Abu Dhabi Global Market (ADGM) has introduced a comprehensive update to its Commercial Licensing framework through the Commercial Licensing Regulations (Conditions of Licence and Branch Registration) Rules 2025(A), adopted on 16 October 2025. This version repeals the May 2025 Rules and aligns the licensing regime with the evolving regulatory standards across the UAE and other international financial centres.
1. Modernised Framework and Broader Regulatory Scope
The 2025(A) Rules mark a significant milestone in ADGM’s commitment to maintaining a transparent and internationally benchmarked licensing environment. The update integrates provisions from the Controlled Activities Rules 2024 and introduces new regulatory categories, compliance obligations, and professional standards across key sectors.
2. Expanded Definitions and Professional Recognition
New definitions now include approved tax regulatory body, recognised professional qualification, and post-qualification experience. The previous reference to the UAE Economic Substance Regime has been removed. Enhanced recognition of professional bodies ensures alignment with global standards.
3. Clearer Licensing and Renewal Process
Licensing rules (Rules 2–4A) have been reorganised for transparency. Rule 4A, newly introduced, governs licence renewals and grants the Registrar greater discretion in respect of renewal. Applicants must provide jurisdictional, activity, and signatory details with renewed verification.
4. Strengthened Governance and Record-Keeping Obligations
Licence holders must maintain at least one authorised signatory with a UAE residency visa. Branches are required to keep accounting records for 10 years. A new Rule 7B prohibits branches from destruction of records within five years after deregistration and introduces penalties for breach.
5. New Sector-Specific Licensing Standards
- Legal Services: Managing partners must have eight years of post-qualification experience and be members of a recognised body, with new conduct obligations under Schedule 2.
- Company Service Providers (CSPs): Expanded AML, insurance, and certification obligations under Schedule 1, with Economic Substance references removed.
- Single Family Offices: The specific licensing condition for this activity requires that the family maintain a minimum net asset value of USD 10 million.
- Tax Services: Newly introduced controlled activity under Rule 15, requiring qualified professionals and compliance with Schedule 3.
6. Registrar’s Powers and Regulatory Clarity
The Registrar may designate approved legal, accountancy, healthcare, and tax regulatory bodies, either generally or on a case-by-case basis. The Rules strengthen Registrar oversight, including the power to strike off inactive branches.
7. Practical Implications for ADGM Entities
- Enhanced Professionalism: Legal, tax, and fiduciary service providers must have verifiable qualifications.
- Stronger Compliance Controls: CSPs and branches must maintain robust internal controls and timely regulatory responses.
- Family Office Regulation: Provides clearer legal footing for family governance structures.
- Streamlined Renewals: Renewal applications are subject to structured scrutiny and enhanced oversight.
8. Conclusion
The ADGM Commercial Licensing Regulations (Conditions of Licence and Branch Registration) Rules 2025(A) underscore ADGM’s continued evolution as a globally aligned and well-regulated jurisdiction. The reforms ensure transparency, professionalism and compliance reinforcing ADGM’s standing as a leading regional hub for financial and legal services.
Should you require any information on the updated Commercial Licensing Regulations, or any assistance in the regularisation process, please contact Yasser Omar (y.omar@hadefpartners.com) or Ahmed Helmy (a.helmy@hadefpartners.com), co-authors of this article.