The Riffle
The ADGM Registration Authority has issued its Annual Accounts Filing Checklist 2026, highlighting the key checks entities should complete before submitting their annual accounts.
The guidance reflects recurring issues identified during the 2024 filing cycle, with particular focus on entity and account accuracy, audit requirements and exemptions, and proper approval and signing of financial statements.
Key Highlights
1. Check the accounts before filing
Entities should ensure that the accounts being uploaded belong to the correct entity and represent the final, approved version.
Where group accounts are required, both group and standalone accounts must be submitted, unless a statutory exemption applies and has been properly disclosed.
The activities described in the financial statements should also align with those permitted under the entity’s commercial licence. For Special Purpose Vehicles (SPVs), this means remaining passive.
Complete comparative information should also be presented in accordance with IAS 1.
2. Confirm audit requirements and exemptions
Where an audit is required, the accounts must be audited by an auditor registered in ADGM and appointed in accordance with the Companies Regulations 2020.
Entities relying on a small company or other audit exemption should first confirm that they meet the applicable eligibility criteria.
Where an exemption is claimed, the required director statements must appear directly above the signature line on the balance sheet, together with all disclosures required under the applicable ADGM small or micro companies regime.
3. Get the formalities right
Accounts must be approved by the board of directors, and the balance sheet must be signed by a director. The date of board approval must also be clearly stated on the balance sheet.
Missing signatures or approval dates are simple but avoidable issues that can result in an incomplete filing.
If a material error is discovered after filing, or the wrong document has been uploaded, directors should promptly revise and re-file the accounts in accordance with the Registrar’s guidance on defective accounts.
Next Steps
Before submitting, entities should run a final verification across three areas: Entity, Audit and Signature.
Filing well ahead of the 30 September 2026 deadline is strongly recommended. Early submission provides time to identify and correct potential issues, while filing on the deadline leaves little room to address errors or queries.
Where there is uncertainty around exemption eligibility or specific accounts requirements, entities should seek appropriate professional advice before filing.
Important Dates
Financial year end: 31 December 2025
Annual accounts filing deadline: 30 September 2026
The Riffle Takeaway
For ADGM entities, annual accounts compliance goes beyond simply meeting the deadline. Getting the entity details, accounts, audit position, exemption disclosures, board approval, signature and dating right before submission can help avoid queries, rejected filings and unnecessary re-filing.
