ADGM Regulatory Priorities 2026-2027: The ADGM Registration Authority Puts Late Filers, Auditors and CSPs on Notice
Sound familiar? Then the ADGM Registration Authority is talking to you. On October 1, 2026, it published the ADGM regulatory priorities 2026-2027. Ten focus areas. Every one has KPIs attached. Late filers, auditors, company service providers and DNFBPs all get named. The message is simple. Results count. And the regulator has told you, in advance, how it will score them.
Key Takeaways
- The ADGM regulatory priorities 2026-2027 list ten focus areas. Last year had nine.
- Company service providers (CSPs) now get a priority of their own.
- Late filings, ownership records and DNFBP controls face remediation and escalation KPIs.
- Statutory audits must come from ADGM registered auditors. No exceptions.
Ten Priorities, One Message: The ADGM Registration Authority Now Judges Compliance by Outcomes
Last year’s report had nine priorities. This year has ten. Each comes with KPIs. The document is non-binding, but don’t shrug it off. Think of it as a syllabus handed out before the exam. It shows where inspectors will spend their time. The approach is risk-based, so firms that look risky get the most attention. The upside? No guessing. You know what the regulator cares about.
The Ten Priorities, Side by Side
| # | Focus area |
| 1 | Accurate, on-time annual filings and license renewals |
| 2 | Audit quality, auditor conduct and corporate reporting |
| 3 | Data-driven supervision of higher-risk licensed persons |
| 4 | Current beneficial ownership information |
| 5 | Risk-based oversight of emerging technology |
| 6 | Fair retail practices and consumer protection |
| 7 | AML, CFT and sanctions supervision of DNFBPs |
| 8 | Quality and governance standards for CSPs |
| 9 | Action on unlicensed activity and false license claims |
| 10 | Timely, proportionate enforcement |
Who Is in the Frame: Licensed Persons, Directors, Auditors, CSPs and DNFBPs
The report is aimed at ADGM licensed persons, directors, auditors, CSPs and advisors. It also covers DNFBPs. That means Designated Non-Financial Businesses and Professions: real estate agents, precious-metal dealers, lawyers, accountants. Hold an ADGM license? You’re in scope. Advise someone who does? You’re in scope too.
What Moved Since Last Year: Three Shifts That Reset the Compliance Agenda
Here are the three major shifts of this year:
Company Service Providers Get a Priority of Their Own
Priority 8 is new and it matters. CSPs set up companies, supply directors and provide registered offices. Last year they had no priority of their own. As DNFBPs, they sat under general AML supervision. Now the RA plans CSP assessments, agreed fixes and enforcement where needed. Its October 2025 rules already make licensed CSPs run conflicts of interest policies.
If you use a CSP, that’s good news. A tested provider is a safer gatekeeper. If you are a CSP with thin onboarding files, it’s a warning. Our advice: ask your CSP for its policy before it asks for your documents.
Auditor Conduct, Higher-Risk Firms and Legal Arrangements Now Written Into the Text
Three small edits. Big effect. Priority 2 now covers auditor conduct, not just audit quality. Priority 3 narrows to higher-risk licensed persons. Priority 4 widens from legal persons to legal arrangements, which include trusts and foundations. Selection will be data-driven. So keep your records clean and consistent. That is your best protection.
The Scorecard Changes: Remediation and Escalation Replace Inspection Counts
Last year’s KPIs counted activity. Think of the percentage of planned inspections done on schedule. This year’s problem is different. Remediation plans agreed and followed up. Supervisory actions tracked to closure. Repeat late filers escalated. Spotting a problem is no longer the finish line – fixing it is. We expect follow-up requests, not one-off letters.
Late Filers Feel the Pressure First: Annual Filings and Statutory Audits Under the Microscope
Priority 1 tracks on-time rates for renewals, annual accounts and confirmation statements. The early cost is small. Under the RA’s late filing rules, a late renewal, beneficial owner change or director change costs USD 150 for each month overdue.
The cap is USD 450 (about AED 1,650). Annual accounts are due six months after the accounting reference date for public companies. Nine for private ones. Leave a fine unpaid for 30 days and services like certificates of good standing are suspended. Waivers exist. But only for clear errors or exceptional events, and you must apply within 30 days.
Then repetition changes the arithmetic. In March 2023, the RA fined Half Moon Investments Limited and its three directors USD 38,000. In August 2025, it fined them again. The total: USD 37,500 (about AED 137,700), including USD 10,000 on each director. Same company. Same directors. Same failure – twice! Our Half Moon case summary has the timeline.
Statutory Audit Means an ADGM Registered Auditor, Full Stop
The wording here is strict. A statutory audit of an ADGM entity must come from a Registered Auditor (a firm) or a Registered Audit Principal (an individual). Both must appear on the register. People search for ADGM approved auditors or approved auditors in ADGM. The official label is ADGM registered auditors. You can check them on the ADGM public register, under Auditors.
Why the fuss? Look at the RA’s audit monitoring report. It inspected seven audit firms in 2024. It found weak group-audit planning, weak partner review and going-concern gaps. Seven firms. Three recurring weaknesses. All published! So before you sign an engagement letter, confirm your ADGM auditors are on the register.
Ownership Records and AML Controls Are Now Tested With Data
Your UBO Records Must Be Adequate, Accurate and Up to Date, All Three
Priority 4 wants beneficial ownership information that is adequate, accurate and current. All three. The KPIs show how the RA will check: filing timeliness, data-validation exercises, fixes for inconsistencies, and escalation for repeat failures. The rule sits in the Beneficial Ownership and Control Regulations 2022. A beneficial owner holds 25% or more of the ownership or voting rights, directly or indirectly. Or is a natural person who controls the entity. Changes must reach the Registrar within 15 days.
The same transparency push drives UBO registration UAE rules onshore. But ADGM entities report to their own Registrar. So what should you check first? Whether your record matches who controls the entity today. Not at incorporation. Today. The RA’s legal persons and arrangements risk assessment explains why ownership data sits at the center of supervision.
DNFBP Assessments and Sanctions Compliance: The Checklist Is Already Public
Priority 7 covers DNFBPs. Real estate agents. Dealers in precious metals and stones. Lawyers, accountants and CSPs. The RA supervises their AML and targeted financial sanctions compliance under a delegation from the FSRA. Its KPIs count assessments completed, remediation plans agreed and enforcement referrals made. The rules sit in the ADGM AML Rulebook. It applies FATF standards and federal law to the DNFBP UAE perimeter inside the free zone.
The good news is that the RA already publishes a self-assessment form, an MLRO appointment checklist and a goAML registration guide. You can start there and If the gaps are wider than your expectations, our AML and compliance team is there to help you out in this situation.
The New Enforcement Frontier: Fake License Claims, Emerging Tech and Retail Conduct
Priority 9 goes after three things. Unlicensed activity. Activity beyond the scope of an ADGM license. And false or misleading claims about license status. The KPIs include prompt assessment of high-risk matters and public alerts where needed. So audit your website, pitch decks and LinkedIn page; anywhere you mention ADGM. Does your wording match what your license permits? Still waiting on your ADGM registration? Say that. Don’t write “ADGM-licensed.”
Emerging Technology and Retail Consumers Get Dedicated Oversight
Priority 5 brings risk-based oversight to emerging technology structures. Expect planned assessments and tech-enabled monitoring. The RA’s resources already cover DLT Foundations. Priority 6 is about retail. Complaints must be handled within target timeframes, and the RA will track retailer monitoring.
Both rest on ADGM regulations the RA already administers. Touch either area? Keep your risk assessments and complaints log ready.
The Upside for Well-Governed Firms: Credibility Is Becoming a Competitive Edge
The 2025-2026 report counted over 11,000 licensed persons. The new one cites more than 14,000 licensed entities. That is a lot more to supervise, so the RA is sorting by data. Firms that file on time and keep clean records get the payoff: a tidier ADGM company register and a jurisdiction the regulator calls trusted.
Everyone trading on the ADGM name benefits. The RA also calls its approach proportionate. Don’t read that as leniency. Read it as a reason to stay tidy.
Digital Supervision and Public Enforcement Outcomes Are Next
Priority 3’s KPIs mention Phase 1 of the RA’s digital, data-driven supervision. Priority 10 promises transparent enforcement. And the RA already publishes its regulatory actions. More data goes in. More outcomes come out.
The ADEPTS View: A 90-Day Plan to Be Inspection-Ready Before the Regulator Asks
Most firms don’t fail on intent. They fail on evidence. Strong corporate governance turns good intentions into minutes and registers a regulator can read. An internal controls review shows where a filing or ownership change could slip through.
Our internal audit ADGM work, accounting services in ADGM and tax services for ADGM companies keep your file ready. So ADGM compliance stops being a scramble. One caution. The audit opinion itself must come from a name on the register. We help you get the file ready for that sign-off.
A Priority-by-Priority Readiness Check
- Days 1-30: Diarize every filing, renewal and accounts date. Clear unpaid fines before they trigger a service restriction.
- Days 31-60: Reconcile your ownership record with the real chain of control.
- Days 61-90: Run an audit readiness review. Self-assess your DNFBP controls. Confirm your auditor is on the register.
Talk to ADEPTS About Your ADGM Filing, Audit and AML Readiness
Book a readiness call and we will map your gaps against all ten priorities.
Get Ahead of the Scorecard
The ADGM Registration Authority has stopped hinting. It now publishes the scorecard. Late filings, stale ownership records, weak audits and false license claims all have a KPI. So compliance in ADGM is no longer a calendar exercise. It is a body of evidence. You have time to build it. Ninety days is enough to start. Want a second pair of eyes? Our compliance team will test your readiness before the regulator does.
References
- Abu Dhabi Global Market. “ADGM Registration Authority Imposes Financial Penalties against Half Moon and Its Three Directors.” Announcement. Accessed October 2, 2026. https://adgm.com/media/announcements/adgm-registration-authority-imposes-financial-penalties-against-half-moon-and-its-three-directors.
- Abu Dhabi Global Market. “ADGM Registration Authority Publishes Enhanced Controls for Legal, Tax and Company Service Providers.” Announcement, October 16, 2025.
https://www.adgm.com/media/announcements/adgm-registration-authority-publishes-enhanced-controls-for-legal-tax-and-company-service-providers. - Abu Dhabi Global Market. “ADGM’s RA Imposes Financial Penalties of USD 37,500 against Half Moon Investments Limited and Its Three Directors concerning Accounts.” Announcement, August 26, 2025.
https://www.adgm.com/media/announcements/adgms-ra-imposes-financial-penalties-of-usd-37500-against-half-moon-investments-limited-and-its-three-directors-concerning-accounts. - Abu Dhabi Global Market. “ADGM’s Registration Authority Publishes Regulatory Priorities for 2026-2027.” Announcement, October 1, 2026.
https://www.adgm.com/media/announcements/adgms-registration-authority-publishes-regulatory-priorities-for-2026-2027. - Abu Dhabi Global Market. “Audit Monitoring Report.” ADGM Publications. Accessed October 2, 2026.
https://www.adgm.com/publications/ra-audit-monitoring-report. - Abu Dhabi Global Market. “Beneficial Ownership and Control.” Operating in ADGM. Accessed October 2, 2026. https://www.adgm.com/operating-in-adgm/obligations-of-adgm-registered-entities/beneficial-ownership-and-control.
- Abu Dhabi Global Market. “DNFBPs.” Operating in ADGM. Accessed October 2, 2026.
https://www.adgm.com/operating-in-adgm/financial-and-cyber-crime-prevention/dnfbps. - Abu Dhabi Global Market. “Find an Auditor.” Operating in ADGM. Accessed October 2, 2026.
https://www.adgm.com/operating-in-adgm/auditors/find-an-auditor. - Abu Dhabi Global Market. “Late Filings to the Registrar.” Operating in ADGM. Accessed October 2, 2026.
https://www.adgm.com/operating-in-adgm/monitoring-and-enforcement/late-filings-to-the-registrar. - ADGM Registration Authority. Regulatory Priorities 2025-2026. Abu Dhabi: Abu Dhabi Global Market, July 2025. https://assets.adgm.com/download/assets/RA%2BRegulatory%2BPriorities%2BReport%2B2025-26%2BSingle.pdf/7f30082e609011f09f3eca751c8b772c.
- ADGM Registration Authority. Regulatory Priorities 2026-2027. Abu Dhabi: Abu Dhabi Global Market, September 2026. https://assets.adgm.com/download/assets/RA+Regulatory+Priorities+Report+2026-2027.pdf/eaa4b7debcca11f18e5f869d6850a5d2.
Disclaimer: This article is for general information only, reflects ADGM sources available as of October 2, 2026, and is not legal advice. ADGM’s priorities report is itself a non-binding guide.
Related Articles
