ADGM

Regulated Activities in ADGM Under the FSRA

2026-04-08 · 6 min read · By Aureus Worldwide

Regulated activities in ADGM are the financial services that a firm may only carry on with authorisation from the Financial Services Regulatory Authority (FSRA). If your business will do any of them by way of business in or from the Abu Dhabi Global Market, you need a Financial Services Permission first. Knowing exactly which regulated activities you will conduct is the single most important early decision, because it determines whether you need authorisation at all, which permission to seek, your prudential category and your capital. This guide walks through the main regulated activities under ADGM's rules and how to think about the perimeter.

What makes an activity regulated

ADGM's financial-services perimeter is set by the Financial Services and Markets Regulations (FSMR), which specify the activities that count as regulated. Three questions decide whether you are caught:

1. Is what you do a specified regulated activity? The activities are defined in the regulations, dealing, managing, advising, custody, insurance and so on.
2. Is it carried on in relation to a specified investment (or, for some activities, another regulated subject such as an accepted virtual asset)? Specified investments include shares, debentures, units in funds, options, futures and other instruments.
3. Is it carried on by way of business? One-off or purely incidental acts may fall outside the perimeter; doing something regularly and commercially generally brings it in.

If all three point the same way, you need a permission. Because the analysis is technical and the consequences of getting it wrong are serious, it is done with regulatory counsel. Our overview of FSRA authorisation in ADGM sets out what authorisation then involves.

The FSRA's regulated activities at a glance

The regulated activities group naturally into families:

Each activity maps to a prudential category and to the controlled functions the firm must staff, the connective tissue explained in our note on FSRA prudential categories.

Deposits, credit and dealing

Accepting Deposits is bank business and sits in the highest prudential category. Providing Credit, lending in the course of business, and Dealing in Investments as Principal, where the firm trades against its own book, both carry meaningful capital. Dealing in Investments as Agent or as Matched Principal, where the firm executes for clients without taking directional risk, sits lower. The distinction between principal and agent dealing is not cosmetic: it changes the risk the firm runs and therefore the capital it must hold.

Managing, advising and arranging

This is where most of ADGM's asset-management and advisory community lives:

• Managing Assets, running client portfolios on a discretionary basis.
• Managing a Collective Investment Fund, the core activity of a fund manager, covered in our guide to becoming an FSRA-authorised fund manager.
• Advising on Investments or Credit and Arranging Deals in Investments, recommending or bringing about transactions without taking discretion or principal risk.

Advising and arranging generally attract the lowest base capital, which is why they are a common entry point for smaller firms, though the conduct-of-business and AML obligations still apply in full.

Custody, insurance and market infrastructure

Providing Custody, Providing Trust Services and Acting as Trustee of a Fund involve safeguarding assets and carry duties around segregation and control. Insurance breaks into effecting and carrying out contracts of insurance (insurers themselves, under the separate PIN prudential regime), Insurance Intermediation and Insurance Management. At the top of the market sit the infrastructure activities, Operating a Multilateral Trading Facility, an Exchange or a Clearing House, which are the most heavily supervised because a failure affects the whole market.

Virtual assets under the FSRA

ADGM was one of the earliest jurisdictions worldwide to build a comprehensive framework for virtual assets. Conducting a regulated activity in relation to accepted virtual assets, operating a virtual-asset exchange (a Multilateral Trading Facility), providing custody, dealing, arranging, advising or managing, requires FSRA authorisation. A virtual asset is treated as a commodity rather than a security, but that does not put it outside the perimeter; the activities around it are regulated, and tokenised securities are regulated separately as digital securities. Our guide to ADGM's virtual asset framework covers this in depth.

Professional and Retail clients

A firm's permission is only half the picture; who it deals with shapes its obligations too. ADGM operates a client-classification regime that distinguishes Professional Clients, those who meet the FSRA's tests of assets, experience or expertise, from Retail Clients, who receive the fullest protections. Many firms choose to deal with Professional Clients only, because serving retail investors brings additional conduct, disclosure and suitability requirements. The classification is not a formality: a firm must assess and document each client's category and treat them accordingly, and dealing with retail investors without the requisite permissions and controls is a serious failing.

Two firms, two perimeters, an example

To see why scoping matters, compare two ventures. A boutique that only advises family offices on investments and never touches their money is likely a Category 4 firm with the lightest capital, but it still needs a permission and full AML controls. A firm that manages those same portfolios on a discretionary basis, or holds client assets, crosses into different regulated activities, a higher prudential category and heavier obligations, even though, to the client, both firms look like they simply help with investments. The perimeter turns on what you actually do, not on how the service is described.

Staying on the right side of the perimeter

Two mistakes are common. The first is assuming a commercial licence is enough, it is not, if the activity is a regulated financial service. The second is scoping the permission wrongly, either too narrowly (so the firm cannot do what it planned) or too broadly (so it carries capital and obligations it does not need). Exclusions exist, for example for certain intra-group arrangements or activities carried on with or for a single family office, but they are specific and should be relied on only after checking. The safe approach is to map your intended activities against the regulated-activity list with regulatory counsel before you apply, then match the permission, prudential category and staffing to that map. Our DIFC and ADGM service helps you frame this analysis.

How Aureus Worldwide can help

Aureus Worldwide is a Dubai-based accounting, tax, CFO and compliance-advisory firm. Where the regulatory perimeter falls is a matter for regulatory counsel. Where we add value is around the authorised business: preparing the financial projections and accounting that support an application, providing outsourced CFO and Finance-Officer support, framing AML processes for firms whose activities carry money-laundering risk, and keeping tax and audit-ready reporting on track alongside your appointed auditor. To build the finance and compliance foundation behind a regulated ADGM business, contact us.

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