Published by the Registration Authority on 16 October 2025 with the Conditions of Licence and Branch Registration Rules 2025(A); the Rules re-define ADGM's controlled activities, add a new controlled activity for tax services, set application requirements for legal and tax service licences and require licensed company service providers to adopt conflicts-of-interest policies, replacing the earlier Controlled Activities Rules.
The Commercial Licensing Regulations (Controlled Activities) Rules 2025 are the ADGM Registration Authority's current list of the activities that need a specific controlled-activity licence rather than an ordinary commercial licence. They were published on 16 October 2025 together with the Commercial Licensing Regulations (Conditions of Licence and Branch Registration) Rules 2025, and the two instruments repeal the earlier framework, including the 2023 Controlled Activities Rules. The source read for this record is the Registration Authority's announcement; the operative text sits in the ADGM rulebook and is not reproduced on the announcement page, so rule numbers are not cited here.
The announcement describes four changes. First, the Controlled Activities Rules introduce a new controlled activity for tax services, bringing tax advisers and tax agents serving ADGM entities into the licensed perimeter alongside legal and company service providers. Second, the Conditions of Licence Rules set application requirements for legal and tax service licences. Third, they impose continuing licence conditions on licensed legal and tax providers. Fourth, they strengthen governance for company service providers.
For legal service providers the conditions are a managing partner or equivalent with at least 8 years of post-qualification experience, a registered office inside the zone, professional indemnity insurance, an annual return to the Registration Authority and compliance with a set of defined principles. For tax service providers at least half of senior management must be suitably qualified professionals, professional indemnity insurance must be obtained and maintained, and the same style of principles applies. For company service providers the announcement states that licensed entities must implement policies and procedures to manage conflicts of interest, which it describes as mandatory.
The Rules are effective immediately for new applicants and licence holders. Transitional timelines have been established for existing licence holders to align with the updated requirements; the announcement does not state those dates, which are in the Rules themselves. The index lists the Rules as in force and as repealing the Commercial Licensing Regulations 2015 (Controlled Activities) Rules 2023, which matches the announcement's statement that the new Rules repeal the existing framework, although the announcement does not name the repealed instruments.
The practical effect is that only a firm licensed by the Registration Authority for the relevant controlled activity may provide legal, tax or company services to ADGM entities from within the zone, and that the people and governance behind such a firm are now specified rather than left to the licence application.
Firms applying for or holding an ADGM commercial licence for a controlled activity, in particular providers of legal services, tax services and company services to ADGM entities; their managing partners and senior management; and the ADGM companies, SPVs and foundations that must appoint licensed providers for those functions.
| Section: Overview of the new framework | Two instruments published on 16 October 2025, the Controlled Activities Rules 2025 and the Conditions of Licence and Branch Registration Rules 2025, replace the existing controlled-activity framework under the Commercial Licensing Regulations 2015. |
| Section: Controlled Activities Rules – tax services | Introduces a new controlled activity for tax services, so that tax advisers serving ADGM entities need a specific controlled-activity licence from the Registration Authority. |
| Section: Conditions of Licence Rules – legal service providers | Applicants must appoint a managing partner or equivalent with at least 8 years of post-qualification experience; licensed firms must keep an office inside the zone, hold professional indemnity insurance, file an annual return with the Registration Authority and comply with defined principles. |
| Section: Conditions of Licence Rules – tax service providers | At least half of senior management must be suitably qualified professionals, professional indemnity insurance must be obtained and maintained, and the provider must comply with defined principles. |
| Section: Company service providers | Licensed company service providers must implement policies and procedures to manage conflicts of interest, described by the Registration Authority as mandatory. |
| Section: Commencement and transition | The Rules are effective immediately for new applicants and licence holders; transitional timelines have been established for existing licence holders to align with the updated requirements. |
The announcement states no fines. Providing a controlled activity without the required licence, or breaching a licence condition, is a contravention of the Commercial Licensing Regulations 2015 attracting fines at the levels set by the Registration Authority's fines rules and, ultimately, licence suspension or withdrawal.
These Rules decide who may act as licensed company service provider, registered-office provider or nominee for our clients' ADGM SPVs and foundations. Polaris is not licensed by the ADGM Registration Authority for a controlled activity, so for every ADGM structure we form we appoint an ADGM-licensed provider for the registered office and the statutory CSP role and coordinate it, while we handle the structuring, documentation, secretarial work and filings ourselves. When a client asks us to recommend a provider we now check that it holds the current controlled-activity licence and has the conflicts-of-interest policy the Rules require. Clients who want tax advice on an ADGM entity from inside the zone are told that the adviser must now hold the new tax services licence.
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