ADGM Virtual Asset Licence (FSRA)
Abu Dhabi Global Market (ADGM) is an international financial centre with its own regulator, the Financial Services Regulatory Authority (FSRA). The FSRA introduced one of the region's first virtual asset frameworks. Firms receive a Financial Services Permission (FSP) covering each regulated activity. VAF Global prepares the compliance framework and documentation that FSRA applications need.
Who needs this licence?
- Virtual asset exchanges and multilateral trading facilities
- Brokers and dealers in virtual assets
- Custodians of virtual assets
- Fund and asset managers with virtual asset strategies
- Firms seeking an internationally recognised common-law jurisdiction
- Issuers of fiat-referenced tokens (a separate FSRA regime) and firms using them
Common FSRA regulated activities for virtual assets
Operating a Multilateral Trading Facility
Running a trading venue for virtual assets.
Dealing in Investments as Principal or as Agent
Two separate activities: trading virtual assets on your own account with clients, or on behalf of clients.
Arranging Deals in Investments
Bringing about or facilitating transactions for clients.
Providing Custody
Safeguarding and administering client virtual assets.
Managing Assets
Discretionary management of client portfolios.
Advising on Investments or Credit
Advice on the merits of virtual asset investments.
Key requirements
- An ADGM entity (a company, or a branch where permitted) with real substance in ADGM
- Approved Persons for the mandatory Controlled Functions (such as Senior Executive Officer, Finance Officer, Compliance Officer and MLRO), with directors approved as Licensed Directors
- Regulatory capital under FSRA rules for the firm's activities, with specific requirements for virtual asset custodians and MTFs
- Only Accepted Virtual Assets: the firm assesses each asset against FSRA criteria and notifies the FSRA before use
- AML/CFT and sanctions framework meeting FSRA rules and UAE federal requirements
- Technology governance, cybersecurity and custody arrangements reviewed for virtual assets
- Business plan, financial projections and a regulatory business plan
The licensing process
- 1
Pre-application discussions
Meetings with the FSRA, including technology demonstrations, to present the business model and confirm the regulated activities.
- 2
Prepare the application
Assemble business plan, policies, financial projections and personnel forms.
- 3
Submission and review
The FSRA reviews the application and raises questions.
- 4
In-principle approval
Approval in principle, subject to conditions such as incorporation and capital.
- 5
Incorporation and conditions
Register the entity with the ADGM Registration Authority and meet outstanding conditions.
- 6
Final approval and launch testing
The FSP is granted on final approval; operational launch testing and third-party systems verification must be completed before going live.
How VAF Global helps
We prepare and run the compliance side of your licence, so your application meets the regulator's expectations from day one.
- Activity scoping and ADGM versus Dubai comparison
- AML/CFT, KYC and sanctions policies for FSRA
- Compliance monitoring programmes and risk assessments
- Support with approved-person readiness
- Outsourced MLRO and compliance support, where permitted
- KYT transaction monitoring
ADGM Crypto Licence (FSRA): FAQ
Is ADGM or VARA better for a crypto business?
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It depends on the business model, target clients and where your team will be based. ADGM is a common-law financial free zone regulated by the FSRA; VARA regulates virtual assets across Dubai outside the DIFC. We help you compare the two before you commit.
What is an FSP?
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A Financial Services Permission is the authorisation the FSRA grants to carry out specified regulated activities in or from ADGM.
Does the FSRA require local staff?
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Yes. Real substance in ADGM is expected, and the Senior Executive Officer, Compliance Officer and MLRO must be UAE-resident. The firm also needs adequate resources in ADGM for its activities.
Related insights
VARA, ADGM, DIFC or CMA? Choosing Your UAE Crypto Regulator in 2026
A plain-English comparison of the UAE's crypto regulators (VARA, ADGM's FSRA, the DFSA and the CMA) and how to choose the right one.
Read articleWhat Does an MLRO Do? Outsourcing the MLRO Role in the UAE
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Read articleOther UAE licensing guides
Last reviewed October 2026. This guide is general information for compliance planning, not legal advice. Regulatory requirements change; always confirm current rules with the regulator. VAF Global is a compliance consultancy and does not provide legal services.