The Abu Dhabi Global Market (ADGM) is planning a major update to how it handles investigations, penalties, and enforcement. These changes are outlined in Consultation Paper No. 7 of 2025 and could impact any business operating within the ADGM.

The goal is to make enforcement more efficient, transparent, and consistent across the board.

What’s Changing?

Currently, ADGM’s enforcement powers and processes are spread across multiple laws. This can lead to confusion and slow responses, especially when dealing with issues that range from minor administrative errors to serious violations. The new proposal introduces a single set of Administrative Regulations that would apply to all commercial legislation within the ADGM.

Here’s a breakdown of the key proposals:

Two-Tiered Enforcement System

ADGM plans to introduce a two-level process based on the seriousness of the issue:

• Tier 1: Minor Contraventions
  These are lower-level issues, like missing a filing deadline. They would be handled quickly through a simplified process, with the option of a 30% fine reduction if paid within 14 days.
• Tier 2: Serious Contraventions
  These involve more significant violations. The process here would include warning notices, the chance to respond, and potential penalties such as large fines, disqualifications, or suspension of a license.

This approach helps ensure minor infractions don’t trigger a full-scale enforcement process while keeping tougher consequences in place for serious misconduct.

Updated Fine Levels

ADGM is revising the fine scale to better reflect the severity of different contraventions. The maximum fine could now reach up to USD 54 million, with escalating penalties for repeat offenses.

Emergency Powers for the CEO

In urgent situations, such as when immediate action is needed to protect the market or other stakeholders, the CEO of the Registration Authority will have new powers to take fast action — such as suspending or canceling a license without delay.

Option to Settle Early

Businesses that acknowledge a contravention may choose to settle early and avoid the full enforcement process. This would reduce the administrative burden and speed up resolution for both parties.

Statutory Settlement Authority

ADGM is also proposing a clear legal basis for settlement agreements. This would allow the Registration Authority to formally enter into binding settlements at any stage during the enforcement process.

How to Participate

ADGM is currently accepting public comments on these proposals. The deadline for feedback is 17 July 2025. If you’d like to submit your thoughts, you can email them to ra.consultation@adgm.com, making sure to reference Consultation Paper No. 7 of 2025.

Why This Matters

If you’re a licensed firm, director, auditor, or anyone operating in the ADGM, these changes could affect how compliance issues are handled in the future. The new regulations are designed to create a clearer, fairer, and more responsive system — helping the ADGM remain a reliable and well-regulated environment for doing business.

We’ll continue to monitor this consultation and share updates once the final regulations are published.

This article is drafted by Marco Marazzi, Business Solutions Legal Advisor of Bizzmosis Group