UAE — Abu Dhabi (ADGM / FSRA)
The UAE's oldest digital-asset regime, built on English common law, with an asset-by-asset "Accepted Virtual Asset" gate.
Who regulates this
Financial Services Regulatory AuthorityFSRA
Financial services within the Abu Dhabi Global Market free zone, under the Financial Services and Markets Regulations 2015.
Licences and permissions
FSP — Operating a Multilateral Trading Facility
Running a venue that matches third-party orders in virtual assets.
The heaviest category. Full prudential, systems and controls obligations attach.
FSP — Providing Custody
Holding or controlling client virtual assets.
Segregation and key-management requirements are prescriptive.
Fiat-Referenced Token activities
Issuing or dealing in FRTs.
Amendments finalised 31 October 2025 took effect 1 January 2026, including FSRA's approach to accepting FRTs for use in ADGM.
What it takes
Capital
Base capital is set by prudential category and scaled by an expenditure-based requirement. An MTF operator sits materially above an advisory firm.
Timeline
Typically six to twelve months from first engagement to Financial Services Permission, driven largely by the depth of the regulatory business plan.
Substance
A real ADGM office and locally-resident Authorised Individuals — Senior Executive Officer, Compliance Officer and MLRO — are expected. Outsourced compliance is scrutinised.
Where a software vendor sits
FSRA regulates regulated activities. Supplying technology to an Authorised Person is not itself one, but the Authorised Person carries outsourcing obligations: it must be able to evidence oversight of, and an exit path from, any material technology provider. Expect to be diligenced as a critical outsourcing arrangement.
What catches people out
The "Accepted Virtual Asset" gate is real. Only assets that clear FSRA's criteria — security, DLT infrastructure, exchange connectivity, market profile, innovation, practical application — may be used in regulated activity. Your token list is a regulatory question, not a product one.
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