ADGM

Becoming an FSRA-Authorised Fund Manager in ADGM

2026-05-13 · 6 min read · By Aureus Worldwide

Becoming an FSRA-authorised fund manager in ADGM means obtaining a Financial Services Permission to carry on fund and asset management as a regulated activity in the Abu Dhabi Global Market. Fund management sits at the centre of ADGM's proposition: a common-law jurisdiction that applies English law directly, an independent regulator in the Financial Services Regulatory Authority (FSRA), and a fund regime built around private capital, venture capital and institutional money. This guide explains what the regulated activity involves, how the manager relates to the fund, the ADGM fund categories, the capital and personnel you need, and the lighter-touch venture capital route.

What "managing a fund" means in ADGM

Under the Financial Services and Markets Regulations (FSMR), fund and asset management are regulated activities. A manager will typically carry on:

• Managing a Collective Investment Fund, running a fund vehicle, taking the investment decisions and being responsible to investors; and/or
• Managing Assets, managing investments on a discretionary basis for clients under a mandate.

Carrying on either by way of business in or from ADGM requires a Financial Services Permission (FSP) from the FSRA. You cannot market or run a fund from ADGM on the strength of a commercial licence alone. For the wider picture of how permissions work, see our overview of FSRA authorisation in ADGM and the full list of regulated activities in ADGM.

The fund manager versus the fund

A common source of confusion is the distinction between the manager and the fund:

• The fund manager is the authorised firm. It holds the FSP, employs the approved individuals, and meets the capital and conduct requirements.
• The fund is a separate vehicle, typically an investment company, an investment partnership (often with an ADGM LLP or limited partnership as general partner), or an investment trust. Depending on its category, the fund is either registered with, or notified to, the FSRA rather than separately authorised.

So the authorisation effort focuses on the manager; the fund is then established and its units offered within the rules for its category.

ADGM fund categories

ADGM's fund regime is tiered by how widely a fund is offered and to whom:

The Qualified Investor Fund is the workhorse for private-capital and venture sponsors because it carries the lightest regulatory load, reflecting that its investors are sophisticated and its minimum commitment is high. The Exempt Fund sits between the QIF and a Public Fund. The FSRA sets the exact minimum subscriptions and unitholder limits in its Fund Rules and updates them periodically, so confirm the current thresholds rather than relying on third-party figures. If your strategy involves funds specifically, our note on corporate tax for investment funds in the UAE is a useful companion.

The venture capital fund manager route

A feature that sets ADGM apart is its dedicated venture capital (VC) fund manager framework. Recognising that VC managers are small, early and capital-light, the FSRA offers a lighter-touch regime for managers who run venture capital funds, typically with reduced or no base capital requirement, lower fees and a streamlined authorisation compared with a full fund manager.

The trade-off is scope: the regime is designed for genuine venture capital fund management and comes with eligibility conditions the FSRA sets and revises. For an emerging manager raising a first fund, it can be the difference between an affordable launch and an uneconomic one, so it is worth checking eligibility early.

Authorisation requirements

Whichever route you take, expect the FSRA to test the firm against its threshold conditions. The main building blocks are:

1. A Regulatory Business Plan, a credible description of the strategy, funds, target investors, operations and financial projections.
2. Prudential category and capital. A fund or asset manager generally falls within Category 3C. It must hold the higher of its base capital, an expenditure-based minimum (a proportion of annual audited expenditure) and any risk-based requirement. See our explainer on FSRA prudential categories for how this works.
3. Approved persons in controlled functions, a Senior Executive Officer, a Finance Officer, a Compliance Officer and a Money Laundering Reporting Officer (MLRO). Smaller managers may combine or, within limits, outsource some roles subject to FSRA agreement. Our ADGM finance-officer guide and our compliance officers and CFO services support these functions.
4. Systems, controls and an AML framework proportionate to the business, see our AML consulting service.
5. Professional indemnity cover and appropriate governance.

Delegation, administration and service providers

Few managers do everything in-house, and the FSRA expects a clear picture of who does what. A typical fund manager relies on a network of service providers:

• a fund administrator for net asset value calculation, investor registers, and subscriptions and redemptions;
• an auditor for the fund's and the manager's financial statements;
• a custodian or prime broker holding the fund's assets; and
• legal counsel for the fund's constitutional documents and offering materials.

Delegating a function does not delegate responsibility: the authorised manager remains accountable to the FSRA for anything it outsources, so each arrangement must be documented, monitored and subject to proper oversight. Getting this operating model right at the application stage, rather than improvising it later, is one of the things that separates a smooth authorisation from a stalled one.

Marketing and client classification

An ADGM fund manager must also respect who it can sell to. Exempt and Qualified Investor Funds are offered by private placement to Professional Clients only, not to the retail public, so the manager must classify each investor correctly and keep the evidence. How a fund is marketed into or from ADGM, and any reliance on reverse solicitation, should be handled carefully and in line with the conduct rules, an area where regulatory counsel earns its fee.

Ongoing obligations

Authorisation is the start, not the finish. An FSRA-authorised fund manager must maintain its capital, file regulatory returns, keep audited financial statements, run its compliance and AML monitoring, manage conflicts of interest, and treat client and fund assets in line with the rules. Fund-specific reporting, investor disclosures and valuations follow the category of each fund. Strong bookkeeping and a disciplined finance function from day one make these obligations routine rather than a scramble.

How Aureus Worldwide can help

Aureus Worldwide is a Dubai-based accounting, tax, CFO and compliance-advisory firm. The regulatory authorisation itself is led by specialist regulatory counsel and granted by the FSRA. What we do is make the finance function behind your application and your live operation solid: building the financial projections for your Regulatory Business Plan, setting up accounting to IFRS standard, providing outsourced CFO and Finance-Officer support, framing your AML processes, and keeping tax and reporting on track. We prepare books to an audit-ready standard and coordinate with your appointed auditor, and we work alongside your legal and DIFC and ADGM advisers throughout. To build the finance and compliance foundation for an ADGM fund manager, contact us.

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