ADGM Regulatory Priorities 2026–2027: What Businesses, Directors and Compliance Teams Need to Know

Abu Dhabi Global Market (ADGM) is an international financial centre in Abu Dhabi that provides a jurisdiction for businesses across financial services, professional services, technology and other commercial activities.

As the number and variety of businesses operating in ADGM continue to grow, maintaining accurate corporate records, meeting filing deadlines and complying with regulatory requirements remain important responsibilities for licensed entities and their management.

On 1 October 2026, the ADGM Registration Authority (RA) published its Regulatory Priorities for 2026–2027, setting out the areas where it intends to focus its monitoring, supervision and enforcement activities during the year ahead.

The report identifies ten priorities covering annual filings, licence renewals, audit quality, beneficial ownership information, emerging technologies, consumer protection, anti-money laundering compliance and the conduct of licensed service providers.

For companies, directors, auditors, company service providers and other regulated businesses, the publication offers a useful indication of the areas receiving particular regulatory attention.

The key message for ADGM businesses is clear: compliance should not be limited to obtaining and renewing a commercial licence. Corporate records, reporting, ownership information and ongoing regulatory obligations also require regular attention.

1. What Are ADGM’s Regulatory Priorities for 2026–2027?

The ADGM Registration Authority is responsible for registering, incorporating and licensing legal entities in ADGM, as well as monitoring and enforcing compliance with the commercial requirements falling within its remit.

Its 2026–2027 report explains where it intends to direct its supervisory and enforcement resources and how it plans to measure progress.

The ten priorities are:

1. Accuracy, timeliness and quality of annual filings and licence renewals.

2. High standards of audit quality, auditor conduct and corporate reporting.

3. Data-driven, risk-based and targeted supervision of higher-risk licensed entities.

4. Accurate and up-to-date beneficial ownership information.

5. Responsible innovation and risk-based oversight of emerging technologies within the RA’s remit.

6. Fair, transparent and responsible retail business practices and stronger consumer protection.

7. Risk-based supervision of designated non-financial businesses and professions (DNFBPs) for anti-money laundering, counter-terrorist financing and targeted financial sanctions compliance.

8. High standards of quality, professionalism, governance and compliance among licensed company service providers.

9. Action against unlicensed activities, activities exceeding the scope of an ADGM licence and misleading claims about licensing status.

10. Timely, decisive and proportionate enforcement against misconduct.

These priorities cover different types of businesses and professional responsibilities. Not every priority will apply to every ADGM entity in the same way.

The report should therefore be used as a guide to areas of regulatory attention, alongside the legislation, licence conditions and other requirements applicable to each business.

2. Annual Filings and Licence Renewals: Why Corporate Records Matter

One of the Registration Authority’s principal priorities is improving the accuracy, timeliness and quality of annual filings and licence renewals.

For businesses, this means reviewing not only whether a filing has been submitted, but also whether it is complete, accurate and consistent with the company's records.

Depending on the entity and its applicable obligations, relevant matters may include annual accounts, confirmation statements, licence renewal documentation and other required corporate filings.

Late or inaccurate submissions can create avoidable compliance issues. Repeated late filing is also specifically identified in the report as an area relevant to regulatory performance monitoring.

What should businesses do?

Companies should maintain a central calendar of statutory and regulatory deadlines, assign responsibility for each filing and ensure that supporting information is available before the deadline.

Management should also review the accuracy of company information before submission rather than relying exclusively on administrative reminders.

Where a company uses an external accountant or company service provider, the allocation of responsibility for preparing, reviewing and submitting documents should be clear.

Outsourcing administrative work does not remove the need for the company and its management to understand their applicable obligations.

3. Beneficial Ownership: Keeping Information Accurate and Up to Date

Beneficial ownership transparency is another express priority for 2026–2027.

The Registration Authority intends to promote adequate, accurate and up-to-date beneficial ownership information among ADGM legal persons and arrangements.

Beneficial ownership information helps establish who ultimately owns or controls an entity. It can be relevant to corporate transparency, regulatory supervision and the prevention of financial misconduct.

For businesses, the practical concern is whether the information maintained in their records continues to reflect their actual ownership and control arrangements.

Changes in shareholding, ownership structures or control may require a review of the entity's records and any applicable notification or filing obligations.

Practical compliance steps

Businesses should:

• Review the beneficial ownership information maintained for their entity.

• Identify changes in ownership or control that may require an update.

• Keep supporting corporate documents and ownership records organised.

• Confirm the applicable deadlines and notification requirements under the relevant ADGM rules.

• Ensure that the information held by the company and information submitted to the relevant authority are consistent.

The exact requirements depend on the entity, its ownership arrangements and the applicable rules. Businesses should not assume that every ownership change follows the same reporting procedure.

4. Audit Quality and Corporate Reporting

The Registration Authority has also identified audit quality, auditor conduct and corporate reporting as priority areas.

This reflects the importance of reliable financial information and appropriate professional standards in maintaining confidence in the business environment.

For companies subject to audit or financial reporting requirements, compliance involves more than producing documents at the end of the financial year. Businesses need suitable records, consistent accounting processes and timely cooperation with their auditors.

The report also identifies regulatory monitoring and follow-up of audit findings as part of the Authority's intended approach.

What businesses should review

Companies should confirm which accounting and audit requirements apply to their legal form and circumstances. They should maintain complete supporting records, meet applicable reporting deadlines and address audit queries promptly.

Where an audit identifies weaknesses or required corrective action, management should document the response and monitor the implementation of agreed measures.

Directors and senior management should also ensure that responsibilities for financial reporting and audit coordination are properly allocated.

The specific accounting, audit and filing obligations applicable to an entity must be checked against the relevant ADGM legislation and guidance.

5. AML/CFT and Targeted Financial Sanctions: Expectations for DNFBPs

Anti-money laundering and counter-terrorist financing compliance remains another important supervisory area.

The Registration Authority has specifically highlighted risk-based supervision of ADGM-licensed designated non-financial businesses and professions (DNFBPs), with a focus on compliance with anti-money laundering (AML), counter-terrorist financing (CFT) and targeted financial sanctions (TFS) requirements.

Depending on the activity and applicable rules, relevant businesses may need to maintain suitable customer due diligence procedures, assess risks, keep appropriate records, monitor transactions or business relationships and comply with applicable reporting and sanctions obligations.

These requirements should be assessed according to the entity's regulated activities and the legal provisions applicable to it.

What should relevant businesses do?

DNFBPs should review whether their compliance procedures remain appropriate for the risks associated with their customers, services and business operations.

They should also confirm that relevant employees understand their responsibilities, records are maintained properly and any required escalation or reporting processes are clear.

A policy document alone may not demonstrate effective compliance. Businesses should consider whether their procedures are implemented in practice, reviewed when circumstances change and supported by appropriate records.

The RA's published priorities do not replace the underlying AML/CFT legislation or create a single set of identical requirements for every business. The applicable obligations must be assessed individually.

6. Company Service Providers: Governance and Professional Standards

Company service providers (CSPs) can support businesses with corporate administration and other services associated with maintaining an entity.

The Registration Authority has identified the quality, professionalism, governance and compliance of licensed CSPs as a priority for the coming year.

For licensed providers, this means reviewing whether their operations, internal procedures and service delivery meet the standards applicable to their activities.

For businesses using these providers, the announcement is a useful reminder to exercise appropriate care when selecting and instructing a service provider.

Considerations for businesses

Before appointing a provider, a business should verify the provider's relevant licensing status and confirm that the proposed services fall within the permitted scope of its activities.

The engagement terms should clearly address the services to be performed, responsibility for deadlines, handling of company records and the process for communicating important compliance matters.

Companies should also maintain access to their own corporate records and avoid relying on informal arrangements for essential filings or regulatory communications.

The relevant licensing status and permitted activities should be checked against official ADGM information.

7. Consumer Protection and Responsible Retail Practices

Consumer protection is another priority identified by the Registration Authority, particularly in relation to fair, transparent and responsible retail business practices.

This is relevant to retail businesses operating within ADGM that fall within the RA's remit.

Businesses should review how they communicate prices, describe products and services, present contractual terms and handle customer complaints.

Clear and accurate information can help reduce disputes and support more consistent customer treatment.

Retail businesses should also identify which consumer protection rules apply to their activities and ensure that their sales and customer service procedures reflect those requirements.

This priority should not be interpreted as meaning that every consumer-facing business is subject to identical rules. The relevant legal requirements depend on the activity, the business model and the applicable regulatory provisions.

8. Emerging Technologies and Unlicensed Activities

The Registration Authority has identified responsible innovation as a priority, including risk-based oversight of emerging technology structures and activities falling within its remit.

It has also highlighted action against unlicensed activities, activities outside the scope of an ADGM licence and false or misleading claims about licensing status.

These priorities are particularly relevant to businesses whose operations, products or services evolve beyond their original business plans.

A company should not assume that an existing licence automatically covers every new service it decides to offer.

Questions businesses should consider

Before introducing a new product, service or operating model, management should verify whether the proposed activity falls within the company's permitted scope.

Businesses should also review the accuracy of their websites, marketing materials and other public statements concerning their ADGM status.

Where an activity may require an additional permission, licence variation or regulatory approval, the relevant requirements should be confirmed before the activity begins.

The applicable position depends on the activity and the authority responsible for regulating it. The Registration Authority's priorities do not replace the requirements of other ADGM authorities or sector-specific regulators.

9. Risk-Based Supervision and Enforcement

The report confirms that the Registration Authority intends to use a risk-based and proportionate approach to monitoring and enforcement.

This includes targeted supervision of higher-risk licensed entities, regulatory monitoring and action intended to address misconduct and improve compliance.

The Authority also identifies timely and proportionate enforcement as a priority, including cooperation with relevant authorities where appropriate.

This does not mean that every ADGM company should expect an investigation or that the report introduces a new penalty schedule.

Instead, it indicates the Authority's intended supervisory focus and reinforces the importance of businesses being able to demonstrate that they understand and meet their applicable obligations.

Companies should maintain appropriate records, address identified compliance gaps and ensure that important regulatory communications receive timely attention.

Where a potential breach is identified, businesses should assess the issue promptly and obtain appropriate professional advice where necessary.

10. An ADGM Compliance Checklist for 2026–2027

Businesses can use the following checklist as a starting point for reviewing their compliance arrangements.

Corporate administration

• Review upcoming annual filing and licence renewal deadlines.

• Confirm the accuracy and completeness of required submissions.

• Assign responsibility for preparing, reviewing and submitting documents.

Ownership and governance

• Check that beneficial ownership information is accurate and up to date.

• Review changes in ownership or control against applicable notification requirements.

• Keep corporate records organised and accessible.

Accounts and audit

• Confirm the applicable accounting, reporting and audit obligations.

• Maintain supporting financial records.

• Address audit queries and corrective actions within appropriate timeframes.

AML/CFT and sanctions

• Identify whether the business is subject to DNFBP requirements.

• Review relevant risk assessments, procedures, records and staff responsibilities.

• Confirm compliance with applicable reporting and targeted financial sanctions obligations.

Licensing and operations

• Verify the scope and status of the business's licence.

• Review any new activities before launch.

• Check the relevant licensing status of external company service providers.

Consumer-facing activities

• Review pricing, contractual information and customer communications.

• Confirm the consumer protection requirements applicable to the business.

• Maintain suitable procedures for customer complaints and disputes.

This checklist is a practical starting point, not a substitute for reviewing the rules applicable to the specific entity.

Conclusion

ADGM's Regulatory Priorities for 2026–2027 provide businesses with greater visibility into the Registration Authority's intended supervisory and enforcement focus.

The priorities place particular emphasis on timely filings, licence renewals, accurate beneficial ownership information, audit quality, AML/CFT compliance, responsible business practices and action against unlicensed activities.

For ADGM companies and their management, the practical response is to review existing compliance arrangements, identify upcoming obligations and address gaps before they become more serious problems.

Importantly, the report does not mean that every priority is a new legal obligation. Businesses must continue to distinguish between existing statutory requirements, licence conditions and the areas receiving increased regulatory attention.

A proactive compliance review can help businesses maintain accurate records, meet their obligations and respond more effectively to regulatory requirements.

Malhotra Legal Consultancy can assist businesses with reviewing relevant corporate documentation, understanding applicable regulatory obligations and identifying compliance considerations associated with their UAE operations. The scope of assistance will depend on the entity's activities and the rules applicable to it.