ADGM company service providers

Not a mailbox, and not an optional convenience. ADGM defines the role concretely[ADGM — SPVs]:

• Submits the incorporation application. For a non-exempt applicant you do not file yourself — the CSP does.
• Acts as the registered office. Satisfying the requirement that every ADGM entity maintain an address in ADGM[ADGM RA — Schedule of Fees].
• Is the primary point of contact for the Registrar. Correspondence goes to them.
• Submits ongoing company filings. Annual returns, changes of director or shareholder, renewals.

For a passive holding vehicle that is close to the entire administrative existence of the company, which is why the relationship matters more than the fee comparison suggests.

An SPV need not appoint a CSP if it is a body corporate that is a subsidiary undertaking of any of the following[ADGM — SPV brochure]:

1. persons exempt under the Commercial Licensing Regulations (Exemptions) Order;
2. an authorised person within the meaning of the Financial Services and Markets Regulations 2015;
3. persons licensed or regulated by the Central Bank of the UAE;
4. a company whose shares are admitted to trading on a regulated market in the UAE, including in ADGM; or
5. a company that has demonstrated to the Registrar's satisfaction that it has substantial assets, turnover and employees in the UAE and adequate governance policies and procedures.

The fifth limb is the discretionary one. ADGM lists the kind of evidence the Registrar will look at: commercial licences of operating UAE entities, asset lists, employee numbers and turnover, establishment cards and residency visas, organisation charts, board composition, and the resources of the compliance or company secretarial function[ADGM — SPV brochure]. On governance it lists business ethics, corporate governance, compliance, anti-bribery, economic substance, risk management and AML policies. The Registrar reserves the right to request more.

Two tests people merge, and should not

The exempt-applicant test decides whether you need a CSP. The Nexus Requirement decides whether you can have an SPV at all[ADGM RA — SPV Guidance Note]. And the RSC categories decide whether you get limited public-register disclosure[ADGM — SPV brochure]. Three different tests, three different questions. Satisfying one says nothing about the others.

Two things about the CSP market that change how you should choose one.

It is a controlled activity

ADGM describes CSP work as a controlled activity, subject to the Commercial Licensing Regulations (Conditions of License and Branch Registration) Rules 2023[ADGM RA — Al Reem guidance note]. A CSP is not simply a corporate services firm that happens to operate in ADGM — it holds a specific licence to do a specific regulated thing, and it can lose it.

ADGM also states plainly that individuals are not allowed to apply for this activity[ADGM RA — Al Reem guidance note]. Your CSP will be a licensed entity, never a person acting in a personal capacity. If someone offers to act as your CSP personally, that is not a service ADGM permits.

ADGM has closed the register before

This is worth knowing before you assume a CSP can always be found or replaced.

ADGM announced a moratorium on CSP activity from 1 January 2024 — described in its own guidance as a temporary prohibition of the activity — running until 30 June 2024, during which no new CSPs could be registered in ADGM[ADGM RA — Al Reem guidance note].

That window has closed and the moratorium is not in force. It is set out here for what it demonstrates rather than what it currently requires: ADGM actively manages the size of this market and will suspend new entrants when it judges that necessary.

The practical consequence for anyone who must appoint a CSP — which is every non-exempt applicant — is that the supplier market is deliberately constrained. Do not plan on the assumption that switching providers is quick, or that new entrants will appear to compete on price. Establish who your CSP will be before you commit to a timeline, and ask what happens to your registered office and your filings if the relationship ends.

This is the honest part of the page.

No authority publishes CSP fees. They are set by each provider at market rates. ADGM's own note on the point is that its published SPV fees "do not include professional fees charged by a Company Services Provider appointed for Non-exempt SPVs"[ADGM — SPV brochure].

What we can tell you, because it follows from the structure of the market rather than from a published figure: for a typical SPV the CSP's annual fee exceeds ADGM's own renewal charge of USD 1,400[ADGM RA — Schedule of Fees]. Frequently by a multiple.

The practical consequence is that any cost comparison built on government fees alone materially understates the running cost of a non-exempt structure. When you receive a quotation, the government element is knowable to the dirham from ADGM's published schedule — so everything above it is the provider's fee, and can be compared like for like.

We are not a CSP. We do not take a fee from providers for introductions, and we cannot file anything for you.

ADGM publishes a list of licensed company service providers[ADGM — Company Service Providers], and the licence itself is a real ADGM category — a CSP pays USD 7,800 to register and USD 7,300 a year for the privilege[ADGM RA — Schedule of Fees], which tells you it is a supervised activity rather than a title anyone can adopt.

Things worth asking that are not the price:

• What is included in the annual fee, and what is billed separately — filings, changes, correspondence, resolutions.
• Who actually handles your file, and how quickly they respond when the Registrar writes to them, since they are the point of contact and not you.
• Experience with your structure. A provider who does SPVs constantly will read your nexus position accurately before you spend anything.
• What happens if you leave. Transferring registered office and records between CSPs is routine, but the terms are worth reading at the start rather than at the end.

The CSP requirement and the registered office requirement are linked but distinct. Every ADGM entity must maintain a registered office address in ADGM[ADGM RA — Schedule of Fees], and ADGM sets out three ways to satisfy it[ADGM — SPV brochure]:

1. the appointed company service provider offers the address — the route for non-exempt entities;
2. an exempt entity may use the address of its ADGM-registered parent or related entity;
3. an ADGM entity licensed with the activity of "registered office provider" may offer an address to exempt entities.

So an exempt group with an existing ADGM presence can hold its SPVs at the parent's address and avoid the CSP fee entirely — which is a meaningful structural advantage of already being in ADGM.