On 9 October 2026, ADGM's Financial Services Regulatory Authority opened a public consultation on revisions to two of its foundational rulebooks — the Fees Rulebook and the General Rulebook. The market has until 6 November 2026 to respond: a tight 28-day window.
What happened
The Financial Services Regulatory Authority (FSRA), the financial regulator of Abu Dhabi Global Market, published Consultation Paper No. 6 of 2026 — "Proposed Revisions to the Fees and General Rulebooks". It is a combined package: the regulator proposes amendments to the Fees Rulebook (FEES) and the General Rulebook (GEN) simultaneously, together with adjustments to General Prudential Management (GPM).
The package contains four documents: the consultation paper itself, Attachment 1 covering GPM amendments, Appendix 1 with FEES amendments, and Appendix 2 with GEN amendments. FSRA seeks feedback on all four, with particular emphasis on responses from Authorised Persons, Recognised Bodies and DNFBPs.
A week earlier, ADGM's Registration Authority had published its regulatory priorities for 2026–2027 — tighter reporting discipline and data-driven supervision. The fees consultation is the operational follow-through: the regulator is now pricing the cost of non-compliance and expanding the list of chargeable procedures. Broader context is in our overview of UAE business regulation in 2026.
Four blocks of fee changes
What exactly is being revised:
- Fees for Recognised Bodies and trading venue operators. ADGM is updating the fee schedule for market-infrastructure participants it recognises — exchanges, clearing houses, trading venue operators. This is fine-tuning: the revision reflects actual market conditions since the previous FSRA fee review.
- A new supervision fee for securities on the Official List. For the first time, FSRA is introducing a dedicated charge for supervising securities admitted to ADGM's Official List. Oversight of listed issuers has until now been funded through general fees — now there will be a dedicated line item.
- Higher penalties for late submission of regulatory returns. FSRA is raising the fees charged when regulated firms miss filing deadlines. The current base rate is USD 500 per late return (introduced in April 2022 after a separate consultation); the new figures will be published together with the final decision after 6 November.
- Clearer fees for variation of financial services. When an Authorised Person extends or narrows its list of permitted regulated activities (variation of financial services), a separate fee applies. The regulator is tightening its logic and, in line with the other proposals, moving toward more predictability for firms that frequently vary their scope.
Who is affected
Three categories of market participants in ADGM:
- Authorised Persons — holders of an FSRA licence to carry on regulated financial activities: banks, broker-dealers, asset managers, EMIs (electronic money institutions), custodians, financial advisers, VA providers (virtual assets).
- Recognised Bodies — recognised market infrastructure: exchanges, multilateral trading facilities (MTFs), clearing and settlement systems.
- DNFBPs — Designated Non-Financial Businesses and Professions in FATF terminology: lawyers, auditors, corporate service providers, real estate agents, dealers in precious metals and stones, where they are registered and fall within ADGM's AML regime.
In practice the reach is wider: anyone who files regular regulatory returns with FSRA and pays fees under the current Fees Rulebook is touched by at least one of the four package items. For firms with corporate banking in ADGM, the regulator's fee discipline is part of the overall compliance perimeter; our breakdown of the UAE corporate bank account covers the parallel bank-side requirements.
How to submit comments
FSRA accepts written responses by email at fsra.consultation@adgm.com. The format is free-form; the regulator expects a position on each discussed block, with reasoning and, where relevant, an estimate of the regulatory burden on the firm.
The full document pack — the consultation paper, Attachment 1 (GPM amendments), Appendix 1 (FEES amendments) and Appendix 2 (GEN amendments) — is published on the ADGM Public Consultations page and in the ADGM rulebook on the Thomson Reuters platform. The pack is openly downloadable, no login required.
The hard deadline is 6 November 2026. The consultation's status is Open. After that date, FSRA will consider the responses and publish the final version of the amendments. Based on prior rounds (CP4/2023 on a similar topic), the final document typically appears 2–4 months after the window closes.
What this means for ADGM-based firms
Three practical takeaways:
- Review the 2027 fee budget. For Authorised Persons and Recognised Bodies, the new schedule will take effect once final amendments are published — build the current actual payment volume into the budget, plus a conservative buffer for the revision.
- Tighten regulatory filing discipline now. Higher penalties for late filings are the most sensitive item for firms with chronic reporting delays. An internal audit of the filing calendar and of accountable individuals is the minimum rational response.
- Submit a comment if the changes touch your business model. FSRA public consultations are not a formality: in CP4/2023 the regulator reflected part of the market's feedback in the final text. For firms with non-standard service structures or frequent variation of financial services, engaging in the consultation is a lever on the final tariff.
Garant will track the consultation and publish the final fee figures as soon as FSRA decides.
