A round of changes to ADGM’s commercial legislation puts more of a company’s real ownership within reach of the register and the Registrar. Here is what has changed, who it affects, and the practical steps worth taking.
On 26 June 2026, the Abu Dhabi Global Market Registration Authority published a further set of amendments to its commercial legislation. The headline items read as technical adjustments, but they share a common purpose: reducing the space between what a company’s records show and who actually owns and controls it.
For anyone using ADGM as a base for a holding company, a fund vehicle, a branch or a professional practice, these are worth reading properly rather than filing away. The changes took effect on publication, and several of them move work onto the entity itself.
Nominee arrangements become visible
The public register will now indicate whether a shareholder or director is acting in a nominee capacity. This does not prohibit nominee arrangements, which remain a legitimate feature of many ownership structures. What changes is visibility. The fact that a person holds shares or a board seat on someone else’s behalf will be apparent from the register, while the underlying beneficial ownership details continue to sit with the Registration Authority rather than being published.
For structures that use nominees for privacy, the distinction is worth understanding. Privacy over the identity of the ultimate owner is largely preserved. The existence of a nominee relationship is not.
Trusts come within closer reach
The Registrar has been granted express powers to request beneficial ownership information for trusts connected to ADGM. Trust arrangements have long been harder to see through than direct company ownership, and this narrows that gap. Trustees and advisers with ADGM-connected structures should expect that information on settlors, beneficiaries and controlling parties can be called for, and should make sure it is current and defensible before the request arrives.
A cash ceiling for professional firms
Certain designated non-financial businesses and professions, including legal, accounting, company service and real estate firms, are now prohibited from accepting or making cash payments above prescribed thresholds. This is a familiar anti-money-laundering control in other major jurisdictions, and its arrival in ADGM follows the same logic. Firms in these categories should check their client-money and settlement practices against the new limits rather than assuming existing processes already comply.
Branches can no longer sit outside the ownership regime
Branches of foreign legal persons registered in ADGM will be required to maintain and provide beneficial ownership information relating to their foreign parent. A branch is not a separate legal entity, and some groups have used the branch route in part because it carried lighter obligations than a locally incorporated company. That gap has closed. Where a foreign parent operates through an ADGM branch, the parent’s ownership now forms part of what the branch must be able to show.
The wider direction of travel
None of this is happening in isolation. Since the UAE’s removal from the FATF grey list in February 2024, the pattern across its financial centres has been to keep tightening rather than ease off. ADGM issued earlier amendment rounds in April and May 2026 before this one. The signal is that transparency standards are a permanent condition of operating in the jurisdiction, not a requirement that was met once and set aside.
Read together, the June changes point in one direction. Ownership information that was previously implicit, held privately, or spread across a foreign parent is being drawn onto the record and made available to the Registrar. The obligation to keep that information accurate and available rests with the entity.
What to do now
The practical steps are straightforward. Review your beneficial ownership records and confirm they reflect the current position. Check that any nominee arrangements are correctly recorded and that you are comfortable with their appearing on the register. If you operate through an ADGM branch, confirm that beneficial ownership information for the foreign parent is available and up to date. If your firm falls within the affected professional categories, review how you handle cash against the new thresholds.
Alpadis administers ADGM-registered entities and branches for clients across the UAE, maintaining statutory and beneficial ownership records, handling corporate secretarial obligations and coordinating filings with the Registration Authority. Where changes like these land, the advantage of having records already in order is that compliance becomes a review rather than a scramble.
