The Riffle
The Abu Dhabi Global Market (ADGM) has introduced one of its most significant commercial legislative updates in recent years. Published on 26 June 2026, the amendments strengthen transparency, modernise operational requirements, align LLP governance with company law, and raise compliance expectations for professional service providers operating within the jurisdiction.
While several amendments are administrative in nature, many have practical implications for companies, LLPs, trusts, branches, and regulated service providers.
Key Highlights
1. Stronger Beneficial Ownership and Transparency Requirements
ADGM has expanded its beneficial ownership framework to improve transparency across different legal structures.
Key changes include:
Trusts connected to ADGM may now be required to disclose beneficial ownership information.
Companies must disclose nominee directors and nominee shareholders to the Registrar.
Foreign company branches must comply with beneficial ownership obligations through their overseas parent entity, as branches themselves are not separate legal persons.
2. Supplementary Operating Addresses (SOAs) Introduced
One of the most practical changes is the introduction of the Supplementary Operating Address (SOA).
An SOA allows an ADGM-licensed business to operate from additional approved locations within ADGM without establishing a separate branch or obtaining another commercial licence.
The Registrar retains discretion to approve, suspend or revoke SOAs where appropriate.
This provides businesses with greater operational flexibility while maintaining regulatory oversight.
3. LLP Rules Now Closely Aligned with Company Regulations
The new LLP Rules significantly modernise the governance framework for Limited Liability Partnerships.
Among the notable changes:
LLPs now follow standardised rules for contracts, deeds and official seals.
Residential address protections have been introduced for LLP members.
LLPs must prepare accounts using recognised accounting standards.
New financial reporting thresholds now apply for micro, small and medium-sized LLPs.
4. Higher Standards for Professional Service Providers
ADGM has introduced stricter licensing requirements for legal, tax, accounting and company service providers.
These include:
Mandatory professional indemnity insurance.
Enhanced “fit and proper person” assessments.
Experience requirements for senior professionals.
Independent MLRO and Compliance Officer appointments for Company Service Providers (CSPs).
5. New Cash Transaction Restrictions
To strengthen anti-money laundering controls, certain professional service providers—including legal, tax, audit, real estate and CSP firms—may no longer accept or distribute cash for transactions exceeding USD 3,000.
The amendments also strengthen record retention obligations and expand the Registrar’s enforcement powers, including branch strike-off procedures where entities are no longer carrying on business.
Other Notable Changes
The legislative package also introduces several additional reforms, including:
ESG reporting requirements for large LLPs meeting prescribed turnover or assets under management thresholds.
Explicit recognition of registered email addresses for statutory notices and filings.
New penalties for providing false or misleading information in licensing matters.
Why This Matters
These amendments reflect ADGM’s continued focus on aligning its commercial framework with international best practices.
For businesses, the reforms introduce greater operational flexibility through Supplementary Operating Addresses while simultaneously increasing expectations around governance, transparency, AML compliance, and professional standards.
Entities operating in ADGM should review their existing structures, beneficial ownership records, licensing arrangements, governance processes, and compliance frameworks to ensure they remain aligned with the new requirements.
The Riffle Take
The June 2026 amendments represent more than a routine legislative update, they signal ADGM’s continued evolution as a mature international financial centre. By balancing greater business flexibility with stronger governance and transparency requirements, ADGM is reinforcing confidence in its regulatory environment while raising the compliance bar for firms operating within its jurisdiction.
