Consultation Paper No. 6 of 2026 - Proposed Revisions to the Fees and General Rulebooks

CONSULTATION PAPER
NO. 6 OF 2026
PROPOSED REVISIONS TO THE FEES
AND GENERAL RULEBOOKS
9 OCTOBER 2026

i
Table of Contents
Introduction ......................................................................................................2
Background.......................................................................................................4
Section A: Markets fees ......................................................................................5
Section B: Late filing fees....................................................................................8
Section C: Fees for varying an FSP..................................................................... 10
Section D: Controller applications involving substantial change.......................... 10
Section E: Variations of an FSP within 12 months of authorisation ....................... 11
Section F: Miscellaneous.................................................................................. 11
Section G: Implementation............................................................................... 12
Appendices and Attachment............................................................................. 12

Why we are issuing this consultation paper

1. The Financial Services Regulatory Authority (the “FSRA”) of Abu Dhabi Global
   Market (“ADGM”) has issued this consultation paper to invite public comment on proposed amendments primarily to the Fees Rulebook (“FEES”), as well as the General Rulebook (“GEN”) and the Guidance and Policies Manual (“GPM”).
2. Capitalised terms contained in this consultation paper have the meanings
   attributed to them in the FSRA’s Glossary Rulebook (“GLO”), unless otherwise defined in this consultation paper. All $ references mean US Dollars.
3. The consultation paper includes the following proposals:
   a. Section A outlines proposed revisions to the application fees and the annual supervision fees payable by Recognised Bodies and by operators of Multilateral Trading Facilities (“MTFs”) and Organised Trading Facilities (“OTFs”), and the introduction of an annual supervision fee in respect of Securities admitted to the Official List. b. Section B sets out a proposed increase in the fee payable for late Regulatory Filings.
   c. Section C proposes clarification concerning the fees payable for varying the
   description of a Regulated Activity to include Virtual Assets (“VAs”), Fiat￾Referenced Tokens (“FRTs”) or Spot Commodities (“SCs”) or when adding additional Regulated Activities under an existing Financial Services Permission (“FSP”) to conduct Islamic Financial Business. d. Section D outlines proposed Guidance relating to supplementary fees for certain change-in-control (“CiC”) applications. e. Section E summarises proposed Guidance relating to applications for the variation of an FSP (“VOP”) within 12 months of licensing. f. Section F covers miscellaneous amendments. g. Section G covers implementation of the proposals in their final form. Who should read this consultation paper
4. This consultation paper should be of interest to all Authorised Persons,
   Recognised Bodies, Listed Entities, Designated Non-Financial Businesses or Professions (“DNFBPs”), prospective controllers and applicant firms, as well as their respective professional advisors. Introduction

How to provide comments
5. All comments should be made in writing and sent to the email address
specified below. Please put the consultation paper number in the subject line. If relevant, please identify the organisation you represent in providing your comments. The FSRA reserves the right to publish, including on its website, any comments you provide, unless you expressly request otherwise at the time of making any comments. The FSRA will give more weight to comments supported by reasoning and evidence. What happens next
6. The deadline for providing comments on these proposals is 6 November 2026.
When we receive your comments, we will consider whether the proposed amendments require any modifications. The FSRA will then proceed to enact the proposed amendments in their final form. You should not act on the proposed amendments described in this consultation paper until the relevant Rules are amended. Comments to be emailed to:
Subject Line: Consultation Paper No. 6 of 2026 Email: fsra.consultation@adgm.com

1. The FSRA undertook a comprehensive review of its fees in 2023 and outlined
   proposals to update them in Consultation Paper No. 4 of 2023 (Proposals for Revisions to Fees and Recognised Functions). Before that, most fees had remained at the levels set in 2015 when ADGM was established and had decreased in real terms over the intervening period. While the FSRA continues to receive strong government support, it remains important to recover a reasonable proportion of costs reflecting the regulatory work we do, in line with the funding model of many other leading regulators worldwide.

2. Certain activities were expressly excluded from the scope of the 2023 review.
   Those exclusions included market infrastructure activities, being activities undertaken by Recognised Investment Exchanges, Recognised Clearing Houses, Remote Bodies and Remote Members. We stated at the time that omitting those activities did not preclude a future review. This consultation paper gives effect to that review.

3. Two developments since 2023 make it timely to revisit the fees that were then
   excluded. First, ADGM’s market infrastructure has matured, and the trading and clearing models now being brought forward are materially more complex than those contemplated when the current fees were set. Second, the FSRA’s Listing Authority is now fully operational and maintains an Official List of Securities. The FSRA has also considered developments in other jurisdictions, and its fees for market infrastructure and Listing Authority activities remain at the lower end of the range, in both absolute and relative terms.

4. The FSRA remains of the view that fees should be balanced and proportionate
   to the size and maturity of the ADGM market. The proposals in Section A of this paper are accordingly calibrated to the complexity of the activities covered by ordinary applications and to the resources required to assess and supervise those activities. Supplementary fees will continue to be appropriate and necessary where additional resources are required to be deployed to license or supervise a firm adequately.

5. As part of our fees review, we identified other areas that need to be directly
   addressed to maintain fairness, transparency and efficiency in ADGM. Accordingly, we propose to increase the fees we apply when Regulatory Filings, including AML Returns, are filed late. We have also set out our proposed approach to (i) fees for variations of an FSP, (ii) fees for CiCs that require a level of review similar to a new authorisation, and (iii) requests for VOPs less than 12 months after licensing. Background

6. The FSRA proposes to revise a limited number of the fees payable by
   Recognised Bodies and by operators of MTFs and OTFs, and to introduce an annual supervision fee in respect of Securities admitted to the Official List. The
   table below summarises the proposed fees. Fees not listed in the table are not
   proposed to change.
   Table 1 – Markets Fees
   FEES Rules Fee Current
   $
   Proposed
   $
   Multilateral Trading Facilities and Organised Trading Facilities Currently:
   3.10.1(b) and
   (c)
   Proposed:
   New 3.9B.1
   Application fee – Operating an
   MTF or OTF, other than in relation to VAs, FRTs or SCs 10,000 100,000 Currently:
   3.10.2(b) and
   (c)
   Proposed:
   New 3.9B.2
   Annual supervision fee –
   Operating an MTF or OTF, other than in relation to VAs, FRTs or SCs 10,000 40,000 3.17.1(b), 3.19.1(b) Additional application fee – Operating an MTF or OTF in relation to VAs, FRTs or SCs (as applicable) 125,000

• in total
  25,000
• in addition to
  the proposed application fee of 100,000
  3.17.2(b),
  3.19.2(b)
  Additional supervision fee –
  Operating an MTF or OTF in relation to VAs, FRTs or SCs (as applicable) 60,000
• in total
  20,000
• in addition to
  the proposed supervision fee of 40,000
  Section A: Markets fees

FEES Rules Fee Current
$
Proposed
$
Recognised Bodies
4.1.1 Application for recognition – as a
Recognised Investment Exchange or a Recognised Clearing House 125,000 150,000
4.1.2 Annual supervision fee – as a
Recognised Investment Exchange or Recognised Clearing House 60,000 100,000
4.1.3 Application for recognition – as
both a Recognised Investment
Exchange and a Recognised
Clearing House
250,000 300,000
4.1.4 Annual supervision fee – as both a
Recognised Investment Exchange and a Recognised Clearing House 120,000 200,000 Specific Fees related to Markets Proposed:
New 9.2.2
Annual supervision fee – for each class of Securities admitted to the Official List – 1,000 Multilateral Trading Facilities and Organised Trading Facilities
7. The application fee for operating an MTF or OTF under FEES 3.10.1(b) and (c) is
presently $10,000, as is the annual supervision fee under FEES 3.10.2(b) and (c). The FSRA proposes increasing the application fees for both MTFs and OTFs to $100,000 and their annual supervision fees to $40,000. The FSRA does not propose to change the current application fee of $125,000 and annual supervision fee of $60,000 for operating an MTF or OTF in relation to VAs, FRTs or SCs. Accordingly, amendments are proposed in FEES 3.17 and 3.19 to reflect that those fees will not change in total when added to the new proposed fees in FEES 3.9B.
8. The current fees were set when an MTF or OTF operating in ADGM was expected
to be a comparatively simple venue. The applications now being received involve materially greater assessment work, including market surveillance arrangements, membership and access criteria, settlement and post-trade arrangements, and operational resilience. The current fees do not reflect the

resources required either to assess such an application or to supervise the venue thereafter. Benchmarking indicates that the fees proposed are appropriate and proportionate given the evolution of the ADGM market.
9. We do not propose to change the trading levy applicable to VAs traded on an
MTF under FEES 3.18.
Question 1
Do you agree with the proposed application fees and annual supervision fees of MTFs and OTFs? Recognised Bodies
10. We propose increasing the application fee for recognition as a Recognised
Investment Exchange or a Recognised Clearing House under FEES 4.1.1 from $125,000 to $150,000, and the annual supervision fee under FEES 4.1.2 from $60,000 to $100,000. Where an applicant seeks recognition in both capacities, the corresponding fees would be $300,000 and $200,000 respectively.
11. The proposed levels bring the FSRA’s fees in line with suitable comparators,
while remaining materially below those charged in larger and more mature markets. They also reflect the resources now required to assess and supervise the trading and clearing models being brought forward in ADGM, which are more complex than those contemplated when the current fees were set. Question 2 Do you agree with the proposed increases to the application fees and annual supervision fees for Recognised Investment Exchanges and Recognised Clearing Houses? Listing Authority fees
12. The FSRA, through its Listing Authority, maintains the Official List of Securities.
Guidance under FEES 9.2.1 presently provides that a Listed Entity whose Securities are admitted to the Official List is not required to pay an annual supervision fee. Therefore, no annual charge is made for maintaining the Official List, even though the function involves ongoing work, comprising processing admissions, suspensions and re-admissions, and monitoring compliance with continuing obligations, including making Disclosures through the FSRA Disclosure Platform.

13. The FSRA proposes to introduce a new annual supervision fee of $1,000
    payable by each Listed Entity with Securities admitted to the Official List (FEES 9.2.2). Where a Listed Entity has more than one class of Securities admitted, a separate fee would be payable in respect of each class, so that the fee scales modestly with the additional monitoring a multi-class issuer creates. The existing Guidance under FEES 9.2.1 would be deleted as a consequence. Question 3 Do you agree with the proposed annual supervision fee of $1,000 for each class of Securities admitted to the Official List, and with the consequential deletion of the Guidance under FEES 9.2.1? Supplementary fees
14. FEES 1.2.4 permits the FSRA to impose a supplementary fee where it expects
    to incur substantial additional costs or to expend substantial additional effort. Rather than setting the baseline fees in Table 1 at a level calibrated to the most demanding case, the FSRA proposes keeping those fees proportionate and relying on FEES 1.2.4 where an individual application requires significantly greater resources. The FSRA proposes adding a reference to systemically important firms to the Guidance under FEES 1.2.4 so the circumstances under which a supplementary fee may be charged remain transparent to the market. Question 4 Do you agree with the proposed amendment to the Guidance under FEES 1.2.4 concerning supplementary fees to include a reference to systemically important firms?
    Section B: Late filing fees
15. The timely submission of regulatory returns is fundamental to the FSRA’s ability
    to discharge its supervisory responsibilities, including under federal anti￾money laundering legislation. Late or missing returns prevent the FSRA from maintaining up-to-date information about a firm’s risk profile and compliance status, and an incomplete data set cannot support timely, risk-based supervision. Late filing also generates additional administrative and supervisory costs for the FSRA.
16. FEES 1.2.7 provides for a fee of $500 where a Regulatory Filing is not submitted
    by the date on which it falls due (the “Late Filing Fee”). It applies to the subset of returns and reports defined as “Regulatory Filings” in GLO that the FSRA has identified as being of particular supervisory importance. This includes

submission of AML Returns by DNFBPs. The Late Filing Fee is currently applied once per Regulatory Filing when the due date is missed.
17. A majority of Authorised Persons, Recognised Bodies and DNFBPs submit their
Regulatory Filings on time. A small number fail to submit on time and do not promptly remedy the failure. This is not acceptable to the FSRA. The current Late Filing Fee, introduced in 2023, has not reduced the incidence of late filings, has not adequately incentivised timely remediation, and does not reflect the supervisory resources required to bring firms into compliance. Accordingly, we propose increasing the existing fee of $500 to $1,000 to better reflect the effort involved. We also propose changing how the fee is applied so it is automatically charged on the first day a Regulatory Filing is overdue and automatically re￾applied at two further intervals where the Regulatory Filing remains outstanding.
18. As per the Guidance under FEES 1.2.2, references to days mean business days.
Table 2 – Late Filing Fees
Trigger Fee applied ($) Cumulative ($)
Regulatory Filing becomes overdue – fee applied automatically on day 1 overdue 1,000 1,000 Two weeks overdue – fee applied automatically on day 11 overdue 1,000 2,000 Four weeks overdue – fee applied automatically on day 21 overdue 1,000 3,000
19. The proposed Late Filing Fee is capped at a cumulative total of $3,000 per
overdue Regulatory Filing. Once that cap is reached, the matter will be referred for escalation, including, where appropriate, formal enforcement action. The structure is intended to recognise the supervisory effort involved in addressing overdue Regulatory Filings in the interim, and to give a firm that has missed a deadline a clear incentive to rectify promptly.
20. Each further period of two weeks during which a Regulatory Filing remains
outstanding generates a further round of administrative and supervisory work, including renewed follow-up and the continued monitoring of an incomplete data set. The cumulative cap of $3,000 preserves proportionality.
21. We propose accompanying Guidance to provide transparency that the Late
Filing Fee will be applied automatically upon a filing deadline being missed.

Requests for an exemption or extension must be received at least 10 business days before the filing deadline and are only likely to be granted in exceptional circumstances. Once applied, a Late Filing Fee is unlikely to be waived. Question 5 What are your views on the proposed increase in the Late Filing Fee? Question 6 Do you have any feedback on the proposed application of the increased Late Filing Fee at two further intervals?
22. Feedback has indicated that the fees applicable to certain variations of an FSP
could be made clearer. The FSRA proposes clarifying FEES 2.1 so that a variation to the description of a Regulated Activity clearly falls within the scope of FEES 2.1(d), now proposed to be renumbered as FEES 2.1.4. However, where a firm varies the description of a Regulated Activity to include VAs, FRTs or SCs within an existing permission, only the fee pursuant to FEES 3.17.1(a) or 3.19.1(a), as applicable, will be payable.
23. We also propose Guidance clarifying the fee treatment where an Authorised
Person with permission to conduct Islamic Financial Business seeks to add Regulated Activities that will also be conducted in a Shari’a-compliant manner. The clarification is intended to ensure consistent treatment and avoid unintended duplication of fees.
24. Minor amendments to GEN to mirror the language relating to changes to the
description of a Regulated Activity are proposed.
Question 7
Do you agree with the proposed clarification of the fees payable for variations of an FSP?
25. A transaction described as a CiC may, in substance, involve extensive changes
to one or more of an Authorised Person’s ownership, business model, governance, management or Regulated Activities such that the circumstances could in essence be considered an ‘FSP for Sale’. In such circumstances, the
Section D: Controller applications involving substantial change
Section C: Fees for varying an FSP

regulatory assessment may be comparable in scope and resource intensity to a new authorisation.
26. FEES 6.1.1 and its accompanying Guidance contemplate a supplementary fee
where assessing a CiC application will require substantial additional expense or effort. The FSRA proposes additional Guidance in FEES, GEN and GPM confirming that, where appropriate, the supplementary fee may be equivalent to that applicable to a new authorisation and that a longer period to assess the CiC application may be warranted.
27. These clarifications are not intended to affect the genuine acquisition of an
operating business where the existing business and control environment remain substantially in place. Question 8 Do you have any comments on the proposed Guidance on Controller applications?
28. The FSRA has received applications from recently authorised firms seeking to
vary their FSP by adding new Regulated Activities within 12 months of licensing. Such applications may require substantial reassessment and raise questions about whether the firm accurately described its intended regulatory footprint during authorisation.
29. The FSRA proposes Guidance highlighting that it will not usually grant such
VOPs within 12 months of issuing an FSP. The Guidance preserves our discretion to approve an application where the circumstances warrant it. Question 9 Do you have any comments in relation to the proposed Guidance on VOPs within 12 months of authorisation?
30. We propose confirming that, ordinarily, the time allowable for payment of an
invoice for fees will be 20 business days from the date the relevant invoice is issued.
31. FEES 1.2.6 excludes Late Filing Fees from the late payment provisions. We
propose removing this exclusion and treating all failures to pay any fees on time the same way.
Section E: Variations of an FSP within 12 months of authorisation
Section F: Miscellaneous

32. We propose minor revisions to confirm that the additional application fee for
    VAs and FRTs pursuant to FEES 3.17 applies to Providing Money Services by way of Fiat-Referenced Token Intermediation, but not to the Regulated Activity of Issuing a Fiat-Referenced Token.
33. We have taken the opportunity to propose minor numbering changes,
    typographical corrections and tidying amendments to FEES, GEN and GPM. Question 10 Do you have any feedback on the proposed miscellaneous amendments?
34. Subject to consultation, completion of the rule-making process under FSMR
    and Board approval in relation to FEES, the FSRA proposes that the amendments set out in this paper take effect on 1 January 2027.
35. This will mean that revised annual supervision fees would apply for the 2027 fee
    year, and would be invoiced on that basis in December of 2026. The revised Late Filing Fee will apply where the due date for the relevant Regulatory Filing falls on or after 1 January 2027.
36. The FSRA intends to communicate the final amendments before their
    implementation and to update FSRA Connect accordingly. The final implementation approach will take account of consultation feedback and systems readiness. Question 11 Do you have any comments on our proposals for implementation? The proposed legislative amendments are set out in the following documents.

• Appendix 1 Proposed amendments to FEES
• Appendix 2 Proposed amendments to GEN
• Attachment 1 Proposed amendments to GPM
  Appendices and Attachment
  Section G: Implementation