Coinbase Just Made Abu Dhabi Its Global Tokenization Base — And That Says More About the UAE Than About Coinbase
You have probably seen the Coinbase–Abu Dhabi headline already. The question now is not what Coinbase announced. It is what this changes for businesses, investors and fund managers in the UAE.
Here is the short answer: Coinbase has received Financial Services Permission from ADGM’s Financial Services Regulatory Authority (FSRA) to arrange deals in investments and provide custody for tokenized securities.
The permission creates a regulated route for this activity; it is not automatic approval for every tokenized product Coinbase may launch.
That distinction is easy to miss. It is also where the story becomes more interesting. The licence, ADGM’s regulatory structure and the first Apple-linked issuance together show how Abu Dhabi intends to turn tokenization from an experiment into financial infrastructure.
Abu Dhabi handed Coinbase something no other financial centre has managed to hand anyone
The 11 August permission is narrow by design: arranging investment deals and custody. It does not give Coinbase an open-ended right to issue any tokenized security it chooses.
Under ADGM’s official digital-assets framework, a digital token with the characteristics of a security is regulated as a security. In Coinbase’s model, the tokens are backed by underlying shares. Eligible holders can receive the associated economic rights, including dividends, while voting rights depend on the terms of each prospectus.
Coinbase’s pitch is simpler: an investor could access these instruments through a wallet rather than the usual brokerage and correspondent-banking chain.
But on-chain does not mean outside compliance. ADGM’s framework still addresses financial crime, custody, market integrity and investor protection, while transfers remain subject to sanctions controls.
That is the important development for tokenization UAE: blockchain is being brought inside regulated capital markets rather than being allowed to operate beside them.
Why ADGM won this, when Coinbase could have picked anywhere
This did not start in 2026. The FSRA introduced its crypto-asset regulatory framework in June 2018, covering exchanges, custodians and other intermediaries. Eight years later, that head start matters.
ADGM also offers something technology alone cannot provide. The ADGM free zone directly applies English common law, has its own Registration Authority and independent ADGM Courts. Its Listing Authority is built around transparent markets and investor confidence.
Brett Tejpaul’s argument goes to the remaining gap: tokenized equities need to remain regulated securities while also operating as blockchain-native assets capable of interacting with on-chain finance.
ADGM’s Chief Market Development Officer Arvind Ramamurthy has similarly described its framework as supporting “responsible innovation across custody, trading, and tokenisation.”
In our view, that is why the Coinbase decision matters. The UAE is no longer competing simply on regulatory flexibility or on where someone can obtain a crypto license UAE. It is offering a regulatory product: law, licensing, custody, market oversight and enforcement designed to work together.
The Apple certificate is the template, and it tells you what comes next
The Apple CB Certificate turns that regulatory theory into a structure.
Coinbase Onchain SPV Ltd, an ADGM special purpose vehicle incorporated in June 2026, is issuing certificates representing beneficial interests in Apple common stock under an FSRA-approved prospectus.
The architecture is simple: SPV + prospectus + custody.
That matters because it is repeatable. Once the legal and regulatory route has been established, the underlying equity can change without rebuilding the entire structure from zero.
The ADGM SPV is therefore relevant beyond Coinbase. UAE investors and businesses already use SPVs for holding companies, real estate, funds and family investments. Tokenization introduces another potential application.
For anyone considering an SPV Abu Dhabi structure, the Apple certificate is worth watching for one reason: it gives us an early view of how regulated tokenized ownership may actually be built.
And equities may only be the first asset class to test that model.
What actually opens up for UAE businesses over the next 12 months
The opportunity is not to put every asset on-chain. It is to use regulated tokenization where it can improve capital access, ownership or distribution. The global real world asset tokenization market is already above $30 billion, while only about $2.47 billion was active in DeFi in May 2026 — showing how far regulated issuance still sits from open on-chain use.
| Area | Possible today | What could develop next |
| Private companies | Traditional equity/SPVs | Tokenized capital raising |
| Real estate | Funds and fractional structures | Wider digital distribution |
| Private credit | Loans and private funds | Tokenized issuance and settlement |
| Family offices | Direct/fund investments | Smaller fractional exposures |
| Fund managers | Conventional distribution | Wallet-based distribution |
A second opportunity sits underneath these assets: custody, KYC, sanctions controls, accounting and reporting technology.
In our view, private credit, fund distribution and supporting compliance services are the most realistic near-term opportunities. Tokenized real estate Dubai structures may follow. Fully permissionless trading of tokenized equities is more likely to take longer.
The tax question none of the headlines are asking
Tokenization does not create a separate UAE tax regime. VAT and Corporate Tax follow the underlying asset, transaction and service. This matters because the FTA expressly excludes financial securities from its virtual-asset definition. Coinbase’s tokenized shares therefore cannot simply be given the same VAT treatment as cryptocurrency.
Cabinet Decision No. 100 of 2024 and FTA Public Clarification VATP040 exempt transfers and conversions of qualifying virtual assets retrospectively from 1 January 2018. Fee-based custody, management, platform, advisory or structuring services require separate analysis. “Regulated” does not mean “VAT-free”.
The FTA has also published Directive on Tax Transactions No. 3 of 2026, prescribing how digital-currency consideration is converted into AED for VAT reporting.
Corporate Tax is separate again. The standard rate is 9% above AED 375,000, while an ADGM entity receives 0% only on qualifying income if the Qualifying Free Zone Person conditions are met. The FTA’s Free Zone guidance confirms that the free-zone location alone is not enough.
Accounting also follows substance: cryptocurrencies may fall within IAS 38, while tokenized securities may fall within financial-instrument standards depending on the rights involved. We explain the VAT distinction further in our guide to tokenized assets, digital securities and UAE VAT.
CARF lands in 2027, and this hub is what makes that date real
The UAE Ministry of Finance has signed the CARF Multilateral Competent Authority Agreement. UAE implementation begins in 2027, with the first automatic exchanges expected in 2028.
CARF brings transaction reporting and customer due diligence into international tax transparency. Exchanges, brokers and other in-scope crypto-asset service providers may need to identify users and their tax residence and report relevant exchanges and transfers.
Depending on structure, the framework can reach more than conventional cryptocurrency; the OECD specifically recognises crypto-form securities, staking-related transfers and certain decentralised services within the wider framework.
That means CARF UAE readiness is not simply an IT exercise. It is a governance and data problem: who owns the information, how tax residence is validated, and whether transaction data can actually be reported.
The hub opens in 2026. Reporting starts in 2027. Those systems need to be designed now. Our UAE Corporate Tax, VAT and CARF guide covers the wider compliance position.
Our read: what we think happens next
The next 12 months should show whether Abu Dhabi has created a genuine market or simply a strong first structure.
Our first expectation is a response from DIFC. We would expect the DFSA to further develop its approach to tokenized securities as competition between the UAE’s financial centres moves deeper into digital capital markets.
ADGM should also attract more issuers. Private credit and investment funds are likely to move before mass-market equities because the commercial case is easier to establish and the investor base is more controlled.
Banks and institutional custodians will be the next important piece. If at least one major UAE bank announces a meaningful tokenized-securities custody or settlement partnership within the next year, that would materially strengthen the market.
Tax guidance should evolve as well. With CARF implementation approaching in 2027, we expect more UAE guidance around the reporting and tax treatment of digital assets and tokenized structures.
There are reasons to remain cautious. Liquidity is still uncertain, integration with traditional markets takes time, and regulatory approval does not guarantee investor demand. The technology may move faster than the market around it.
What we would tell a client sitting in this space today
For businesses already active in digital assets, the priority should be getting the existing structure ready before adding another product. That means reviewing VAT treatment, making sure CARF data can actually be captured, and settling the IFRS accounting position before it becomes an audit issue.
Businesses considering ADGM company formation should look beyond incorporation. Substance, tax status, banking, regulatory permissions and reporting obligations need to work together. ADGM registration is only one step in that process.
For businesses still watching, there is no need to move simply because Coinbase has. The better approach is to identify the trigger that would justify action: clearer regulation, proven liquidity, a relevant asset-class launch or a commercially viable use case.
In our experience, setting up the entity is usually the easier part. Aligning the legal structure with tax, accounting and compliance requirements is where most of the real work begins.
How ADEPTS works with businesses on this
ADEPTS supports businesses assessing ADGM SPV and holding-company structures, including Corporate Tax and QFZP assessments, VAT reviews, IFRS classification, audit readiness and CARF reporting preparation.
The objective is not simply to establish an entity. It is to determine whether the proposed structure works from a regulatory, tax and financial-reporting perspective before commitments are made.
FAQs
No. The permission covers specified regulated activities. Individual products may still require separate regulatory approvals and prospectus requirements.
Not automatically. Economic and voting rights depend on the structure of the certificate and the terms of the relevant prospectus.
Not automatically. The FTA excludes financial securities from the virtual-asset definition, so the VAT treatment depends on the underlying instrument and the service being supplied.
No. The 0% rate applies only to Qualifying Income where the entity meets the Qualifying Free Zone Person conditions.
In-scope businesses need systems capable of identifying reportable customers, tax residence and relevant crypto-asset transactions before reporting begins.
Potentially, yes. But establishing an SPV does not itself authorise regulated tokenization activity. The intended activities and required permissions must be assessed separately.
References
- Abdou, Mahmoud. “UAE Signs Multilateral Competent Authority Agreement on the Automatic Exchange of Information under the Crypto-Asset Reporting Framework.” Ministry of Finance – United Arab Emirates, 20 Sept. 2025, https://mof.gov.ae/en/news/uae-signs-multilateral-competent-authority-agreement-on-the-automatic-exchange-of-information-under-the-crypto-asset-reporting-framework/.
- ADGM Courts – Unique Digital Transformation of Justice and Legal Services. 20 May 2024,
https://www.adgm.com/adgm-courts. - ADGM Launches Crypto Asset Regulatory Framework. 25 June 2018,
https://www.adgm.com/media/announcements/adgm-launches-crypto-asset-regulatory-framework. - Authority, Federal Tax. “Federal Tax Authority Issues Corporate Tax Guide on Free Zone Persons.” Federal Tax Authority – Media Centre, https://tax.gov.ae//en/media.centre/news/federal.tax.authority.issues.corporate.tax.guide.on.free.zone.persons.aspx
- Coinbase Establishes Its Tokenization Hub in Abu Dhabi, with Financial Services Permission from the Financial Services Regulatory Authority (FSRA). 8 Nov. 2026,
https://www.adgm.com/media/announcements/coinbase-establishes-its-tokenization-hub-in-abu-dhabi-with-financial-services-permission-from-the-financial-services-regulatory-authority. - Digital Assets. 21 Aug. 2024, https://www.adgm.com/business-areas/digital-assets.
- Matos, Gino. RWA Tokenization Boom Exposes DeFi Composability Gap. 18 May 2026,
https://cryptoslate.com/rwa-tokenization-defi-composability-gap/. - Registration Authority. 22 May 2024, https://www.adgm.com/registration-authority.
- The Requirements for Registration and Deregistration of Entities for the Purposes of Cabinet Decision No. 142 of 2024 on the Imposition of Top-Up Tax on Multinational Enterprises.
https://tax.gov.ae//Datafolder/Files/Pdf/2026/legislation/FTA%20Decision%20No.%2012%20of%202026%20on%20Registration%20and%20Deregistration%20Timelines%20-%2008%202026.pdf. - VAT Public Clarification Amendments to the Executive Regulation of Federal Decree-Law No. 8 of 2017 on Value Added Tax – 2017 ) ( Cabinet Decision No. 100 of 2024. https://tax.gov.ae//Datafolder/Files/Pdf/2025/VATP040%20-%20Amendments%20to%20VAT%20ER%20-%2014%2003%202025.pdf.
