ADGM's expansion to Al Reem Island

Most financial free zones grow by building. ADGM grew by absorbing an existing district — which is a different exercise, because Al Reem Island already had businesses on it operating under Abu Dhabi mainland licensing.

The instrument was UAE Cabinet Resolution No. 41 of 2023[ADGM RA — Al Reem guidance note], and the milestone date ADGM marks is 24 April 2023[ADGM — Our Jurisdiction]. The practical consequence was that ADGM's legal and regulatory framework became applicable across the island, and every business there needed an ADGM licence to continue.

ADGM began transitional arrangements from 1 November 2023 and set a deadline of 31 December 2024[ADGM RA — Al Reem guidance note].

The transition is over. There is no longer an “Al Reem question” for a new business: if you are establishing on either island you are establishing in ADGM, on the same terms, under the same licence categories and the same published fees.

What remains useful about the history is the scale it produced. A financial centre of 14.38 million square metres — around 1,438 hectares — is a materially different proposition from a single office district, particularly for a business that needs actual premises rather than a registered address.

Businesses moving from an ADDED licence into ADGM had two routes, and they are not two ways of doing the same thing. They produce different entities.

Continuation

ADGM describes continuation as a transfer of incorporation. The legal form is not intended to change; what changes is the place of registration[ADGM RA — Al Reem guidance note]. ADGM calls it a convenient way to change the company's nationality — moving it from one jurisdiction into another while the company continues to exist and its business dealings continue uninterrupted[ADGM RA — Al Reem guidance note].

What carries across, in ADGM's own terms[ADGM RA — Al Reem guidance note]:

• All property and rights the company was entitled to immediately before the certificate of continuance continue to be its property and rights.
• All criminal and civil liabilities, and all contracts, debts and other obligations it was subject to, continue to apply.
• Pending legal proceedings may be continued by or against the company.

That second bullet is the one to sit with. Continuation is not a fresh start — it carries the liabilities over with the assets. If there is a dispute or an outstanding obligation on the ADDED entity, it follows the company into ADGM. That is exactly what you want if you are protecting contracts and banking relationships, and exactly what you do not want if you were hoping the move would leave something behind.

The certificate of continuance, once issued, is conclusive evidence that the company has migrated and is formed under ADGM Companies Regulations. The ADGM incorporation certificate for a continuing business contains the former licence details[ADGM RA — Al Reem guidance note] — so the history is on the face of the document, which is generally helpful when a bank asks why the entity looks new.

New registration

New registration creates a new legal entity or branch that never existed before, and its registration date marks the start of its lifecycle[ADGM RA — Al Reem guidance note].

Clean, but it means novating contracts, reopening bank accounts, reissuing visas and rebuilding trading history from zero. See opening an ADGM bank account.

If you take the continuation route, there is a hard prerequisite that sits outside ADGM entirely.

ADDED licensees on Al Reem choosing Continuance to ADGM are required to obtain a No Objection Certificate from ADDED confirming eligibility to apply. ADGM states plainly: without the NOC, the application will not be accepted by ADGM RA[ADGM RA — Al Reem guidance note].

And obtaining it requires clearing any outstanding fees payable to ADDED, as well as to other regulating authorities where applicable[ADGM RA — Al Reem guidance note].

So the practical sequence is: settle every outstanding obligation with Abu Dhabi's Department of Economic Development first, get the NOC, and only then approach ADGM. An unpaid fee you had forgotten about does not slow the application down — it stops it before it starts. ADGM publishes a dedicated ADDED contact for this, transfertoadgm@ded.abudhabi.ae[ADGM RA — Al Reem guidance note].

Which ADGM legal form you land in

ADGM maps existing ADDED legal forms onto ADGM equivalents[ADGM RA — Al Reem guidance note]:

• Limited Liability Company → Private Company Limited by Shares
• Sole Proprietorship → Private Company Limited by Shares
• Branch of a free zone, UAE, GCC or foreign company → Branch of a Company

The sole proprietorship line deserves attention. ADGM has no sole-proprietor form, so a one-person ADDED business becomes a company with share capital, a director and filing obligations. That is a genuine change in how the business is run and reported, not a relabelling.

ADGM ran two fee incentives to encourage the move, and both are now closed. They still appear in circulating material, which is why they are worth stating precisely.

As part of its welcome offering[ADGM RA — Al Reem guidance note]:

• ADGM RA waived all fees associated with registration of Category B and Category C businesses — this incentive ended on 31 October 2024.
• ADGM RA waived the USD 7,500 continuation fee for businesses continuing into ADGM — this incentive ended on 31 December 2024.

Both dates have passed. If a proposal you are reading quotes a waived registration or continuation fee today, it is working from expired guidance — ask which document and which date it comes from before you rely on the number.

Two limits applied even while the waivers were live: they did not apply to Category A (financial) businesses, and they applied only to partnerships and companies engaged in non-financial businesses without exclusive activities[ADGM RA — Al Reem guidance note]. To use them, applicants had to file under specific activity codes — 7452 (Migrated Al Reem Island legal entity) for Category B and 4500 (Migrated Al Reem Island entity retail) for Category C[ADGM RA — Al Reem guidance note].

For what applies now, see ADGM company formation cost.

This is the practical reason the expansion still matters, and it is worth stating plainly because it affects how you should read any ADGM material — including ADGM's own.

Documents published before 2023 describe a smaller jurisdiction. ADGM's own SPV Guidance Note, published in March 2020, still describes the Registration Authority's responsibilities as covering businesses “operating in or from Al Maryah Island”[ADGM RA — SPV Guidance Note]. That was accurate when written. It is now incomplete.

The same applies to the SPV brochure, which describes the registered office requirement as an address “on Al Maryah Island”[ADGM — SPV brochure] — and which also quotes fees that the January 2025 schedule has since superseded.

The rule that follows: check the date on any ADGM document making a geographic or a numeric claim. A PDF on an official domain is not automatically current, and the older ones are exactly the ones that rank well and get quoted.

Every ADGM entity must maintain a registered office address in ADGM and pay the associated lease registration fee[ADGM RA — Schedule of Fees]. The expansion widened where that address can be.

For a holding structure the distinction is academic — an SPV needs an address, not a floor. For an operating business that will employ people, a jurisdiction ten times larger is a genuinely different market for space. See ADGM office space.