On 9 July 2026 the Registration Authority of Abu Dhabi Global Market (ADGM RA) published a package of amendments to the free zone's commercial legislation. The changes are about ownership transparency, stronger anti-money-laundering and counter-terrorist financing (AML/CFT) standards, and the way lawyers, auditors, corporate service providers and real-estate agents handle cash. All amendments are effective on publication.
What actually changed
ADGM RA is the companies registrar for the Abu Dhabi Global Market free zone, operating under its own common-law-based legal framework. The 9 July package focuses on four targeted but practically sensitive blocks.
1. The public register now flags nominee shareholders and directors
Under the revised rules, the ADGM public register indicates whether a shareholder or director is acting in a nominee capacity. It is a step toward greater transparency of corporate ownership and control structures — a direction anchored in FATF standards and regional regulatory practice.
For existing companies it means one thing: if the ownership structure includes a nominee that was kept in the non-public layer, that fact becomes publicly visible. The value of a properly documented nominee declaration, correctly tied to the ultimate beneficial owner, goes up accordingly.
2. Broader powers to obtain UBO information on trusts
The Registrar has been granted express powers to request beneficial-ownership information relating to trusts connected to ADGM. Previously the scope of information the Registrar could pull from trust structures was narrower; the new version gives the regulator an explicit right to obtain the full UBO chain for any trust with an ADGM link — settlor, trustee, protector and beneficiaries.
For trust arrangements where ADGM is the trustee's jurisdiction or where an asset sits in ADGM, this adds an obligation to keep UBO records current and to hand them to the Registrar on request.
3. Cash-payment restrictions on lawyers, auditors, corporate agents and real-estate agents
New licensing conditions prohibit certain professions in the Designated Non-Financial Businesses and Professions (DNFBP) category — law firms, audit and accounting practices, corporate service providers (agents that incorporate and administer companies) and real-estate agents — from accepting or distributing cash payments above prescribed thresholds. The specific threshold is set out in the amended Rules as the prescribed threshold.
The rationale is standard AML: payments above the threshold move into the banking channel with full identification of payer and payee, closing the main practical channel for structuring (smurfing).
4. UBO requirements extended to branches of foreign legal persons
Branches of foreign legal persons registered in ADGM are now required to maintain and provide UBO information not only about themselves but also about their foreign parent entity. Previously this requirement did not apply directly to branches; the Registrar can now request the full UBO chain via the branch.
The practical effect is that the foreign parent must be ready to hand its branch up-to-date information on ultimate beneficial owners — otherwise the branch cannot satisfy a Registrar's request.
Who is impacted first
- ADGM companies that use nominees. Nominee structures remain lawful, but they stop being non-public. Internal documentation — nominee agreement, declaration of trust, UBO form — needs to be in place and current.
- Trusts and trust services in ADGM. Rebuild UBO registers across the full chain of trust participants and check the process for handing the data to the Registrar.
- Law firms, auditors, accounting practices, corporate service providers and real-estate agents in ADGM. Update internal payment intake and disbursement policies, fix the threshold in SOPs, move the payment flow into the banking channel.
- Branches of foreign companies in ADGM. Agree with the parent office a regular UBO-refresh channel and prepare a UBO passport for the parent entity.
How this fits into the broader UAE picture
The ADGM amendments are part of the UAE's continuing push to strengthen its AML/CFT regime: after the country's removal from the FATF grey list in February 2024, the UAE has continued to close out the remaining pockets of risk. UBO registers have been tightened on the mainland side (Cabinet Decision No. 58/2020 and follow-on acts), the CBUAE has raised DNFBP-supervision expectations, DIFC has synchronised its Regulations. In that logic, ADGM RA updating its own commercial framework is not an isolated move but the next step in a joined-up direction.
For a business choosing a jurisdiction it means the standards inside the country are converging in practice: the gap between DMCC, IFZA, Meydan, DIFC and ADGM free zones on UBO and AML is narrowing, and the real differences shift onto other axes — cost, licence scope, banking access. The wider regulatory outline for 2026 is covered in our guide to UAE business regulation in 2026: what actually changed.
What an ADGM company should do right now
- Reconcile with the register. Open your ACCESSADGM record and check how shareholders and directors are currently reflected and whether nominee status is flagged. If a nominee is used de facto but not documented in the register, tidy it up.
- Refresh the UBO pack. Bring UBO declarations up to date for the company, the trust (if any) and — for branches — the parent, including source-of-funds if internal policy calls for it.
- Revisit the cash policy. If the company is a law firm, an accounting or audit practice, a corporate service provider or a real-estate agent in ADGM: fix the payment threshold in the SOP, allow only the banking channel or card, ban cash disbursement above the limit, and lock in the client KYC step.
- Review contracts and mandate letters with clients for references to payment channels and client due-diligence requirements.
- Run internal training. Front office and compliance need to know the new thresholds and be able to explain them to clients without improvisation.
The official amendment text and the updated versions of the acts are available via the Legal Framework section on adgm.com. The ADGM Registration Authority press release describing the key changes was published on 9 July 2026.
This article is for information only and is not legal, tax or compliance advice. Verify the exact cash-payment thresholds, the scope of UBO information that may be requested and the parameters of nominee disclosure against the current version of ADGM's commercial legislation and, where needed, with a qualified adviser.
