ADGM Commercial Licensing Regulations 2025

ADGM Regulations of 2025 · ADGM

Official title
ADGM Commercial Licensing Regulations 2025
Instrument
ADGM Regulations of 2025
Issued by
Board of Directors of ADGM
Jurisdiction
ADGM
Dates
issued 28 October 2025 · in force 28 October 2025
Status
in force (amended)
Amended by
Commercial Licensing Regulations (Amendment No. 1) 2026
Topics
ADGM · Licensing
Official source
ADGM Legal Framework (rulebook) · official text (PDF)
Full text
English official text — 50 sections, 8,193 words, from the official text
Verified
30 October 2026
Print

ADGM's licensing statute from 28 October 2025, replacing the 2015 Regulations: no one may carry on a controlled activity in or from ADGM without a Registration Authority licence, licences must be renewed before expiry, and contraventions carry fines up to level 9 on the Fines Scale.

Summary

The Commercial Licensing Regulations 2025 decide who may carry on business in or from the Abu Dhabi Global Market. They came into force on publication on 28 October 2025 and repeal the Commercial Licensing Regulations 2015 (section 48(4)). The consolidated version of June 2026 includes the Amendment No. 1 Regulations 2026, which added supplementary operating addresses and a general false-statement contravention.

The core is the general prohibition in section 1: no person may carry on a controlled activity in or from ADGM, or purport to do so, unless it is a licensed person or an exempt person. The Regulations do not list the controlled activities themselves; section 2 leaves that to Board rules, currently the Controlled Activities Rules 2025(A), which cover financial, legal, accountancy, audit, company and tax services, single family office activities and any other economic activity carried on by way of business. Registered auditors under the Companies Regulations 2020 are deemed licensed for audit services.

The Registrar grants a licence on application (sections 9 and 10) when the applicant meets the conditions of licence set in Board rules. The licence states the licensed activities, the principal address and any approved supplementary operating address, and its issue and expiry dates. A licence does not replace any other approval required in ADGM, including under Federal law, and no other approval replaces the licence (section 10(7) and (8)).

Section 11 governs renewal: an application may be made no earlier than one month before expiry; a renewal approved within one month after expiry is treated as continuous, and a later one attracts a late renewal fee. A licensee that does not intend to renew must tell the Registrar within one month after expiry how it will close its operations, registration or incorporation in ADGM.

Part 3 controls business names and requires the individuals and partnerships it covers to show their names and a service address on letters, orders, invoices, receipts and payment demands, and at their premises. Fines are set as levels on the Fines Scale: up to level 9 for breaching the general prohibition or exceeding a licence, level 8 for false statements, level 6 for false claims to be licensed and for a renewal left outstanding, and level 3 for wind-down and disclosure failures.

Who it applies to

Every person, natural or legal, that carries on or claims to carry on a controlled activity in or from ADGM; licensed persons and their renewals; exempt persons; and individuals and partnerships covered by the business-name disclosure rules.

Contents

English official text in 50 sections. Open the full text or jump to a provision:

  1. Section 1 — The general prohibition
  2. Section 2 — Controlled activities
  3. Section 3 — Contravention of the general prohibition
  4. Section 4 — Licensed persons exceeding scope of licence
  5. Section 5 — False claims to be licensed or exempt
  6. Section 6 — Partnerships
  7. Section 7 — Withdrawal of licence
  8. Section 8 — Exemption orders
  9. Section 9 — Application for a licence
  10. Section 10 — Granting licences
  11. Section 11 — Renewal of licences
  12. Section 12 — Granting licences: special cases
  13. Section 12A — Supplementary operating addresses
  14. Section 12B — Supplementary operating address statement of policy
  15. Section 13 — Variation by Registrar at request of licensed person
  16. Section 14 — Applications under this Part
  17. Section 15 — Determination of applications
  18. Section 16 — Right to refer matters to the court
  19. Section 17 — Power to make rules
  20. Section 18 — Modification or waiver of rules
  21. Section 19 — Publication of directions under section 18
  22. Section 20 — Limit on effect of contravening rules
  23. Section 21 — Rule-making instruments
  24. Section 22 — Verification of rules
  25. Section 23 — Power of the Registrar to give guidance
  26. Section 24 — Service of notices
  27. Section 25 — Application of this Chapter
  28. Section 26 — Name suggesting connection with government or public authority
  29. Section 27 — Other sensitive words or expressions
  30. Section 28 — Withdrawal of Board's approval
  31. Section 29 — Name containing inappropriate indication of company type or legal form
  32. Section 30 — Name giving misleading indication of activities
  33. Section 31 — Application of this Chapter
  34. Section 32 — Information required to be disclosed
  35. Section 33 — Disclosure required: business documents etc
  36. Section 34 — Exemption for large partnerships if certain conditions met
  37. Section 35 — Disclosure required: business premises
  38. Section 36 — Consequences of failure to make required disclosure: contraventions
  39. Section 37 — Consequences of failure to make required disclosure
  40. Section 38 — Interpretation
  41. Section 39 — Definitions
  42. Section 40 — Carrying on controlled activities in the Abu Dhabi Global Market
  43. Section 41 — Parent and subsidiary undertaking
  44. Section 42 — Group
  45. Section 43 — Meaning of "participating interest"
  46. Section 44 — Controller
  47. Section 45 — Disregarded holdings
  48. Section 46 — Manager
  49. Section 47 — General false statement contravention
  50. Section 48 — Short title, extent and commencement

Key provisions

Section 1General prohibition: no controlled activity may be carried on in or from ADGM, or purportedly carried on, except by a licensed or exempt person; registered auditors are deemed licensed for audit services.
Section 2Controlled activities are those specified in Board rules, which may also say when an activity is carried on in or from ADGM; the current rules are the Controlled Activities Rules 2025(A).
Sections 3–5Carrying on a controlled activity without a licence or beyond its scope is a contravention with fines up to level 9; false claims to be licensed or exempt, level 6. A due diligence defence applies, and contracts are not void merely because of the contravention.
Section 8The Board may exempt specified persons or classes from the general prohibition by order, for all or some controlled activities, in specified circumstances or subject to conditions.
Sections 9–10The Registrar grants a licence when the conditions of licence in Board rules are met; the licence states the activities, the addresses they may be carried on from, a unique number, and issue and expiry dates.
Section 10(7)–(8)A licence does not exempt the holder from any other licence or approval required in ADGM, including under Federal law, and no other approval replaces the need for a licence.
Section 11Renewal: apply no earlier than one month before expiry; approval within a month after expiry is continuous, later approval carries a late fee; an outstanding renewal is a level 6 contravention; non-renewing licensees must notify their wind-down within a month.
Sections 12A–12BInserted in June 2026: the Registrar may approve supplementary operating addresses, which form part of the licence without creating a branch, entity or separate licence, subject to conditions and a published Registrar policy.
Sections 26–30Business names may not suggest a government connection, use sensitive words without approval, wrongly indicate a company type or legal form, or give a misleading indication of the activities carried on.
Sections 32–36Individuals and partnerships covered by Part 3 must show names and a service address on business letters, orders, invoices, receipts and payment demands and at their premises; failures carry fines up to level 3.
Section 47Inserted in June 2026: a general false-statement contravention under these Regulations, punishable by a fine up to level 8 on the Fines Scale.
Section 48The Regulations came into force on publication, 28 October 2025, apply in ADGM, and repeal the Commercial Licensing Regulations 2015 from that date.

Obligations and deadlines

  • Hold a licence for every controlled activity carried on in or from ADGM before starting it.
  • Carry on controlled activities only within the scope and from the addresses stated in the licence.
  • Apply for renewal no earlier than one month before the licence expires.
  • If not renewing, tell the Registrar within one month after expiry how operations will be closed.
  • Use a supplementary operating address only as approved and on the Registrar's conditions.
  • Show the required names and service address on business documents and at business premises.

Penalties

Fines are set as levels on the Fines Scale: up to level 9 for carrying on a controlled activity without a licence or outside its scope (sections 3 and 4), level 8 for a false statement (section 47), level 6 for falsely claiming to be licensed or exempt and for a renewal left outstanding beyond the late-fee period (sections 5 and 11(5)), and level 3 for failing to notify or complete a wind-down after non-renewal and for business-name disclosure failures (sections 11(8), 34 and 36). Late renewal also attracts a late renewal fee set by Board rules.

In practice — how Polaris handles it

We set up ADGM companies and foundations for clients through an ADGM-licensed company service provider and keep their filings and documents, so these Regulations set the licensing calendar we work to. At formation we check the proposed business against the Controlled Activities Rules, because the licence lists each controlled activity and the addresses it may be carried on from, and trading outside that scope is a level 9 contravention. We diarise renewal so the application is filed in the month before expiry: a renewal approved more than a month late attracts a late fee, and one left outstanding beyond that is itself a contravention. When a client closes an ADGM entity instead of renewing, we make sure the Registrar is told within a month of expiry and that the wind-down is completed.

History and citations

Amended byCommercial Licensing Regulations (Amendment No. 1) 2026
RepealsCommercial Licensing Regulations 2015
CitesADGM Founding Law

“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.

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Related Polaris services

Source and verification. This record was written from the official text published at en.adgm.thomsonreuters.com, read on 30 October 2026. Quoted from that text: “The Commercial Licensing Regulations 2015 are repealed from the date these Regulations come into force.”
Published for general information by Polaris Corporate Services FZ-LLC, a licensed Trust and Corporate Service Provider. It is not legal advice and does not replace the official text, which prevails in case of difference. Arabic is the authoritative language of UAE federal and emirate legislation; English translations are provided by the issuing authorities. Instruments change: check the status and the official source before relying on this page.

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