Crypto Law Profile

ADGM FSRA Regulation of Virtual Asset Activities in ADGM

ADGM FSRA guidance and rulebook framework for virtual asset activities in ADGM, covering FSP authorisation, Accepted Virtual Assets, custody, AML/CFT, technology governance, disclosures, MTFs and market conduct.

Abu Dhabi Global Market Effective Agency guidance Jun 25, 2018

At a glance

Status In force in ADGM; current Rulebook guidance version dated Jun. 10, 2025.
Regulator Administered by the ADGM Financial Services Regulatory Authority.
Permission model VA firms need an FSP and relevant FSRA approvals for covered activities.
Asset gate VA Regulated Activities may use only Accepted Virtual Assets.

Overview

The ADGM FSRA Regulation of Virtual Asset Activities in ADGM is the Financial Services Regulatory Authority’s current guidance for the virtual asset regime in Abu Dhabi Global Market. The current Rulebook version is dated June 10, 2025, and the guidance states that it is issued under section 15(2) of the Financial Services and Markets Regulations 2015 and should be read with FSMR, FSRA rulebooks and related digital asset guidance. It applies primarily to applicants for a Financial Services Permission, Authorised Persons conducting a virtual asset regulated activity, and Recognised Investment Exchanges permitted to operate a multilateral trading facility in relation to virtual assets.

The profile below treats the instrument as agency guidance supporting a broader binding framework. The guidance says the applicable ADGM regulations and FSRA rules governing virtual assets, together with the guidance, form the “Virtual Asset Framework.” It is not presented as standalone legal advice or as an exhaustive statement of FSRA policy.

Key provisions of the ADGM virtual asset framework

The framework regulates virtual asset activity through existing financial services permissions and activity-specific FSRA approvals. At present, the guidance identifies virtual asset regulated activities as dealing in investments as principal, dealing in investments as agent, advising on investments or credit, arranging deals in investments, managing assets, providing custody, and operating a multilateral trading facility. Chapter 17 of the Conduct of Business Rulebook applies to Authorised Persons conducting virtual asset regulated activities, with additional requirements for MTF operators and virtual asset custodians.

  • Authorisation and permissions: Firms conducting virtual asset regulated activities in or from ADGM must hold the relevant FSP and satisfy applicable FSMR and FSRA rulebook requirements.
  • Accepted Virtual Assets: Authorised Persons may conduct a virtual asset regulated activity only with an Accepted Virtual Asset. The 2025 guidance shifts the assessment to the Authorised Person, requires notification to the FSRA no later than five business days before use, and requires a public list of Accepted Virtual Assets used by the firm.
  • Risk controls: The framework addresses AML/CFT and sanctions, consumer protection, technology governance, exchange-type activities, and custody. The guidance highlights controls for wallets, private keys, origin and destination of virtual asset funds, security, risk management, settlement, transaction recording and custody reconciliation.

Accepted Virtual Assets and market conduct

The June 2025 version gives detailed criteria for assessing an Accepted Virtual Asset. Those criteria include traceability and monitoring, security, market profile, exchange connectivity, distributed ledger infrastructure and ecosystem, innovation or efficiency, and practical functionality. The guidance also expects governance arrangements, recordkeeping and continuous monitoring so that an asset continues to satisfy the relevant criteria.

Market conduct rules apply where Accepted Virtual Assets are admitted to trading on an MTF. The guidance states that ADGM’s market abuse provisions cover market abuse behaviour relating to Accepted Virtual Assets traded on an MTF, requires transaction reporting by MTFs, and applies misleading-statement provisions to Accepted Virtual Assets. MTFs are also expected to maintain exchange-like controls such as market surveillance, fair and orderly trading processes, settlement processes, transaction recording, rulebooks and transparency mechanisms.

Status and timeline

ADGM launched its original crypto asset regulatory framework on June 25, 2018, covering spot crypto asset activities by exchanges, custodians and other intermediaries. The terminology and framework have since evolved, including the shift from “crypto assets” to “virtual assets,” later updates to the guidance, and 2025 amendments focused on Accepted Virtual Assets, capital requirements, fees, product-intervention powers, privacy tokens and algorithmic stablecoins.

As of June 16, 2026, the June 10, 2025 Rulebook version remains the relevant profile baseline identified for this law page. Editors should separately track related ADGM developments, including the FSRA’s April 29, 2026 announcement finalising a framework for virtual asset staking, because those developments may affect related rulebook obligations even where the core virtual asset guidance page is unchanged.

Key provisions

Financial Services Permission

Applicants must hold the relevant FSP and obtain FSRA approval for covered VA activities in or from ADGM.

Licensing Jun 25, 2018 Source

Accepted Virtual Assets

VA Regulated Activities may be conducted only with Accepted Virtual Assets assessed under COBS 17.2.2 and notified to FSRA before use.

Asset assessment Jun 10, 2025 Source

AML/CFT and sanctions controls

The framework applies AML, sanctions and tax-reporting controls, including attention to origin and destination of VA funds.

AML/CFT Jun 25, 2018 Source

Custody and technology governance

VA custodians and other firms must address wallets, private keys, reconciliation, security, outages, outsourcing and forks.

Custody Jun 25, 2018 Source

MTF market conduct

Accepted Virtual Assets traded on MTFs are subject to market-abuse, transaction-reporting, surveillance and disclosure expectations.

Market abuse Jun 25, 2018 Source

Timeline

  1. Public consultation closed

    FSRA closed consultation on a proposed spot crypto asset framework for exchanges, custodians and intermediaries.

    Under consultation Source
  2. Original framework launched

    ADGM launched its crypto asset framework and published guidance for crypto asset activities in ADGM.

    Enacted Source
  3. Virtual asset terminology update

    FSRA updated the framework, including terminology from crypto assets to virtual assets.

    Enacted Source
  4. Guidance updated

    Rulebook version history shows an updated guidance version from Sep. 28, 2022.

    Enacted Source
  5. Guidance updated

    Rulebook version history shows a further guidance version from Dec. 18, 2023.

    Enacted Source
  6. Digital asset amendments proposed

    FSRA issued Consultation Paper No. 11 of 2024 on proposed digital asset framework amendments.

    Under consultation Source
  7. 2025 amendments implemented

    FSRA implemented digital asset amendments and updated the VA guidance with immediate effect.

    In force Source
  8. Staking framework finalised

    FSRA announced a finalised framework for staking of Virtual Assets, a related VA framework development.

    In force Source

Who it affects

Actors

Abu Dhabi Global Market, ADGM Financial Services Regulatory Authority

Asset classes

Accepted Virtual Assets, Fiat-referenced tokens, Virtual assets

Official sources

Editorial note

This profile covers the FSRA Virtual Asset Framework as described in the current guidance, together with the underlying FSMR and FSRA rulebooks referenced by the guidance. Treat the guidance as regulator guidance supporting binding ADGM rules, not as standalone legal advice.