The ADGM public register

Almost every confused search about the ADGM register comes from merging two different things.

1. The Registrar's register

The public record maintained by the Registration Authority under Part 35 of the Companies Regulations 2020. Any person may inspect it[ADGM — Companies Regulations 2020]. It is what you use to confirm an entity exists, and it is where public notice of incorporation and of the receipt of certain filed documents appears[ADGM — Companies Regulations 2020].

2. The company's own registers

Every company maintains its own register of members and register of directors. These are not the Registrar's register and they are not open to the world on the same terms.

Under section 121, the register and list of members' names must be open to inspection by any member without charge, and — except for a restricted scope company or an investment company — by any other person on payment of a prescribed fee[ADGM — Companies Regulations 2020].

So a member always gets in. A stranger usually gets in on payment. And against an RSC, a stranger does not.

Why the distinction matters practically

If you are doing diligence on an ADGM counterparty, the Registrar's register tells you the entity exists and gives you what has been publicly filed. It does not automatically hand you a full shareholder list for every structure. Those are different questions with different answers, and asking the wrong one wastes time.

Section 961 lists material the Registrar must not make available for public inspection[ADGM — Companies Regulations 2020]. The items that matter most in practice:

• Documents filed by a restricted scope company or an investment company that are not subject to the enhanced disclosure requirements.
• Directors' residential addresses — protected information under section 228(1), which restricts disclosure by the Registrar.
• Representations received in response to a notice proposing to put a director's usual residential address on the public record.
• Disqualification of directors material — documents or notices filed or prepared by the Registrar under that chapter, other than a decision notice.
• Applications for administrative restoration to the register that are pending or were unsuccessful.

There is also a mechanism at section 962 for applying to the Registrar to make an address unavailable for public inspection[ADGM — Companies Regulations 2020].

What this means if you are searching

An RSC returning thin results is not an error or a gap in the data. It is the statute operating as designed — and the restriction is on the public register only. The Registrar receives full disclosure in every case[ADGM — SPV brochure].

Directors' residential addresses being absent is likewise deliberate and normal, and matches the position in most modern company-law jurisdictions. A service address appearing where you expected a home address is the system working.

Section 960 sets out the copying rights[ADGM — Companies Regulations 2020]:

• Any person may request an electronic copy of any publicly available material on the register.
• Where the material derives from a document subject to the enhanced disclosure requirements, the fee for that electronic copy must not exceed the administrative cost of providing it.
• Any person may request a paper copy of publicly available material, and the Board may make rules requiring fees for paper copies.

The cost cap on electronic copies of enhanced-disclosure material is the useful detail. It means the register is not a revenue product for that category — if you are quoted a figure that looks like a commercial data charge, that is not what the Regulations contemplate.

The certificate of incorporation as evidence

Where you need proof rather than a search result, the certificate does more work than a register printout. Section 12 requires it to state the company's name and registered number, date of incorporation, whether it is limited or unlimited, whether limited by shares or guarantee, whether private or public, and — if private — whether it is a restricted scope company[ADGM — Companies Regulations 2020].

And it is conclusive evidence that the registration requirements were complied with and that the company is duly registered[ADGM — Companies Regulations 2020]. A counterparty asking for the certificate rather than a screenshot is asking for the stronger document.

What a register check can and cannot settle.

It can confirm

• That the entity exists and is registered in ADGM, with its registered number and incorporation date[ADGM — Companies Regulations 2020].
• Its legal form — limited or unlimited, by shares or guarantee, private or public, and whether it is a restricted scope company[ADGM — Companies Regulations 2020].
• What has been publicly filed, including material for which public notice of receipt is given[ADGM — Companies Regulations 2020].

It cannot settle

Whether they are licensed to do what they say. Registration and licensing are related but distinct, and licensing sits under the Commercial Licensing Regulations. If the question is whether a provider may lawfully act as your company service provider, see company service providers — that is a controlled activity question, not a register one.

Whether the entity is financially sound. A small company may be exempt from audit, and an RSC is exempt from the audit Part entirely[ADGM — Companies Regulations 2020]. Absence of filed audited accounts tells you about the exemption, not the balance sheet. See audit requirements.

Who ultimately owns it. A statement of initial beneficial ownership and control is required at incorporation[ADGM — Companies Regulations 2020], but that is a filing to the Registrar. Do not assume the public view gives you the ultimate beneficial owner, particularly for an RSC.

For anything that turns on ownership or standing, ask the counterparty for documents directly and verify them against the register — rather than expecting the register to substitute for disclosure.