UAE ADGM Digital Assets Framework

The framework applies across several asset and activity categories rather than treating all tokens as a single product. Virtual Assets are addressed as digitally transferable value used for exchange, account, or store-of-value functions, while digital tokens that exhibit the characteristics of a security are treated as securities. FRTs are addressed separately through dedicated rules for issuance and regulated activities involving tokens referencing fiat value.

ADGM also regulates derivatives over digital assets and collective investment funds investing in digital assets through existing FSRA categories for derivatives and fund units. This activity-based structure means the same underlying token may receive different treatment depending on the product, function, service, and regulated activity involved.

The ADGM framework is directed primarily at FSRA-authorised market operators, multilateral trading facilities, brokers, custodians, asset managers, intermediaries, FRT issuers, and other firms conducting regulated activities involving digital assets. The FSRA’s 2020 amendments moved the virtual-asset regime from a bespoke “Operating a Crypto Asset Business” model to the underlying regulated activities, including custody, trading venue operation, dealing, and other financial services.

Under the updated Virtual Asset guidance, authorised persons conducting VA regulated activities must work with Accepted Virtual Assets and maintain governance processes for asset assessment, website publication, and ongoing monitoring. The guidance identifies regulatory requirements across capital, anti-money laundering and counter-financing controls, technology governance, virtual-asset risk disclosures, market-abuse controls, transaction reporting, custody, MTF operations, application processes, and fees.

The June 10, 2025 amendments streamlined the process for accepting Virtual Assets in ADGM, refined capital requirements and fees, introduced a specific product-intervention power for Virtual Assets, and confirmed the FSRA’s approach to the prohibition of privacy tokens and algorithmic stablecoins within ADGM.

The FRT framework developed in stages. FSRA rules for FRT issuance were published in December 2024. On October 31, 2025, the FSRA finalized amendments for regulated activities involving FRTs, including its approach to accepting FRTs for use in ADGM, expanding the activities that may be carried on in relation to FRTs, and rules for authorised persons that hold or control client FRTs. Those amendments took effect on January 1, 2026.

On April 29, 2026, the FSRA finalized a regulatory framework for staking Virtual Assets after consultation. The framework identifies categories of authorised persons permitted to conduct staking activities using client VAs and sets requirements governing such activities, including targeted changes on non-proof-of-stake models with similar characteristics, reward limits, key terms, client disclosures, and client reporting.

This profile should be reviewed against the latest ADGM and FSRA Rulebook notices before publication because the framework is updated through amendments, guidance, consultation outcomes, and notices rather than a single consolidated digital-assets statute.