ADGM’s Digital-Asset Rulebook Overhaul — Key Legal Changes Effective 10 June 2025

Abu Dhabi Global Market’s Financial Services Regulatory Authority (FSRA) has completed the most far-reaching rewrite of its crypto rules since 2018. A notice published on 10 June 2025 confirms that the Board has enacted a new suite of rules and companion amendments that now sit inside the core ADGM rulebooks.(en.adgm.thomsonreuters.com) The changes are already in force, so existing licence-holders must read and apply them without delay. 

 

What actually changed?

 

Accepted Virtual Assets (AVA) and listing self-assessment 

 Authorized Persons that operate trading venues or brokerage desks may now perform an internal AVA test and list a qualifying token once they have filed the prescribed notification; the FSRA retains a 20-business-day window to object. The definition and the test methodology appear in the updated Conduct of Business Rulebook (COBS VER18.100625).(en.adgm.thomsonreuters.com) 

Product-intervention power 

 The Financial Services and Markets (Amendment No. 1) Regulations 2025 insert a new section into FSMR that allows the Regulator to halt dealings in a specified virtual asset across ADGM—mirroring the FSRA’s securities-market intervention tool.(en.adgm.thomsonreuters.com) 

Token-type exclusions 

 Privacy-enhancing coins and algorithmic stablecoins are expressly prohibited under the same COBS amendments. Tokens that lose AVA status become “non-permitted” and must be delisted immediately.(en.adgm.thomsonreuters.com) 

Capital and liquidity recalibration 

Digital-asset custodians, brokers and exchanges must now calculate minimum capital as a percentage of client-asset value, not revenue. The formula and related liquidity tests live in the revised Prudential – Investment, Insurance Intermediation and Banking Rulebook (PRU VER16.100625).(en.adgm.thomsonreuters.com) 

Fund-manager flexibility 

Updates to the Fund Rulebook (FUNDS VER10.100625) now allow Qualified Investor Funds and venture strategies to hold a wider range of virtual assets—provided each holding is an AVA and the manager maintains a live compliance file evidencing that assessment. 

Revised fee schedule 

The FSRA Fees Rules (FEES VER19.100625) introduce a new AVA-notification fee and update annual supervision fees for virtual-asset service providers. 

 

Practical implications for license-holders

    • Board-level accountability. A firm that self-certifies a token as an AVA must record the rationale in board minutes and keep the evidence up to date. If the FSRA later disagrees, directors may face enforcement for inadequate governance. 
    • Token-inventory housekeeping. Custodians and trading venues should map their books against the new prohibition list and delist or divest any non-compliant coins. 
    • Capital-planning stress tests. Because buffers are now linked to client-asset balances, businesses must run forward projections for high-volume trading days to avoid inadvertent breaches. 
    • Disclosure upgrades. Offering documents for funds and brokerage Ts&Cs must disclose the risk that a token could fail the AVA test or be frozen under the intervention power. 
    • Documentation hygiene. AVA assessment methodologies, liquidity-stress models, and revised fee assumptions should be embedded into internal manuals and compliance monitoring programmes. 

 

Transitional relief and timeline

The notice provides no formal grace period: the amended rules took effect on publication (10 June 2025). However, the FSRA has indicated—informally—that firms demonstrating “reasonable progress” toward compliance within the first 90 days will be treated proportionately. That leeway is pragmatic, not guaranteed, and does not excuse material breaches.(en.adgm.thomsonreuters.com) 

 

Next steps for market participants

  1. Run an immediate gap analysis against the new AVA criteria and prohibited-token list. 
  2. Update ICAAP and liquidity frameworks to reflect the PRU capital changes. 
  3. Refresh public disclosures and client agreements in light of the intervention power. 
  4. File the new fee forms if you are launching or relisting tokens after 10 June 2025. 

By weaving these requirements into existing governance and compliance structures, firms can continue to innovate in digital assets while remaining aligned with ADGM’s strengthened rulebook. 

 

Disclaimer

The opinions expressed in this blog are those of the respective authors. ATB Legal does not endorse these opinions. While we make every effort to ensure the factual accuracy of the information provided in our blogs, inaccuracies may occur due to changes in the legislative landscape or human errors. It is important to note that ATB Legal does not assume any responsibility for actions taken based on the information presented in these blogs. We strongly recommend taking professional advise to ensure the best possible solution for your individual circumstances.

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