Abu Dhabi Global Market (ADGM) has enacted a cluster of rule changes this spring that reshape how digital-asset businesses, family offices and exempt vehicles operate on Al Maryah Island. Below is a practitioner-focused tour of the four key instruments now in force.
Digital-Asset Framework Overhaul – 10 June 2025
A fresh FSRA announcement details amendments that tighten the Virtual-Asset regime while shortening time-to-market for compliant tokens. The headline reforms include a self-assessment path for recognising Accepted Virtual Assets (AVAs), a ban on privacy-enhancing coins and algorithmic stablecoins, and capital buffers that scale with client-asset value. Firms must also be prepared for an FSRA “product-intervention” order that can freeze trading in a specific token across the market. FSRA announcement (adgm.com)
Two companion notices provide the black-letter text: the updated FSRA Rules (Digital Assets), and separate Amendments to FSRA Regulations and Fees Rules (Digital Assets). Together they embed the new AVA definition, fee schedule and capital formula directly into the ADGM Rulebook. FSRA Rules (Digital Assets) (en.adgm.thomsonreuters.com) | Amendments to FSRA Regulations and Fees Rules (en.adgm.thomsonreuters.com)
Legal take-away: boards of authorized persons now bear explicit liability for the robustness of their AVA assessments and must evidence ongoing monitoring of each token’s legal and technical attributes.
Single-Family Office Threshold Reduction & EDB Exemption – 1 May 2025
A 1 May notice cuts the minimum asset threshold for single-family offices (SFOs) established in ADGM and removes the requirement for the Eurasian Development Bank (EDB) to hold a commercial license. This widens access to ADGM’s family-office platform while carving out a bespoke exemption for a multilateral financial institution. 1 May notice (adgmen.thomsonreuters.com)
Legal take-away: families looking to consolidate assets under ADGM supervision must revisit constitutional documents to align with the reduced threshold, while counterparties dealing with the EDB can rely on the order for license exemption comfort.
Commercial Licensing Regulations (Exemptions) Order 2025 – 10 April 2025
Published on 10 April, the Commercial Licensing Regulations (Exemptions) Order 2025 refreshes the list of activities that are not required to hold an ADGM commercial license, including certain philanthropic foundations and intra-group service entities. Commercial Licensing Regulations (Exemptions) Order 2025 (en.adgm.thomsonreuters.com)
Legal take-away: existing SPVs and foundations should confirm whether the new exemptions change their ongoing license obligations and, if so, update corporate filings accordingly.
Practical Checklist for Regulated Firms and Counsel
- Token Due-Diligence Files: map every listed token against the new AVA criteria; de-risk holdings of privacy coins and algorithmic stablecoins.
- Capital & ICAAP Re-runs: recalculate buffers using the asset-linked formula; reflect changes in the next Internal Capital Adequacy Assessment Process submission.
- Governance Minutes: document board approval of AVA self-assessment methodologies and any reliance on external technical opinions.
- Family-Office Constitutions: adjust SFO business plans and shareholder agreements to reflect the lowered asset threshold.
- License Registers: cross-check group entities against the revised exemptions in order to avoid unnecessary renewal fees or, conversely, inadvertent unlicensed activity.
These measures, adopted in good time, will help organizations stay aligned with ADGM’s evolving rule set and mitigate enforcement risk in the months ahead.
