ADGM licence types

An ADGM commercial licence is not a tier of service you select. It records what the entity is permitted to do, and ADGM prices it according to which category that activity falls into.

That framing matters because it changes the first question. It is not “which licence should I buy?” but “what will this business actually do, and what is that called in ADGM’s activity list?” ADGM publishes a searchable register of permitted activities with the category each falls into [ADGM — Permitted Activities], and the answer to the second question determines the fee, the regulator, the documents and the timeline.

ADGM directs applicants accordingly: firms wishing to be registered as a financial service provider contact the FSRAto start the process, while non-financial and retail applicants contact the Registration Authority’s Business Development team[FSRA].

Category A — Financial Business Activities

Anything inside the FSRA’s regulatory perimeter: asset managers, advisers, brokers, payment firms, virtual asset firms, banks, insurers. The FSRA rulebook is the reference for permitted financial services activities.

Registration Authority fees total USD 17,000[ADGM RA — Schedule of Fees] with renewal at USD 16,500 [ADGM RA — Schedule of Fees]— and that is the RA’s charge alone. FSRA fees are set out in the FSRA’s own FEES rulebook, vary by permission, and are entirely separate. Reading the RA figure as the cost of a financial licence understates it by an order of magnitude, and regulatory capital is a further requirement that is not a fee at all. See what ADGM formation costs.

Category B — Non-Financial Business Activities

Professional services, consultancy, technology, holding companies, most operating businesses. This is where the majority of ADGM entities sit.

USD 5,800[ADGM RA — Schedule of Fees] to register, USD 5,300 to renew[ADGM RA — Schedule of Fees] — halved from January 2025 [ADGM — 2025 fee reduction].

Category C — Retail Business Activities

ADGM’s permitted retail activities include manufacturing; wholesale and retail trade; repair of motor vehicles and motorcycles; transportation and storage; accommodation and food service; information and communication; professional, scientific and technical activities; administrative and support services; arts, entertainment and recreation; and other service activities.

USD 2,800[ADGM RA — Schedule of Fees] to register, USD 2,300 to renew — cut by two-thirds from January 2025 [ADGM — 2025 fee reduction].

A cheaper track for structures that hold rather than trade. ADGM applies specialised fees to [ADGM RA — Schedule of Fees]:

• Professional Membership Organisations
• Companies or partnerships entering into insurance contracts as a principal (captive insurers only)
• Investment Partnerships, and the General Partners of Investment Partnerships
• Open Ended and Closed Ended Investment Companies
• Special Purpose Vehicles

The activity fee is USD 900, giving a registration total of USD 1,900[ADGM RA — Schedule of Fees] and renewal of USD 1,400[ADGM RA — Schedule of Fees] — around a third of a standard non-financial entity.

The trade-off is real, not administrative. An SPV cannot conduct operational business or hire staff. Choosing the specialised track because it is cheaper, when the business will trade, is the most expensive mistake available on this page.

Time-limited reductions for particular sectors [ADGM RA — Schedule of Fees]:

• Tech Start-up — USD 1,500[ADGM RA — Schedule of Fees], for three years, covering registration and two consecutive renewals. Note ADGM’s requirement that start-ups have A dedicated desk[ADGM — Setting up FAQs] — hot-desking is not accepted[ADGM — Setting up FAQs].
• Venture Capital Fund Managers — USD 1,500, three years, for FSRA-approved applicants.
• Social Enterprises — USD 700, subject to obtaining and maintaining a certificate confirming the entity’s classification as a social enterprise from the competent authority.
• Carried Interest Vehicles — USD 1,900 initial, USD 1,000 renewal.

Plan for the cliff. Incentivised fees apply only for the stated duration, after which the entity reverts to standard fees for its category — non-financial tech start-ups to Category B, and fintech start-ups conducting at least one financial activity to Category A. A start-up paying USD 1,500 in year one may face USD 5,300, or USD 16,500, in year four. Annual data protection fees are excluded from the incentivised figure throughout.

Three questions, in order.

1. Is any part of this a financial service? If yes, you are in Category A, the FSRA comes first, and the timeline is not measured in days. If you are unsure — and payments, lending, advising on investments and dealing in virtual assets are the usual boundary cases — resolve it before anything else. Discovering it late means starting again.

2. Will the entity trade, or only hold? Holding structures may qualify for the specialised track at roughly a third of the cost, with the restriction that they cannot trade or employ.

3. Does an incentive apply? Tech start-up, VC fund manager, social enterprise or carried interest vehicle — worth checking, but check the eligibility criteria rather than assuming a self-description qualifies.

Then find the activity in ADGM’s permitted activities register and describe it precisely in the application. A vague or padded activity description generates questions and delay.

A commercial licence for non-financial activities may cover more than one business activity, but those activities must be complementary — they must form a logical business proposition when considered together [ADGM — Permitted Activities].

This differs from the habit some UAE free zones encourage, where applicants bolt on every activity they might conceivably want so as to avoid amending later. That does not work here, and it is worth knowing before you draft the application rather than after it comes back with questions.

“Management consultancy and business advisory” is a logical proposition. “Management consultancy, event catering and vehicle repair” is a fee-avoidance strategy, and reads as one.

Possible, and charged. ADGM’s schedule sets variation fees [ADGM RA — Schedule of Fees]:

• USD 100 — variation where the business activities remain within the same category
• USD 3,100 — where the activity changes from Category C to Category B
• USD 11,300 — for the larger step up in category

The gradient tells you something useful: moving within a category is trivial, and moving up one is priced closer to a fresh registration. Adding an activity you always intended to have is cheap; discovering you picked the wrong category is not.

This is the practical argument for spending time on classification at the start, and for raising the “might this be financial services?” question early rather than hoping it does not come up.

Renewal is the commercial licence fee, the business activity fee for your category, and the USD 300[ADGM RA — Schedule of Fees] data protection fee — which ADGM requires to be submitted separately from the commercial licence renewal[ADGM RA — Schedule of Fees]. That separation is the single most commonly missed obligation in ADGM, precisely because it is separate.

Alongside it:

• A registered office in ADGM at all times, with its lease registration fee [ADGM RA — Schedule of Fees].
• Filings on change of directors, shareholders, address or share capital.
• Annual accounts, where the entity’s form requires them — noting that ADGM’s filing schedule excludes Restricted Scope Companies from the annual accounts and reports requirement.
• Federal corporate tax registration and filing, and VAT if you cross the threshold. Free zone status does not exempt you.

Figures from the ADGM Schedule of Fees, version dated January 2025. Fees, tax rules and requirements change. Verify current figures with the ADGM Registration Authority, the FSRA and the UAE Ministry of Finance before acting. This page is general information, not legal or tax advice.