ADGM Tightens Beneficial Ownership, Nominee and Trust Transparency Rules
The Registration Authority of Abu Dhabi Global Market (ADGM) has amended its commercial legislation in several rounds during 2026. The changes align ADGM with international anti-money laundering standards and took effect on publication.
May 2026 amendments
- Trusts: the location of the trustee, rather than the governing law of the trust, determines which beneficial ownership obligations apply.
- Non-profit purposes: foundations and trusts can no longer be set up for purposes that fall within ADGM's definition of non-profit organisations.
- Bearer shares: expressly prohibited.
- Filing deadlines: clarified under the Companies Regulations.
- Licensing: the Commercial Licensing Rules have been replaced with new 2026 Rules.
July 2026 amendments
- Nominee disclosure: the public register will show whether a shareholder or director is acting as a nominee.
- Trust information: the Registrar can request beneficial ownership information on trusts connected to ADGM.
- Foreign branches: ADGM branches of foreign companies must keep and provide beneficial ownership information on their foreign parent.
- Cash restrictions: certain professional businesses, including legal, accounting, company service and real estate firms, cannot accept or pay cash above set thresholds.
What ADGM entities should do
- Check that registers of shareholders, directors and beneficial owners are complete and current
- Confirm nominee arrangements are properly documented and disclosed
- Review foundation and trust purposes against the new rules
- For branches, collect beneficial ownership information on the foreign parent
Official source: ADGM - Amendments to the Commercial Legislation (May 2026) | ADGM - Amendments to the Commercial Legislation (July 2026)