In a decisive step toward reinforcing ethical conduct and regulatory transparency, the Abu Dhabi Global Market (ADGM) has officially enacted the Whistleblower Protection Regulations 2024, marking a significant development in the UAE’s push for stronger corporate governance.
23 June, 2025
Whistleblower Protection in ADGM: New Mandatory Regulations for 2025
In a landmark move to enhance transparency and ethical business conduct, the Abu Dhabi Global Market (ADGM) has introduced the Whistleblower Protection Regulations 2024, setting a new standard for corporate governance in the UAE. These binding regulations, effective from May 31, 2025, require all ADGM-registered entities to establish secure, confidential, and enforceable whistleblowing frameworks.
This development marks a shift from the voluntary 2022 Guiding Principles on Whistleblowing to a legally binding structure designed to promote proactive disclosures, deter misconduct, and protect individuals who report violations in good faith.
From Voluntary Guidelines to Mandatory Compliance
While ADGM previously encouraged internal disclosure mechanisms through non-binding principles, the new 2024 regulations now establish a mandatory legal framework. Issued by the ADGM Registration Authority (RA) and supported by the Financial Services Regulatory Authority (FSRA), the rules apply to all ADGM-licensed entities—ranging from banks and law firms to tech startups and holding companies.
Entities employing more than 35 staff or generating annual revenues exceeding USD 13.5 million are subject to additional obligations, such as structured internal policies, employee training, and formal oversight systems.
What Constitutes Whistleblowing?
A whistleblower is someone who raises concerns in good faith about misconduct within an organisation. Under the new rules, “protected disclosures” may include:
Breaches of UAE or ADGM laws
Financial crimes such as fraud, bribery, or money laundering
Violations of regulatory obligations under FSRA or RA regulations
These reports can be made internally within the entity or externally to competent authorities such as the Registration Authority, FSRA, ADGM Office of Data Protection, or UAE law enforcement bodies.
Compliance Requirements for ADGM Businesses
By May 31, 2025, all ADGM-registered entities must implement a comprehensive whistleblowing mechanism. The framework should include:
Secure and accessible reporting channels (e.g., hotlines, emails, third-party systems)
Procedures to review and escalate reports confidentially and fairly
Confidentiality protections and support for anonymous disclosures
Record-keeping obligations, with all records retained for at least six years
These elements must be incorporated into the company’s core governance structure, ensuring the system is maintained and actively used.
Legal Protections Against Retaliation
A key highlight of the new law is the explicit protection against retaliation. Employers are now legally prohibited from punishing whistleblowers through:
Termination or demotion
Harassment or discrimination
Denial of promotions, benefits, or compensation
These protections apply even to anonymous whistleblowers and may extend to contractors and third parties in certain situations.
Consequences of Non-Compliance
Failure to comply with the Whistleblower Protection Regulations can result in significant penalties, including:
Fines
Public censure
Suspension or revocation of commercial licenses
The ADGM Registrar holds enforcement powers and can investigate businesses for violations. Given ADGM’s reputation as a premier financial jurisdiction, non-compliance risks both regulatory and reputational consequences.
Embedding Whistleblowing Into Organisational Culture
These rules aim to create a cultural shift—not just compliance for the sake of legal formalities. They are designed to build trust, foster integrity, and allow employees to raise ethical concerns without fear. As stated by Emmanuel Givanakis, CEO of FSRA:
“Strong and effective whistleblowing frameworks are considered a hallmark of good governance and risk management at any organisation.”
ADGM’s emphasis is on integrating whistleblowing into daily operations, positioning it as a proactive tool for internal accountability and risk management.
Preparing for Compliance: What Businesses Should Do Now
Businesses operating under ADGM should act immediately to meet the upcoming deadline. Recommended steps include:
Updating compliance policies in line with the new law
Implementing digital reporting systems and secure reporting channels
Training employees on whistleblower rights and procedures
Assigning responsible personnel for managing reports confidentially
Testing and auditing systems to ensure they function in practice
Larger companies must also conduct regular reviews and staff training to ensure broad understanding and participation.
Conclusion
ADGM’s Whistleblower Protection Regulations 2024 represent a decisive step toward embedding integrity at the heart of corporate governance. By making whistleblowing legally protected and operationally mandatory, the regulations empower employees, protect organisations from reputational damage, and elevate ADGM’s standing as a jurisdiction that values ethical business conduct.
With the May 31, 2025 deadline approaching, businesses must see this not as a mere regulatory obligation, but as an opportunity to enhance trust, protect stakeholders, and build long-term resilience.
Whistleblower Protection in ADGM: New Mandatory Regulations for 2025
In a landmark move to enhance transparency and ethical business conduct, the Abu Dhabi Global Market (ADGM) has introduced the Whistleblower Protection Regulations 2024, setting a new standard for corporate governance in the UAE. These binding regulations, effective from May 31, 2025, require all ADGM-registered entities to establish secure, confidential, and enforceable whistleblowing frameworks.
This development marks a shift from the voluntary 2022 Guiding Principles on Whistleblowing to a legally binding structure designed to promote proactive disclosures, deter misconduct, and protect individuals who report violations in good faith.
From Voluntary Guidelines to Mandatory Compliance
While ADGM previously encouraged internal disclosure mechanisms through non-binding principles, the new 2024 regulations now establish a mandatory legal framework. Issued by the ADGM Registration Authority (RA) and supported by the Financial Services Regulatory Authority (FSRA), the rules apply to all ADGM-licensed entities—ranging from banks and law firms to tech startups and holding companies.
Entities employing more than 35 staff or generating annual revenues exceeding USD 13.5 million are subject to additional obligations, such as structured internal policies, employee training, and formal oversight systems.
What Constitutes Whistleblowing?
A whistleblower is someone who raises concerns in good faith about misconduct within an organisation. Under the new rules, “protected disclosures” may include:
Breaches of UAE or ADGM laws
Financial crimes such as fraud, bribery, or money laundering
Violations of regulatory obligations under FSRA or RA regulations
These reports can be made internally within the entity or externally to competent authorities such as the Registration Authority, FSRA, ADGM Office of Data Protection, or UAE law enforcement bodies.
Compliance Requirements for ADGM Businesses
By May 31, 2025, all ADGM-registered entities must implement a comprehensive whistleblowing mechanism. The framework should include:
Secure and accessible reporting channels (e.g., hotlines, emails, third-party systems)
Procedures to review and escalate reports confidentially and fairly
Confidentiality protections and support for anonymous disclosures
Record-keeping obligations, with all records retained for at least six years
These elements must be incorporated into the company’s core governance structure, ensuring the system is maintained and actively used.
Legal Protections Against Retaliation
A key highlight of the new law is the explicit protection against retaliation. Employers are now legally prohibited from punishing whistleblowers through:
Termination or demotion
Harassment or discrimination
Denial of promotions, benefits, or compensation
These protections apply even to anonymous whistleblowers and may extend to contractors and third parties in certain situations.
Consequences of Non-Compliance
Failure to comply with the Whistleblower Protection Regulations can result in significant penalties, including:
Fines
Public censure
Suspension or revocation of commercial licenses
The ADGM Registrar holds enforcement powers and can investigate businesses for violations. Given ADGM’s reputation as a premier financial jurisdiction, non-compliance risks both regulatory and reputational consequences.
Embedding Whistleblowing Into Organisational Culture
These rules aim to create a cultural shift—not just compliance for the sake of legal formalities. They are designed to build trust, foster integrity, and allow employees to raise ethical concerns without fear. As stated by Emmanuel Givanakis, CEO of FSRA:
“Strong and effective whistleblowing frameworks are considered a hallmark of good governance and risk management at any organisation.”
ADGM’s emphasis is on integrating whistleblowing into daily operations, positioning it as a proactive tool for internal accountability and risk management.
Preparing for Compliance: What Businesses Should Do Now
Businesses operating under ADGM should act immediately to meet the upcoming deadline. Recommended steps include:
Updating compliance policies in line with the new law
Implementing digital reporting systems and secure reporting channels
Training employees on whistleblower rights and procedures
Assigning responsible personnel for managing reports confidentially
Testing and auditing systems to ensure they function in practice
Larger companies must also conduct regular reviews and staff training to ensure broad understanding and participation.
Conclusion
ADGM’s Whistleblower Protection Regulations 2024 represent a decisive step toward embedding integrity at the heart of corporate governance. By making whistleblowing legally protected and operationally mandatory, the regulations empower employees, protect organisations from reputational damage, and elevate ADGM’s standing as a jurisdiction that values ethical business conduct.
With the May 31, 2025 deadline approaching, businesses must see this not as a mere regulatory obligation, but as an opportunity to enhance trust, protect stakeholders, and build long-term resilience.
Whistleblower Protection in ADGM: New Mandatory Regulations for 2025
In a landmark move to enhance transparency and ethical business conduct, the Abu Dhabi Global Market (ADGM) has introduced the Whistleblower Protection Regulations 2024, setting a new standard for corporate governance in the UAE. These binding regulations, effective from May 31, 2025, require all ADGM-registered entities to establish secure, confidential, and enforceable whistleblowing frameworks.
This development marks a shift from the voluntary 2022 Guiding Principles on Whistleblowing to a legally binding structure designed to promote proactive disclosures, deter misconduct, and protect individuals who report violations in good faith.
From Voluntary Guidelines to Mandatory Compliance
While ADGM previously encouraged internal disclosure mechanisms through non-binding principles, the new 2024 regulations now establish a mandatory legal framework. Issued by the ADGM Registration Authority (RA) and supported by the Financial Services Regulatory Authority (FSRA), the rules apply to all ADGM-licensed entities—ranging from banks and law firms to tech startups and holding companies.
Entities employing more than 35 staff or generating annual revenues exceeding USD 13.5 million are subject to additional obligations, such as structured internal policies, employee training, and formal oversight systems.
What Constitutes Whistleblowing?
A whistleblower is someone who raises concerns in good faith about misconduct within an organisation. Under the new rules, “protected disclosures” may include:
Breaches of UAE or ADGM laws
Financial crimes such as fraud, bribery, or money laundering
Violations of regulatory obligations under FSRA or RA regulations
These reports can be made internally within the entity or externally to competent authorities such as the Registration Authority, FSRA, ADGM Office of Data Protection, or UAE law enforcement bodies.
Compliance Requirements for ADGM Businesses
By May 31, 2025, all ADGM-registered entities must implement a comprehensive whistleblowing mechanism. The framework should include:
Secure and accessible reporting channels (e.g., hotlines, emails, third-party systems)
Procedures to review and escalate reports confidentially and fairly
Confidentiality protections and support for anonymous disclosures
Record-keeping obligations, with all records retained for at least six years
These elements must be incorporated into the company’s core governance structure, ensuring the system is maintained and actively used.
Legal Protections Against Retaliation
A key highlight of the new law is the explicit protection against retaliation. Employers are now legally prohibited from punishing whistleblowers through:
Termination or demotion
Harassment or discrimination
Denial of promotions, benefits, or compensation
These protections apply even to anonymous whistleblowers and may extend to contractors and third parties in certain situations.
Consequences of Non-Compliance
Failure to comply with the Whistleblower Protection Regulations can result in significant penalties, including:
Fines
Public censure
Suspension or revocation of commercial licenses
The ADGM Registrar holds enforcement powers and can investigate businesses for violations. Given ADGM’s reputation as a premier financial jurisdiction, non-compliance risks both regulatory and reputational consequences.
Embedding Whistleblowing Into Organisational Culture
These rules aim to create a cultural shift—not just compliance for the sake of legal formalities. They are designed to build trust, foster integrity, and allow employees to raise ethical concerns without fear. As stated by Emmanuel Givanakis, CEO of FSRA:
“Strong and effective whistleblowing frameworks are considered a hallmark of good governance and risk management at any organisation.”
ADGM’s emphasis is on integrating whistleblowing into daily operations, positioning it as a proactive tool for internal accountability and risk management.
Preparing for Compliance: What Businesses Should Do Now
Businesses operating under ADGM should act immediately to meet the upcoming deadline. Recommended steps include:
Updating compliance policies in line with the new law
Implementing digital reporting systems and secure reporting channels
Training employees on whistleblower rights and procedures
Assigning responsible personnel for managing reports confidentially
Testing and auditing systems to ensure they function in practice
Larger companies must also conduct regular reviews and staff training to ensure broad understanding and participation.
Conclusion
ADGM’s Whistleblower Protection Regulations 2024 represent a decisive step toward embedding integrity at the heart of corporate governance. By making whistleblowing legally protected and operationally mandatory, the regulations empower employees, protect organisations from reputational damage, and elevate ADGM’s standing as a jurisdiction that values ethical business conduct.
With the May 31, 2025 deadline approaching, businesses must see this not as a mere regulatory obligation, but as an opportunity to enhance trust, protect stakeholders, and build long-term resilience.
Whistleblower Protection in ADGM: New Mandatory Regulations for 2025
In a landmark move to enhance transparency and ethical business conduct, the Abu Dhabi Global Market (ADGM) has introduced the Whistleblower Protection Regulations 2024, setting a new standard for corporate governance in the UAE. These binding regulations, effective from May 31, 2025, require all ADGM-registered entities to establish secure, confidential, and enforceable whistleblowing frameworks.
This development marks a shift from the voluntary 2022 Guiding Principles on Whistleblowing to a legally binding structure designed to promote proactive disclosures, deter misconduct, and protect individuals who report violations in good faith.
From Voluntary Guidelines to Mandatory Compliance
While ADGM previously encouraged internal disclosure mechanisms through non-binding principles, the new 2024 regulations now establish a mandatory legal framework. Issued by the ADGM Registration Authority (RA) and supported by the Financial Services Regulatory Authority (FSRA), the rules apply to all ADGM-licensed entities—ranging from banks and law firms to tech startups and holding companies.
Entities employing more than 35 staff or generating annual revenues exceeding USD 13.5 million are subject to additional obligations, such as structured internal policies, employee training, and formal oversight systems.
What Constitutes Whistleblowing?
A whistleblower is someone who raises concerns in good faith about misconduct within an organisation. Under the new rules, “protected disclosures” may include:
Breaches of UAE or ADGM laws
Financial crimes such as fraud, bribery, or money laundering
Violations of regulatory obligations under FSRA or RA regulations
These reports can be made internally within the entity or externally to competent authorities such as the Registration Authority, FSRA, ADGM Office of Data Protection, or UAE law enforcement bodies.
Compliance Requirements for ADGM Businesses
By May 31, 2025, all ADGM-registered entities must implement a comprehensive whistleblowing mechanism. The framework should include:
Secure and accessible reporting channels (e.g., hotlines, emails, third-party systems)
Procedures to review and escalate reports confidentially and fairly
Confidentiality protections and support for anonymous disclosures
Record-keeping obligations, with all records retained for at least six years
These elements must be incorporated into the company’s core governance structure, ensuring the system is maintained and actively used.
Legal Protections Against Retaliation
A key highlight of the new law is the explicit protection against retaliation. Employers are now legally prohibited from punishing whistleblowers through:
Termination or demotion
Harassment or discrimination
Denial of promotions, benefits, or compensation
These protections apply even to anonymous whistleblowers and may extend to contractors and third parties in certain situations.
Consequences of Non-Compliance
Failure to comply with the Whistleblower Protection Regulations can result in significant penalties, including:
Fines
Public censure
Suspension or revocation of commercial licenses
The ADGM Registrar holds enforcement powers and can investigate businesses for violations. Given ADGM’s reputation as a premier financial jurisdiction, non-compliance risks both regulatory and reputational consequences.
Embedding Whistleblowing Into Organisational Culture
These rules aim to create a cultural shift—not just compliance for the sake of legal formalities. They are designed to build trust, foster integrity, and allow employees to raise ethical concerns without fear. As stated by Emmanuel Givanakis, CEO of FSRA:
“Strong and effective whistleblowing frameworks are considered a hallmark of good governance and risk management at any organisation.”
ADGM’s emphasis is on integrating whistleblowing into daily operations, positioning it as a proactive tool for internal accountability and risk management.
Preparing for Compliance: What Businesses Should Do Now
Businesses operating under ADGM should act immediately to meet the upcoming deadline. Recommended steps include:
Updating compliance policies in line with the new law
Implementing digital reporting systems and secure reporting channels
Training employees on whistleblower rights and procedures
Assigning responsible personnel for managing reports confidentially
Testing and auditing systems to ensure they function in practice
Larger companies must also conduct regular reviews and staff training to ensure broad understanding and participation.
Conclusion
ADGM’s Whistleblower Protection Regulations 2024 represent a decisive step toward embedding integrity at the heart of corporate governance. By making whistleblowing legally protected and operationally mandatory, the regulations empower employees, protect organisations from reputational damage, and elevate ADGM’s standing as a jurisdiction that values ethical business conduct.
With the May 31, 2025 deadline approaching, businesses must see this not as a mere regulatory obligation, but as an opportunity to enhance trust, protect stakeholders, and build long-term resilience.
