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Abu Dhabi's sandbox with serious ambitions. ADGM is quietly becoming one of the more interesting fund domiciles in the Middle East. Common-law framework, English-language documentation, and a regulator that actually picks up the phone. We cover FSRA licensing, fund structuring in Abu Dhabi Global Market, and what makes ADGM different from DIFC.
Fund structuring
ADGM is proposing to exempt properly structured employee investment vehicles from fund licensing and minimum subscription rules. The details matter — one ineligible participant can blow up the entire structure.
Regulatory
The FSRA proposed two new fund manager categories in late 2025: Sub-Threshold for managers under $200M, and Institutional for those targeting $5M+ tickets. Here is what changes and why it matters.
Tax
The UAE's 9% corporate tax does not have to apply to your ADGM fund. Qualifying Free Zone Person status preserves 0% — but the conditions are strict and the compliance is ongoing.
Operations
ADGM mandates specific service provider appointments for every fund — fund administrator, custodian, and corporate service provider. New proposals tighten local nexus requirements further.
Regulatory
ADGM's Category 3C licence is the gateway for fund managers in Abu Dhabi. A proposed sub-threshold framework could cut capital requirements and approval times in half for emerging managers.
Fund structuring
Choosing between an Exempt Fund and a Qualified Investor Fund in ADGM is not a technicality. The minimum subscription threshold — $50,000 or $500,000 — shapes your investor base, your fundraise, and your admin costs.
FSRA regulatedInternational recognitionTax-efficientSetup: 4–6 weeks