The Riffle
The Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM) has issued Consultation Paper No. 6 of 2026, proposing amendments to its Fees Rulebook, General Rulebook and Guidance and Policies Manual.
The proposals complete the review of market infrastructure fees deferred during the FSRA’s earlier fee assessment. They also introduce annual supervision fees for listed securities, increase charges for overdue regulatory filings and clarify expectations around changes in control and variations of permission.
For trading venues, recognised bodies, listed entities and other regulated businesses, the consultation has implications for budgets, reporting controls and business expansion plans. These remain proposals, with implementation targeted for 1 January 2027, subject to the applicable rulemaking process and FSRA Board approval.
Key highlights
Higher market infrastructure fees: Base MTF/OTF application fees would increase from US$10,000 to US$100,000, with annual supervision fees rising from US$10,000 to US$40,000.
Specialist venue totals retained: Combined application and annual supervision fees for MTFs/OTFs involving Virtual Assets, Fiat-Referenced Tokens or Spot Commodities would remain US$125,000 and US$60,000, respectively.
Recognised body increases: An RIE or RCH would pay US$150,000 for an application and US$100,000 annually. Dual recognition would attract fees of US$300,000 and US$200,000, respectively.
New listing supervision fee: An annual charge of US$1,000 per class of securities admitted to the Official List is proposed.
Escalating late filing fees: The initial charge would double to US$1,000, with further charges taking the cumulative fee to US$3,000 for continued delay.
Closer scrutiny of licensing changes: Substantial changes in control could attract fees equivalent to a new authorisation. The FSRA would generally decline applications to add regulated activities within 12 months of initial licensing, subject to exceptional cases.
Feedback deadline: Comments are invited by 6 November 2026.
What is proposed, and what should firms do next?
Market infrastructure operators: Reassess 2027 application and supervision budgets, including the impact of higher fees for MTFs, OTFs, RIEs and RCHs.
Listed entities: Identify each class of securities admitted to the Official List and budget for the proposed annual charge.
Compliance teams and DNFBPs: Strengthen filing controls. Proposed late fees would apply on the first, eleventh and twenty-first business days after a deadline, with continued non-compliance potentially escalated to Enforcement.
Applicants and acquirers: Define intended activities and ownership structures early. Transactions involving substantial changes to control, governance or business models could face additional scrutiny and fees.
Finance and regulatory teams: Review responsibility for filing deadlines, regulatory invoices and payment procedures, including the standard 20-business-day payment period.
Conclusion
CP6/2026 would raise the cost of authorising and supervising certain market infrastructure businesses while introducing a recurring listing charge and stronger financial incentives for timely regulatory reporting. Its licensing guidance also places greater emphasis on the substance of acquisitions and the accuracy of initial business plans.
Affected firms should assess the proposals before the consultation closes on 6 November 2026. The proposed January implementation leaves a short preparation window if the amendments are adopted.
The Riffle takeaway
Budget for the proposed fees, tighten filing controls and plan licensing scope early. The consultation connects regulatory charges with the work required to supervise firms. Trading venues and recognised bodies should assess their 2027 costs, while compliance teams and applicants should review how reporting deadlines and business changes are managed.
Sources: supplied executive briefing on ADGM FSRA CP6/2026; FSRA consultation announcement dated 9 October 2026.
