ADGM

ADGM Ongoing Compliance & Annual Filings

2026-07-01 · 6 min read · By Aureus Worldwide

Setting up in the Abu Dhabi Global Market is only the beginning; keeping the entity in good standing year after year is the real ongoing job. ADGM ongoing compliance covers a recurring cycle of obligations, annual licence renewal, audited accounts, a confirmation filing, up-to-date registers and beneficial ownership, data protection renewal, and UAE tax and substance duties. Miss them and you risk fines, loss of good standing or eventual strike-off. This guide sets out the annual filing obligations for ADGM companies and how to stay on top of them.

Compliance starts the day you incorporate

The obligations below begin the moment your entity is registered, not at some later date. A new ADGM company should build its compliance calendar at incorporation, mapping each recurring duty to an owner and a deadline. The categories differ by entity type, a passive SPV carries less than a full operating company, and an FSRA-authorised firm carries the most, but the framework is common to all. Our ADGM company setup guide covers the formation side; this guide picks up where that leaves off, and our ADGM finance officer guide explains who typically owns these duties day to day.

Annual licence renewal

Every ADGM entity holds a commercial licence that must be renewed annually with the ADGM Registration Authority. Renewal keeps the entity in good standing and lawfully able to operate; letting it lapse jeopardises everything else, from banking to visas. Fees are set by ADGM and revised periodically, so confirm the current amount rather than relying on last year's figure.

Accounting records and audited financial statements

ADGM applies robust financial-reporting standards:

• Accounting records. Every company must maintain proper books, generally under IFRS, sufficient to show and explain its transactions and financial position, see our accounting service.
• Audited financial statements. Most ADGM entities must have their accounts audited by an approved auditor and file them, with additional reporting for FSRA-authorised firms. Certain small companies meeting size thresholds may qualify for exemptions, so check whether your entity does.

Because Aureus is not an ADGM-registered auditor, we prepare your books to an audit-ready standard and coordinate with a licensed audit partner who signs the report, see our audit service for how that works in practice.

Annual confirmation and registers

Beyond the accounts, ADGM companies must keep their public record accurate:

• File an annual confirmation (a return confirming the company's particulars, directors, shareholders, registered office and share capital).
• Maintain statutory registers of members, directors and, where relevant, secretaries.
• Keep a register of beneficial owners and file or update ultimate beneficial ownership (UBO) information, consistent with UAE UBO requirements, our UBO consulting team supports this.

These filings are how ADGM and the wider UAE keep ownership transparent, and they must be updated promptly when things change.

Data protection registration

If your entity processes personal data, and almost every one does, if only employee and client data, it must comply with the ADGM Data Protection Regulations 2021 and generally register with the Office of Data Protection and renew annually. The full framework is set out in our guide to the ADGM Data Protection Regulations. The annual renewal is an easy obligation to overlook, so it belongs on the compliance calendar alongside the licence.

Economic Substance (ESR)

The UAE Economic Substance regime can apply to ADGM entities carrying on a relevant activity, such as holding company, financing and leasing, headquarters or fund management business. Where it applies, the entity must file an ESR notification and, if it earns relevant income, an economic substance report demonstrating adequate substance in the UAE. Whether ESR bites depends on your activities, so assess it each year rather than assuming last year's answer still holds, our ESR reporting service handles this.

UAE Corporate Tax

ADGM entities fall squarely within the UAE Corporate Tax regime:

• Register with the Federal Tax Authority.
• File a Corporate Tax return, generally within nine months of the end of the tax period, and pay any tax due.
• Apply the rates: 0% below AED 375,000 and 9% above, with a qualifying free zone person potentially accessing 0% on qualifying income where substance and de minimis conditions are met.

The free zone benefit is valuable but conditional and needs to be assessed on your facts each year, our tax team manages registration, computation and filing.

VAT

Where your taxable supplies exceed the mandatory registration threshold of AED 375,000, you must register for VAT at 5% and file periodic returns; voluntary registration is available above AED 187,500. Even zero-rated or exempt businesses need to determine their position correctly, because getting VAT treatment wrong is a common source of penalties.

Employment, payroll and WPS

If you employ staff, ongoing duties flow from the ADGM Employment Regulations 2019, compliant payroll, wage records, end-of-service gratuity provisioning and health insurance renewals. Our ADGM employment guide covers these in depth, and our business process outsourcing team can run the payroll for you.

Regulated firms: FSRA returns

FSRA-authorised firms carry an additional layer: regulatory reporting and prudential returns, notifications of changes in control and controllers, ongoing capital and systems-and-controls requirements, and regulatory audit obligations. These sit on top of everything above and are supervised by the FSRA directly. Firms in this category need a finance and compliance function equal to the task.

Notifying changes to the Registration Authority

Compliance is not only annual. When something changes, a new director or shareholder, a change of registered office, a name change or an amendment to the articles, the company must notify the Registration Authority within the required timeframe. Letting the register drift out of date is itself a breach, so build a habit of filing changes as they happen.

An ADGM annual compliance calendar

Use a calendar like this, assign each line an owner, and review it at least once a year, it is the single most reliable way to avoid a missed filing.

What happens if you fall behind

The consequences of non-compliance escalate. Late filings attract fines; persistent failure can lead to loss of good standing, restrictions, and ultimately strike-off from the register, while tax defaults carry their own penalties under the UAE regime. A struck-off company undermines the very credibility that made ADGM attractive in the first place. Staying current is far cheaper than putting a lapsed entity right.

How Aureus Worldwide can help

Aureus Worldwide is a Dubai-based accounting, tax and compliance firm that keeps ADGM entities in good standing all year round. We maintain your books to an audit-ready standard, coordinate the audit with a licensed partner, manage your Corporate Tax and VAT filings, support UBO, ESR and data protection obligations, run payroll, and help track every deadline through our accounting, compliance officers and DIFC and ADGM services. We are not a law firm and not an ADGM-registered auditor, audit and legal work sit with licensed partners and your counsel, and we coordinate them for you. To put your ADGM ongoing compliance on a firm footing, contact us.

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