.

All findings are classified by severity and mapped directly to Rulebook sections.

Deliverable:
📄 VARA Gap Assessment Report — includes clause-level findings, issue severity, and a suggested plan for remediation.

3. Compliance Support & Risk Framework Implementation​

Hacken supports clients in bridging gaps through hands-on advisory:

  • Development of missing documentation (e.g., IS Policy, BCP, Logging Policy).
  • Alignment of backup, access control, and monitoring practices to VARA standards.
  • Implementation of risk registers for both Web2 infrastructure and Web3 services, customized based on asset inventory, criticality, and likelihood/impact models.
  • Guidance on third-party vendor reviews and shared responsibility matrix.

Deliverable:
📄 Documentation Package (if requested) + Updated Risk Register & Implementation Notes.

4. Follow-Up Check​

After remediation, Hacken performs a follow-up audit to confirm:

  • Issues have been resolved with adequate evidence.
  • Policies are implemented and traceable to real procedures.
  • ICT and Web3 risks are now governed under a maintained framework.

Deliverable:
📄 Follow-Up Report — status of all previous findings and closure tracking.

5. Final VARA Compliance Report​

The audit concludes with a formal assessment report that may be used internally or as evidence for regulators during licensing and review.

Deliverable:
📄 Comprehensive VARA Compliance Report, including:

  • Executive Summary
  • Control-by-Control Compliance Table
  • Risk Assessment Summary
  • Remaining Action Items (if any)
  • Audit Sign-off Statement

Optional Complementary Services​

Where needed, Hacken may refer clients to independent security teams for:

  • Technical Penetration Testing (Web2/Web3)
  • Smart Contract Security Audits
  • Static Code Analysis (SCA)
  • Infrastructure Hardening

These services are conducted under separate scope to ensure the independence of compliance services.

Deliverables Summary​

StageDeliverable
ReadinessReadiness Assessment Report + Remediation Plan
Gap AssessmentVARA Gap Assessment Report
Support PhasePolicy Drafting, Risk Register, Advisory Notes
Follow-UpFollow-Up Report
FinalComprehensive VARA Compliance Report
Optional Add-onsPentest, Smart Contract Audit (Separate Scope)

Conclusion​

The Hacken VARA Audit Methodology is tailored to the Technology and Information Rulebook requirements and provides a structured, transparent path to audit readiness. Whether the goal is new licensing, annual re-certification, or proactive risk governance, Hacken ensures your Web2/Web3 operations are secure, documented, and regulator-ready.

For onboarding, please fill our Hacken Compliance Services Form.