The regulation that applies English common law, including the rules of equity, directly in ADGM as it stands from time to time, and makes a schedule of English civil statutes applicable in the zone, subject to ADGM's own regulations. The consolidated text is published in the ADGM rulebook hosted by Thomson Reuters.
The Application of English Law Regulations 2015 are the instrument that makes English law the civil and commercial law of Abu Dhabi Global Market. ADGM's own description, on the ADGM Courts page read for this record, is that the foundation of the civil and commercial law in ADGM is provided by these Regulations, which make English common law, including the rules and principles of equity, directly applicable in ADGM, and that a wide-ranging set of well-established English statutes on civil matters are also made applicable in the zone. ADGM presents this as the first direct-application approach in the Middle East, modelled on Singapore and Hong Kong.
The practical consequence is that a contract, a trust, a security document or a directors' duty question arising in ADGM is read against English case law and the applied English statutes unless an ADGM enactment provides otherwise. That is the single largest difference between ADGM and the DIFC, which codified its own contract, obligations and trust laws rather than importing English law wholesale. It also means that ADGM has no civil code of its own and that the federal Civil Transactions Law does not govern civil and commercial matters inside the zone.
The page places the Regulations alongside the ADGM Courts, Civil Evidence, Judgments, Enforcement and Judicial Appointments Regulations 2015, which constitute the courts that apply this law and are drawn in part from Scots and Australian federal law. The ADGM Courts comprise a Court of Appeal and a Court of First Instance with Commercial and Civil, Real Property, Employment and Small Claims Divisions, with Small Claims appeals heard by the Civil Division.
The Regulations were enacted by the Board of Directors of ADGM in 2015 under Abu Dhabi Law No. 4 of 2013 and remain in force; the index records no amendments. The ADGM page does not reproduce the operative text, the schedule of applied English statutes or the precedence rule between ADGM enactments and English law, so this record does not cite section numbers. The consolidated text is published in the ADGM legal framework library, and any question about whether a particular English statute applies, and with what modifications, must be answered from that text rather than from this page.
Every person, company, foundation, partnership and branch established or operating in ADGM, the parties to contracts and other civil or commercial relationships governed by ADGM law, and the ADGM Courts and arbitral tribunals that apply that law.
| Section: Foundation of ADGM Courts – application of English law | The foundation of the civil and commercial law in ADGM is provided by the Application of English Law Regulations 2015, which make English common law, including the rules and principles of equity, directly applicable in ADGM. |
| Section: Foundation of ADGM Courts – English statutes | In addition to the common law, a wide-ranging set of well-established English statutes on civil matters is made applicable in ADGM; the page does not list them. |
| Section: Foundation of ADGM Courts – ADGM Courts Regulations | The ADGM Courts, Civil Evidence, Judgments, Enforcement and Judicial Appointments Regulations 2015, which constitute the courts applying this law, are drawn in part from Scots and Australian federal law and tailored to ADGM. |
| Section: English Common Law – direct application | ADGM's legal framework enshrines the direct application of English common law, making ADGM the first jurisdiction in the Middle East to adopt an approach similar to Singapore and Hong Kong. |
| Section: ADGM Courts Structure | A Court of Appeal and a Court of First Instance with Commercial and Civil, Real Property, Employment and Small Claims Divisions; appeals from the Small Claims Division go to the Civil Division. |
This instrument is why we can tell clients that an ADGM SPV's shareholders' agreement, share pledge, facility agreement or directors' duty question will be read under English law by a court that applies English precedent. When a client is choosing between a DIFC and an ADGM holding company, the governing-law difference is usually the first thing we explain: lenders and international counsel already know English law, which shortens negotiation of ADGM security and intercreditor documents. We draft ADGM constitutional documents and agreements on that basis and leave DIFC-style codified-law drafting for DIFC entities. Where a client's foundation or SPV is formed in ADGM we coordinate the registered office through an ADGM-registered provider and handle the documentation ourselves.
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