ADGM Commercial Legislation Amendments (June 2026)
What Are the New ADGM Commercial Legislation Amendments?
The ADGM Registration Authority published fresh amendments to its commercial legislation on 26 June 2026. While some changes refine existing rules, others introduce new compliance obligations for ADGM companies, trusts, foreign branches, and designated non-financial businesses and professions.
For businesses operating in ADGM, this is more than a routine legislative update. The new measures introduce additional disclosure obligations, expand the Registrar’s authority to obtain beneficial ownership information, tighten controls around high-value cash transactions, and extend beneficial ownership requirements to registered branches of foreign legal entities. Together, these reforms reflect ADGM’s continued effort to align its corporate framework with evolving international transparency standards.
The June package also builds on the regulatory momentum established earlier this year. Following the amendment rounds issued on 24 April and 1 May 2026, the Registration Authority has continued refining ADGM’s commercial legislation instead of relying on isolated updates. The latest changes reinforce a broader programme of modernisation designed to improve regulatory oversight while keeping ADGM aligned with international best practices.
Among the most notable developments are four practical changes that businesses should understand:
- Public registers will now indicate whether a shareholder or director is acting in a nominee capacity.
- The Registrar has been given express powers to request beneficial ownership information relating to trusts connected with ADGM.
- Certain DNFBPs are prohibited from accepting or distributing cash above prescribed thresholds as part of enhanced AML controls.
- Registered branches of foreign legal persons must now maintain and provide beneficial ownership information relating to their foreign parent entity.
For affected businesses, the next step is straightforward: review nominee arrangements, beneficial ownership records, trust documentation, and branch reporting processes. As the amendments took effect upon publication, organisations should check the official ADGM Rulebook and address any compliance gaps without delay.
What Does Public Disclosure of Nominee Status Mean for ADGM Entities?
The ADGM commercial legislation amendments 2026 introduce a new transparency requirement under which the public register will indicate whether a shareholder or director is acting in a nominee capacity. Importantly, this does not make the identity of the underlying beneficial owner publicly available. Instead, it simply flags the existence of a nominee arrangement while the beneficial ownership information remains accessible only to the Registrar.
This marks a notable shift in how nominee arrangements are reflected within ADGM’s public corporate records. Previously, the public register listed a company’s directors and shareholders but did not indicate whether they were acting in a nominee capacity. The new rules introduce a nominee status flag, increasing transparency while keeping the identity of the ultimate beneficial owner (UBO) confidential and accessible only to the Registrar.
For businesses using nominee shareholders or directors in legitimate holding or investment structures, the change highlights the need to review existing arrangements. Companies should ensure nominee appointments are properly documented and supported by accurate beneficial ownership records to remain compliant with the updated disclosure requirements.
How Are Beneficial Ownership Rules for Trusts Changing?
The June 2026 amendments give the Registrar clearer powers to obtain beneficial ownership information where a trust has a connection to ADGM. In many cases, that connection may involve an ADGM trustee, an ADGM entity, or assets held through ADGM. What hasn’t changed is confidentiality—the information remains with the Registrar and is not published on the public register.
The latest changes give the Registrar express powers to obtain beneficial ownership information where a trust has a connection to ADGM. In practice, this may include trusts with an ADGM-based trustee, a settlor or beneficiary linked to an ADGM entity, or trust assets held through an ADGM company or legal arrangement. The objective is to ensure that ownership and control information can be accessed when required for regulatory supervision or compliance purposes.
Rather than introducing an entirely new reporting regime, these amendments build upon the Beneficial Ownership and Control (BOC) Regulations 2022. ADGM has already established a framework requiring legal entities to maintain accurate and up-to-date beneficial ownership records. The June 2026 amendments strengthen that framework by giving the Registrar clearer statutory authority to request information relating to trusts where appropriate.
The update also aligns with the broader direction of ADGM’s 2026 legislative reforms. Earlier amendments clarified that certain trust-related obligations depend on the location of the trustee, rather than simply the governing law of the trust. The latest changes continue that approach, ensuring the Registrar can obtain relevant beneficial ownership information whenever a trust has a sufficient connection to ADGM’s regulatory jurisdiction.
For trustees, family offices, foundations, and corporate service providers, the message is straightforward. Trust structures should be supported by complete and current beneficial ownership records, with documentation that can be produced promptly if requested by the Registrar. Organisations that administer trusts through ADGM may also wish to review their governance procedures to ensure they remain aligned with the evolving regulatory framework.
Learn more about how ADGM’s Beneficial Ownership and Control Regulations continue to evolve in our guide on ADGM Registration Authority Publishes Amendments to Commercial Legislation.
What New Cash Transaction Restrictions Apply to DNFBPs in ADGM?
The ADGM commercial legislation amendments 2026 introduce new cash transaction restrictions for certain Designated Non-Financial Businesses and Professions (DNFBPs). Under the updated licensing conditions, covered businesses are prohibited from accepting or distributing cash above prescribed thresholds, reinforcing ADGM’s commitment to stronger AML/CFT compliance and financial transparency.
The amendments apply to DNFBPs such as:
- Legal service providers
- Accounting firms
- Company service providers
- Real estate businesses
These sectors often deal with high-value transactions, making them more exposed to money laundering risks. Businesses should confirm the applicable cash threshold in the official ADGM Rulebook before updating internal policies.
The new restrictions reflect wider AML reforms across the UAE, including Federal Decree-Law No. 10 of 2025, and are consistent with the FATF’s approach to higher-risk sectors. Businesses should review their cash handling, customer due diligence, and AML procedures in light of the new rules.
How Do the Amendments Affect Registered Branches of Foreign Companies?
The ADGM commercial legislation amendments 2026 expand beneficial ownership obligations for registered branches of foreign legal entities. Branches must now maintain and provide beneficial ownership information relating to their foreign parent company, strengthening transparency across cross-border corporate structures.
Previously, branch-level obligations were more limited. The latest amendments extend the focus beyond the local branch by requiring businesses to identify and maintain records of the ultimate beneficial owners (UBOs) of the foreign parent entity.
For example, an overseas company operating through an ADGM branch can no longer rely solely on the details of its local branch manager or authorised signatories. It should also be able to identify and document the individuals who ultimately own or control the parent company.
Businesses should review their compliance processes to ensure they can readily provide:
- Beneficial ownership information for the foreign parent entity
- Supporting ownership and control documentation
- Updated records whenever ownership or control changes
If you’re establishing or managing an ADGM entity, explore The Ultimate Guide to Forming a Holding Company in ADGM (2026) for incorporation and ongoing compliance insights.
What Does This Mean for ADGM-Registered Businesses?
Every regulatory update brings new compliance considerations. ADEPTS advises ADGM companies, trusts, registered branches, and DNFBPs on beneficial ownership, corporate governance, and AML requirements to help them stay aligned with the latest rules.
| Action | Who Should Review |
| Review nominee shareholder and director arrangements | ADGM Companies |
| Update trust-related beneficial ownership records | Trusts and Foundations |
| Review cash-handling policies and AML controls | DNFBPs |
| Gather beneficial ownership information for foreign parent entities | Registered Branches |
As the amendments took effect upon publication, businesses should not assume a transitional grace period. Compliance should be treated as immediate, although organisations are encouraged to verify implementation requirements against the official ADGM Rulebook.
How ADEPTS Can Help
Keeping pace with regulatory change requires more than updating statutory records. It requires a practical compliance strategy. ADEPTS works with ADGM companies, trusts, registered branches, and DNFBPs to assess the impact of new regulations and implement the necessary changes.
Our team can assist with:
- ADGM company and branch compliance
- Beneficial ownership reviews and record updates
- AML/CFT policy reviews for DNFBPs
- Corporate governance and regulatory advisory
Whether you’re reviewing nominee arrangements, updating beneficial ownership records, or strengthening internal compliance procedures, ADEPTS provides practical guidance to help your business meet evolving ADGM requirements.
Conclusion
The ADGM commercial legislation amendments 2026 reinforce ADGM’s commitment to greater beneficial ownership transparency and stronger AML/CFT controls. Public nominee disclosure, enhanced trust-related beneficial ownership powers, new cash transaction restrictions for DNFBPs, and expanded branch reporting obligations represent the four key changes businesses should understand.
The June amendments are unlikely to be the last. As ADGM continues refining its regulatory framework, businesses should expect further updates to beneficial ownership and AML requirements. Regular compliance reviews will help avoid unnecessary regulatory issues.
References
- Abu Dhabi Global Market. (2026, June 26). ADGM Registration Authority publishes amendments to the commercial legislation.
https://www.adgm.com/media/announcements/adgm-registration-authority-publishes-amendments-to-the-commercial-legislation - Abu Dhabi Global Market. (2026). 26 June amendments to ADGM commercial legislation. Thomson Reuters ADGM Rulebook.
https://en.adgm.thomsonreuters.com/rulebook/26-june-amendments-adgm-commercial-legislation - Abu Dhabi Global Market. (2022). Beneficial Ownership and Control Regulations 2022. Thomson Reuters ADGM Rulebook.
https://en.adgm.thomsonreuters.com/rulebook/beneficial-ownership-and-control-regulations-2022 - Financial Action Task Force. (n.d.). International standards on combating money laundering and the financing of terrorism & proliferation (The FATF Recommendations). https://www.fatf-gafi.org
- United Arab Emirates. (2025). Federal Decree-Law No. (10) of 2025 regarding anti-money laundering, combating the financing of terrorism and proliferation financing.
https://uaelegislation.gov.ae/en/legislations/3314/download
