The Riffle
The Abu Dhabi Global Market (ADGM) Registration Authority (RA) has issued new guidance in October 2026, establishing a clearer regulatory framework for Crypto Mining activities conducted in or from ADGM.
Issued under Section 23 of the Commercial Licensing Regulations 2025, the guidance distinguishes between commercial blockchain validation activities and regulated financial services, providing greater clarity on licensing, operational requirements, and regulatory oversight.
The framework adopts a technology-neutral approach, covering Proof-of-Work (PoW), Proof-of-Stake (PoS), and other blockchain validation mechanisms.
Key Highlights
1. Crypto Mining Classified as a Commercial Activity
Crypto Mining is classified as a non-financial commercial activity under ADGM Business Activity Code 7230. Operators conducting mining or validation for their own account require an RA Commercial Licence but do not automatically require Financial Services Regulatory Authority (FSRA) approval.
2. Clear Boundaries Between RA and FSRA Regulation
The guidance distinguishes between different operational models:
Own-account mining and non-custodial infrastructure: Regulated by the RA under the commercial licensing framework.
Custodial staking and third-party asset management: Require FSRA authorisation alongside an RA Commercial Licence.
Pooled or intermediated staking: May constitute regulated financial activities, requiring FSRA consultation and potentially additional permissions.
3. AML/CFT Regulatory Treatment
Pure Crypto Mining conducted for an operator's own account does not constitute a Virtual Asset Service Provider (VASP) activity and falls outside the formal VASP AML/CFT regulatory framework.
However, entities providing third-party custody, asset administration, or safeguarding services may trigger applicable AML/CFT obligations.
4. Governance and Operational Requirements
Licensed operators must maintain appropriate corporate governance, beneficial ownership disclosures, cybersecurity controls, physical security measures, and business continuity arrangements.
Cybersecurity frameworks should align with recognised international standards, including ISO 27001 and NIST.
5. Enhanced Licensing and Disclosure Requirements
Applicants must provide detailed operational plans covering infrastructure, energy efficiency, security arrangements, and risk management.
They must also disclose blockchain wallet and smart contract addresses used to receive or manage mining rewards. Material structural changes must be reported to the RA, while disclosed reward-flow information remains confidential.
6. Oversight of International Mining Operations
ADGM-registered operational headquarters overseeing overseas mining facilities must disclose their international operations, assess host-jurisdiction risks, conduct due diligence on partners, and maintain appropriate governance standards across their global operations.
Significant overseas compliance breaches and regulatory actions must also be reported to the RA.
7. Risk-Based Supervision and Enforcement
The RA will adopt a risk-based supervisory approach involving ongoing monitoring, inspections, independent verification, and on-chain oversight.
Non-compliance may result in financial penalties, remediation requirements, or suspension or revocation of commercial licences.
Why It Matters
The guidance provides greater regulatory certainty for businesses exploring crypto mining and blockchain validation activities within ADGM.
Importantly, it establishes that the nature of an operator's activities, particularly whether third-party assets are involved, determines the applicable regulatory requirements.
Businesses should assess their operating models, establish the appropriate licensing structure, strengthen governance and security controls, and ensure that any activities crossing into financial services are appropriately authorised.
Riffle Takeaway
ADGM's new guidance establishes a clearer distinction between commercial crypto mining and regulated digital asset services.
By introducing defined licensing boundaries, enhanced transparency requirements, and stronger governance expectations, the framework supports the responsible development of blockchain validation activities while reinforcing regulatory accountability.
