ADGM Controlled Activities Rules 2025

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.

Official title
ADGM Commercial Licensing Regulations (Controlled Activities) Rules 2025
Instrument
ADGM Rules of 2025
Issued by
Board of Directors of ADGM (published by the Registration Authority)
Jurisdiction
ADGM
Status
in force
Repeals
Commercial Licensing Regulations 2015 (Controlled Activities) Rules 2023
Topics
ADGM · Licensing · Company law
Official source
adgm.com
Verified
29 October 2026

Summary

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.

Who it applies to

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.

Key provisions

Section: Overview of the new frameworkTwo 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 servicesIntroduces 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 providersApplicants 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 providersAt 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 providersLicensed company service providers must implement policies and procedures to manage conflicts of interest, described by the Registration Authority as mandatory.
Section: Commencement and transitionThe 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.

Obligations and deadlines

  • Obtain a controlled-activity licence before providing legal, tax or company services in or from ADGM.
  • Legal firms: appoint a managing partner with at least 8 years' post-qualification experience and hold professional indemnity insurance.
  • Tax firms: ensure at least half of senior management are suitably qualified and hold professional indemnity insurance.
  • Company service providers: adopt and operate conflicts-of-interest policies and procedures.
  • Licensed legal firms: file an annual return with the Registration Authority.
  • Existing licence holders: meet the new conditions within the transitional timelines set in the Rules.

Penalties

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.

In practice — how Polaris handles it

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.

Related instruments

ADGM Commercial Licensing Regulations

ADGM Regulations 2015 · ADGM · in force (amended)

Requires every person carrying on business in or from ADGM to hold a commercial licence from the Registration Authority, defines controlled activities that need specific …

ADGM Companies Regulations

ADGM Regulations 2020 · ADGM · in force (amended)

Enacted 29 April 2020 under Article 6(1) of Abu Dhabi Law No. 4 of 2013, replacing the 2015 regulations: private and public companies, restricted scope companies, directo…

ADGM Foundations Regulations

ADGM Regulations 2017 · ADGM · in force (amended)

Enacted 14 August 2017 under Article 6(1) of Abu Dhabi Law No. 4 of 2013, the Regulations create the ADGM foundation with any lawful non-charitable objects, a council of …

ADGM BOCR 2022

ADGM Regulations 2022 · ADGM · in force (amended)

Enacted 14 December 2022 to replace the 2018 regulations, they define a beneficial owner as a natural person owning or controlling 25% or more of an ADGM entity or otherw…

ADGM RA Fee Schedule 2025

Official Guide 2025 · ADGM · in force

January 2025 schedule consolidating the US-dollar fees the Registration Authority charges under its fees rules for entity registration, commercial licences and renewals, …

ADGM Founding Law

AD Law 4/2013 · Abu Dhabi · in force (amended)

Establishes the Abu Dhabi Global Market as an independent financial free zone governed by a Board of Directors, creates its three authorities (Registration Authority, Fin…

RAKEZ CSP Regulations 2020

Free Zone Regulations 2020 · RAKEZ · in force

Regulations issued 16 September 2020 under Law No. 2 of 2017 for the registration and certification of entities providing corporate services in the Zone, their duties, ap…

Related Polaris services

Source and verification. This page was written from the official text published at adgm.com, read on 29 October 2026. Quoted from that text: “Licensed entities must implement policies and procedures to manage conflicts of interest.”
This summary is 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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