Incorporate first. Add financial activities once the FSP is granted.
Important: This article presents an independent analysis and does not represent the official position of the Financial Services Regulatory Authority (FSRA) or of any other regulatory authority of the United Arab Emirates. The content set out herein does not constitute legal advice and is exclusively informational in nature, intended for business owners, executives and investors seeking to understand the regulatory framework applicable to licensed companies in the Abu Dhabi Global Market (ADGM).
Effective 2 November 2026, Abu Dhabi Global Market (ADGM) has introduced changes to the incorporation and licensing process for businesses intending to conduct regulated financial services activities.
The update, communicated by the ADGM Registration Authority, draws a clearer line between company incorporation, commercial licensing and regulatory authorisation by the Financial Services Regulatory Authority (FSRA).
What Has Changed?
Under the revised approach, financial services activities are no longer available for selection at the incorporation stage through the ADGM Registry portal.
Applicants who have received an In-Principle Approval (IPA) from the FSRA but are awaiting their Financial Services Permission (FSP) must now select only “Administrative Activities Ancillary to Office Set Up” (Activity Code 6400) during the incorporation process, instead of the financial services activity under licensing, as it was allowed before
The relevant regulated financial services activities may be added to the company’s commercial licence only after the FSRA has granted the necessary Financial Services Permission (FSP).
Importantly, this requirement applies not only to newly incorporated entities but also to existing ADGM companies seeking to transition from non-financial activities to regulated financial services activities through a variation of licensed activities notification.
IPA vs FSP: Why the Distinction Matters
In-Principle Approval (IPA) is an important stage in the FSRA authorisation process. It is a transitory approval, issued subject to pre-conditions that must be met before the FSP is granted.
However, IPA does not constitute permission to commence regulated financial services activities. An IPA holder must also not present itself as regulated by the FSRA until the FSP is granted, as ADGM reminded entities in October 2023.
Financial Services Permission (FSP) is the formal regulatory authorisation granted by the FSRA, permitting an entity to undertake the regulated activities specified in its permission, subject to applicable conditions.
Your Action Checklist
For businesses and Company Service Providers (CSPs):
- Know your stage. Confirm whether the FSRA has granted an IPA or the FSP.
- Sequence correctly. Use Activity Code 6400 only, and add financial services activities once the FSP is granted.
- Plan the variation. Keep the FSP ready as supporting evidence for any licence variation, and allow for it in project timelines.
- Keep records aligned. Keep records of FSRA approvals, and make sure licensed activities match regulatory permissions.
- Describe status accurately. Do not describe the entity as FSRA-regulated until the FSP is in place.
- Check before filing. CSPs should check authorisation status before submitting incorporation or variation applications.
How We Can Assist
As an ADGM licensed Company Service Provider, Banks Legal Limited supports clients with ADGM incorporation and licensing applications, including coordinating the timing of FSRA authorisation, commercial licensing and licence variations.
For further information on ADGM incorporation and licensing, please contact Banks legal Limited.
Contact Details
Email: admin@bankslegal.com
WhatsApp: +971 55 655 2447
