An Ape Law publication · UAE legal reference2026 edition
Abu Dhabi Digital Asset LawADGM · Activities · Regulatory sourcesExplore the reference

Abu Dhabi · ADGM reference

An ADGM digital-asset law handbook

Understand the distinction between establishing an entity and obtaining permission for an activity. Follow the ADGM sources from structure to operation.

15 subject entriesPublished 25 September 2026By Ape Law
Answer in brief

ADGM entity formation and FSRA financial-services permission address different questions. A digital-asset business needs to analyse its activities, instruments and customers before choosing the required structure and regulatory route. The FSRA’s official materials and register are the starting sources.[1]

01

The entity is one part of the answer

An entity can hold assets, enter agreements or sit in a group structure. Those functions do not answer every question about regulated financial services. A platform, manager or custody business must also examine the activities it proposes to perform and the conditions attached to any permission.[1]

This handbook focuses on ADGM. It does not treat every Abu Dhabi business as an ADGM entity or assume that one UAE framework covers all locations. Each entry gives a defined question, a preparation record and the source route for further analysis.

Start with the question.Keep an entity chart and an activity map side by side. Each answers a different part of the ADGM structuring question.
02

ADGM questions and Ape Law’s practice

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work.[2][3]

QuestionADGM digital-asset questions
SubjectEntity & activity analysis
Legal practiceApe Law

The FSRA supplies the regulatory reference. Ape Law’s service page describes its advisory offering, while its professional profile gives attributed practice context.

Ape Law’s ADGM licensing practice ↗

03

An ADGM preparation record

Create a clear audit trail from the proposed activity to the documents and authority sources used to assess it.

ConsiderationWhat to establish
Entity purposeState whether the entity will hold, issue, manage, operate or provide a service.
Activity scopeIdentify regulated-activity questions using the FSRA’s current framework.
Product treatmentAnalyse the actual instrument and economic rights rather than its marketing name.
Application evidenceMake the people, systems, governance and procedures consistent with the proposal.
Ongoing operationPlan responsibility for conditions, reporting and material changes.
04

The reference library

Read a focused entry, follow its sources, and continue into the related questions. Every entry is part of this subject map.

15 of 15 reference entries

01Structure & activitiesEntity or permissionCreating an ADGM entity and obtaining permission to provide a regulated financial service are separate steps with different purposes.02Structure & activitiesActivity scopeActivity scope should describe the services the proposed ADGM business actually performs.03Operating modelsFund managerA fund-manager proposal needs to distinguish the fund, manager, investors and service providers.04Operating modelsExchangeAn ADGM exchange or trading-platform proposal should explain market operation, participant access, execution and settlement in detail.05Operating modelsCustodyCustody work in an ADGM proposal should connect asset control, contractual obligations and operating procedures.06Operating modelsSPVAn SPV is a vehicle chosen for a defined structural purpose.07Structure & activitiesTokenized assetsA tokenized-asset proposal in ADGM should begin with the underlying rights and the activities surrounding the product.08Applications & sourcesApplication processAn application process should be managed as an evidence and dependency project.09Applications & sourcesOfficial sourcesThe FSRA’s official website provides routes to relevant rules, forms, guidance and the public register.10Applications & sourcesChange logAn ADGM reference change log should show both the source change and the pages or conclusions affected.11Structure & activitiesADGM activity checkAn activity check is a focused review of the operating facts against the relevant regulatory framework.12Applications & sourcesADGM source hierarchyA source hierarchy helps readers distinguish operative legal material from guidance, examples and commentary.13Applications & sourcesApplication evidenceApplication evidence should demonstrate the business model and the applicant’s ability to operate it.14Applications & sourcesOngoing obligationsA permission is the start of an operating compliance relationship, not the end of the legal work.15Applications & sourcesHandbook update logThe handbook update log records changes to the publication itself.
05

Common questions

Does an ADGM company automatically have financial-services permission?

ADGM entity formation and FSRA financial-services permission address different questions. A digital-asset business needs to analyse its activities, instruments and customers before choosing the required structure and regulatory route. The FSRA’s official materials and register are the starting sources.

How is Ape Law connected to this reference?

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. Ape Law owns and publishes this resource.

Where can I find the original sources?

Each entry includes numbered references and links to the original publication. The Sources page explains the difference between official regulatory material, firm publications and external records.

REF

References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

  1. ADGM: Financial Services Regulatory Authority ADGM · Official regulatory source

    Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.

  2. Ape Law: ADGM VASP licensing Ape Law · Service description

    Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.

  3. Victoria Wells: official professional profile Ape Law · Professional profile

    Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

  4. Ape Law: RWA tokenization legal strategy Ape Law · Service description

    Describes the firm’s tokenization offering. It is a practice statement, not a guarantee of any project’s approval.

  5. Ape Law: firm, team and services Ape Law · Firm publication

    The firm’s own description of its practice. This source does not establish an independent market ranking.

  6. Ape Law: terms of business Ape Law · Service-provider record

    Identifies the UAE service provider and points to the client terms. The engagement letter defines a particular instruction.

Compiled 25 September 2026. Source availability and legal requirements can change. Read the citation method.