ADGM Conduct of Business Rulebook (COBS)chapter by chapter

Rule 2.2.1-2.2.42.2 Client Categorisation

Every Client must be categorised as Retail or Professional for each Regulated Activity, with an agent's undisclosed principal and a trust's trustee treated as the Client.

Rule 2.4.2-2.4.42.4 Deemed and Assessed Professional Clients

Establish a reasonable basis for classifying individuals and undertakings as Professional Clients by inspecting relevant documentation and applying specific asset tests.

Rule 2.5.1-2.5.22.5 Market Counterparties

Firms may classify a Person as a Market Counterparty only if it is a deemed Professional Client, given prior written notice, and did not object within the notice period.

Rule 2.6.12.6 Right to elect Retail classification / re-classification

Professional Clients must be informed of their right to elect Retail classification and its protections and consequences, and re-classified as Retail upon express request.

Rule 2.6.22.6 Assessment of knowledge and experience

Firms must apply prescribed knowledge, experience, portfolio and qualification factors when assessing an individual or undertaking for assessed Professional Client status.

Rule 2.6.3-2.6.42.6 Reliance on classification made elsewhere / Group Clients

Firms may rely on a Branch or Group client classification only if substantially equivalent with gaps addressed, and must give the Regulator unrestricted access to underlying records.

Rule 2.7.1-2.7.52.7 Record Keeping

Firms must keep client classification records and notices for at least six years after the business relationship ends, and immediately notify the Regulator if unrestricted record access lapses.

Rule 2.7.2-retRecord Retention — Client classification procedures/evidence and notices sent to Clients

Firms must retain client classification procedures, classification evidence, and notices sent to clients for six years after the client business relationship ends, or last transaction if unclear.

Rule 3.2.1-3.2.63.2 Communication of Information and Marketing Material

Firms must ensure communications are clear, fair and not misleading, must not limit statutory duties or liability, must send required information directly to clients, and must include prescribed content and past-performance disclosures in marketing material for retail clients.

Rule 3.3.2-3.3.43.3 Key Information and Client Agreement

A Client Agreement containing key information must be established before regulated activities, with 14 days notice for unilateral amendments affecting Retail Clients.

Rule 3.4.2-3.4.33.4 Suitability

Firms must assess clients' suitability for recommendations based on their needs and maintain accurate client information.

Rule 3.5.1-3.5.83.5 Conflicts of Interest

Firms must identify and manage conflicts of interest, maintain records, have a written policy, and disclose unmanaged conflicts and inducements to Retail Clients.

Rule 3.6.1-3.6.63.6 Soft Dollar Agreements

Firms accepting soft dollar goods or services must limit them to permitted categories with value-for-money assessment, disclose the arrangement and policy to clients before dealing, and provide annual cost-benefit disclosure.

Rule 3.7.1-3.7.23.7 Record Keeping

Firms must keep records of marketing material, advice, client classification, client agreements, suitability assessments, and inducement disclosures for a minimum of six years.

Rule 3.7.1(a)-retRecord Retention — Marketing Material issued

Entities must retain marketing material records for six years from the date provided to a person.

Rule 3.7.1(b)-(d)-retRecord Retention — Financial Instruments/Regulated Activities provided, advice/recommendations, Cli

Financial records including advice and client agreements must be retained for 6 years post-client relationship termination.

Rule 3.7.1(e)-retRecord Retention — Suitability assessment and inducement/Soft Dollar disclosure records

Firms must retain suitability assessment and inducement or soft dollar disclosure records for six years from the date inducements were last received.

Rule 3.7.1(g)-retRecord Retention — Financial promotions under Schedule 2 of FSMR

Firms must retain records of financial promotions under Schedule 2 of FSMR for six years from the date each promotion was made.

Rule 3.8.2-3.8.243.8 ADGM Green Portfolios and Climate Transition Portfolios

Firms branding a Retail Discretionary Portfolio as ADGM Green or Climate Transition must meet investment requirements, obtain annual third-party attestation, and report material breaches immediately.

Rule 4.2.14.2 Accepting Deposits restrictions

Firms must not accept deposits or manage unrestricted profit-sharing investment accounts from UAE markets, nor conduct UAE Dirham foreign exchange transactions for clients while doing so.

Rule 4.3.1-4.3.34.3 Providing Credit

Retail clients can only receive credit for business purposes if they are an undertaking, with specific conditions for deemed Professional Client treatment.

Rule 4.4.14.4 Depositor Protection

Banks must prioritize payments to eligible depositors over other unsecured creditors during insolvency.

Rule 5.2.2-5.2.45.2 General

Trust Services providers must keep adequate knowledge of and comply with ADGM law and Rules, demonstrate corporate governance compliance, and transact client business expeditiously.

Rule 5.3.1-5.4.15.3-5.4 Exercise of Discretion and Delegation

Obtain adequate information and conduct regular reviews before exercising discretion, ensuring fiduciary duty is upheld and delegation is controlled.

Rule 5.6.1-5.6.35.6 Professional Indemnity Insurance

Firms must maintain adequate professional indemnity insurance, provide the Regulator with a copy and notify changes, report cover annually with evidence, and notify claims exceeding US$10,000 as they arise.

Rule 5.7.1-5.8.15.7-5.8 Dual Control and Internal Reporting

Firms must maintain adequate internal controls, including two suitably skilled persons able to manage and challenge the business, plus internal reporting confirming legal compliance and sound management.

Rule 5.9.1-5.10.45.9-5.10 Adviser Selection and Staff Competence

Firms must record and monitor selection of third-party advisers for client affairs and ensure staff and recommended trustees have suitable qualifications, experience, and ongoing fiduciary training.

Rule 5.11.1-5.11.45.11 Books and Records

Firms must keep books and records sufficient to show orderly management of client affairs, prepare regular proper accounts, and allow transactions to be recreated and client assets and liabilities attributed per client.

Rule 5.12.1-5.12.25.12 Due Diligence

Firms must hold verified documentary evidence identifying settlors, trustees and principal beneficiaries of trusts, and demonstrate knowledge of the source of funds involved in transactions.

Rule 5.13.1-5.13.55.13 Fitness and Propriety of Trustees

Persons must ensure non-employee trustees are fit and proper, with pre-appointment skills checks, notify the Regulator of appointment and termination, and obtain written agreement to comply as employees.

Rule 6.2.1-6.2.46.2 Personal Account Transactions

Firms must establish employee personal account transaction controls requiring written notice, permission and no client conflicts, and must prevent Investment Analysts from personal dealing ahead of their own published research.

Rule 6.3.16.3 Record Keeping (PA Transactions)

Records of PA-dealing notices and employee determinations must be retained for a minimum of 6 years from the relevant trigger date.

Rule 6.3.1(b)-retRecord Retention — Personal Account Transaction notices, permissions, notifications and exclusion d

Personal account transaction notices, permissions, notifications and exclusion determinations must be retained for six years from employee contract termination or each permission or notification date.

Rule 6.4.2-6.4.76.4 Investment Research and Offers of Securities

Investment Analysts must have supervision procedures, conflict management, and required disclosures in their published research.

Rule 6.5.2-6.5.56.5 Best Execution

Firms must take reasonable care to achieve best execution for client transactions, weighing price, costs, speed, likelihood of execution and settlement, and other relevant factors.

Rule 6.6.1-6.7.36.6-6.7 Non-Market Price Transactions and Aggregation/Allocation

Authorised Persons must not enter non-market price transactions without reasonable steps against improper purpose, and must allocate investments promptly, fairly and with allocation records.

Rule 6.8.1-6.8.26.8 Record Keeping - Communications and Orders

Organizations must record and retain client-related transaction communications for at least 2 years and order records for at least 6 years.

Rule 6.8.1(c)(iv)-retRecord Retention — Voice and electronic communications relating to Client orders/Transactions

Client order and transaction voice and electronic communications must be retained for two years from the date of the recorded communication.

Rule 6.8.2(d)-retRecord Retention — Records of order receipt, execution and order-passing (Chapter 11 minimum conten

Records of order receipt, execution and order-passing must be kept for six years from the date the order is allocated.

Rule 6.9.2-6.9.66.9 Other Dealing Rules

Transactions must be executed promptly and fairly without churning, and allocations must be accurate.

Rule 6.10.2-6.10.36.10 Confirmation Notes

Firms must send a confirmation note to the client or counterparty within two days of transaction execution, containing prescribed content, and retain a copy for at least six years from despatch.

Rule 6.10.3-retRecord Retention — Confirmation notes

ADGM COBS firms must retain confirmation notes for six years from the date of despatch.

Rule 6.11.2-6.11.36.11 Periodic Statements

Firms must give Investment Management and Contingent Liability clients periodic statements at the prescribed interval, and keep a copy of each statement for at least six years from provision.

Rule 6.11.3-retRecord Retention — Periodic statements

Periodic statement records must be retained six years from the date the statement was provided.

Rule 6.12.1-6.12.36.12 Information to Prime Brokerage Clients

Prime brokerage clients must receive daily statements showing values of safe custody assets and client money, plus prescribed collateral and exposure items, by close of the next day.

Rule 7.2.2-7.2.87.2 Insurance Business and Intermediation Restrictions

Firms must not write or intermediate UAE-situated risk business outside permitted free-zone or reinsurance scope, and must use only appropriately licensed and experienced insurance intermediaries under written terms of business.

Rule 7.3.1-7.3.27.3 Communication of Information and Marketing Material

Firms must keep insurance communications clear, fair and not misleading, market only suitable contracts of insurance, and promptly withdraw and correct any misleading information they have issued.

Rule 7.4.1-7.5.77.4-7.5 Duty of Disclosure (Client and Authorised Person)

Clients must disclose insurer identity, contact and claims-notification details, whether advice is based on fair market analysis, and their agency capacity, and explain consequences of non-disclosure.

Rule 7.6.1-7.6.57.6 Disclosure of Costs and Remuneration

Firms must disclose all premiums, fees, charges and taxes for each contract or service, including credit facility costs used to pay premiums, before imposing new costs.

Rule 7.7.1-7.8.77.7-7.8 Product Information, Suitability and Advice

Firms must give clients adequate, timely information for informed decisions, apply suitability checks to retail long-term insurance, obtain acknowledgement of declined advice, and disclose whether advice is given.

Rule 7.9.1-7.10.57.9-7.10 Placement, Ongoing Service and Claims

Insurance intermediaries must place cover only with lawfully permitted insurers, document and confirm policies promptly, handle amendments, renewals and claims fairly, and notify policy or legislative changes.

Rule 7.11.5-7.11.147.11 Insurance Monies

Firms must segregate insurance monies in designated insurance bank accounts, hold them only in those accounts or approved assets, and dispose of downgraded assets within 30 days.

Rule 7.11.15-7.11.167.11 Untraceable Client credit balances

A firm may only take credit for an untraceable client balance after reasonable tracing efforts and at least six years after the client was notified, and must keep withdrawal records for six years.

Rule 7.11.16-retRecord Retention — Records of sums withdrawn from untraceable Client credit balances

Records of sums withdrawn from untraceable client credit balances must be retained for six years from the date of withdrawal or realisation.

Rule 7.12.1-7.12.47.12 Conflicts of Interest

Firms must identify and manage conflicts of interest affecting insurance, intermediation and management clients, disclose unmanageable conflicts in writing, and decline to act where conflicts cannot be managed.

Rule 7.13.1-7.13.27.13 Product Development

Insurance product development must consider target client segments, product characteristics, distribution suitability and risk appetite, with retained oversight where development is outsourced.

Rule 8.2.18.2 General MIR cross-compliance

An MTF or OTF Operator must comply with the applicable Recognised Body requirements, covering systems, trade recording, membership, market abuse, trading transparency, settlement, clearing and default rules.

Rule 8.4.1-8.4.58.4 Liquidity Incentive Schemes

Liquidity incentive schemes may only be introduced after member due diligence, a written participant agreement and prior regulator approval, with scheme details lodged at least 10 days before approval and advance announcement.

Rule 8.5.2 and 8.6.1-8.6.88.5-8.6 MTF and OTF-specific restrictions

MTF operators must not execute client orders against proprietary capital or engage in matched principal trading; OTF operators face limits on own-account dealing and discretion.

Rule 9.2.1-9.2.109.2 Quality of the Rating Process

Rating agencies must apply rigorous, consistently applied rating methodologies, assign ratings at agency level, avoid misrepresentation, and maintain a methodology review function.

Rule 9.4.1-9.4.39.4 Monitoring and Updating

Firms must allocate adequate resources to monitor and update published ratings on an ongoing basis, and announce discontinued ratings to the public or subscribers as applicable.

Rule 9.5.1-9.6.59.5-9.6 Integrity and Independence of the Rating Process

Credit rating agencies must act honestly, avoid advance rating assurances, appoint an independent compliance officer, require staff to report misconduct, and keep ratings free from business-relationship influence.

Rule 9.7.1-9.8.79.7-9.8 Conflicts of Interest and Analyst Independence

Firms must adopt written conflicts of interest procedures, disclose analyst compensation and revenue concentration, prohibit analyst trading or gift-taking that could compromise objectivity, and review departing analysts' past work.

Rule 9.9.1-9.9.99.9 Transparency and Timeliness of Ratings Disclosure

Rating providers must distribute rating decisions promptly and publicly disclose their distribution policies, methodologies, historical default rates, and material methodology changes, indicating basis, dates, and whether solicited.

Rule 9.10.1-9.11.39.10-9.11 Confidential Information and Market Communication

Confidential issuer information must be protected from misuse, employee trading on it is prohibited, and a market communication function must handle complaints and concerns.

Rule 9.12.1-9.139.12-9.13 Ancillary Services and Fees

Do not provide prohibited consultancy services to Rating Subjects, ensure operational separation of any permitted ancillary services, and avoid outcome-contingent rating fees.

Rule 9.14.1-9.14.59.14 Remuneration and Reporting Lines

Rating-involved employees' remuneration and reporting lines must be structured to manage conflicts and not be linked to rating revenue, with periodic formal remuneration policy reviews.

Rule 9.15.1-9.15.2-retRecord Retention — Credit Rating records (analysts, approvals, supporting information, fees, method

Credit rating records, including analyst details, approvals, supporting information, fees, methodology and communications, must be retained for six years from the date the rating is publicly disclosed or distributed by subscription.

Rule 9.15.1-9.15.49.15 Record Keeping

Credit rating agencies must retain records for at least six years from public disclosure, covering analysts, approvals, fee and subscriber accounts, methodologies and rating communications.

Rule 10.3.1-10.3.310.3 Additional requirements for CSDs

Central securities depositories must maintain rules and accounting practices ensuring securities-issue integrity and a definitive record of title, record book-entry securities before trade date, prevent unauthorised record changes, reconcile intraday, and prevent overdrafts.

Rule 10.4.1-10.4.210.4 CSD Links

Before establishing a CSD link, firms must assess link risks, including DVP settlement and intermediary risk, maintain ongoing controls, and notify the Regulator of due-diligence results.

Rule 12.1.2-12.1.412.1 Core and Additional Key Information

Every client agreement must include prescribed core information such as fees, regulatory status, conflicts and complaints procedures, plus extra disclosures for investment business and management.

Rule 14.2.1-14.2.314.2 General Requirements

Category 4 authorised persons must comply with Client Money Rules, keep client money identifiable and secure, report material non-compliance to the Regulator without delay, and generally not hold or control client money.

Rule 14.4.1-14.5.414.4-14.5 Payment into Client Accounts

Firms must pay client money into a client account within one day of receipt, record client money promptly, avoid holding own money in client accounts, and keep cheque and payment order records for six years.

Rule 14.5.3-14.5.4-retRecord Retention — Records of cheques and payment orders received

Records of cheques and payment orders received must be kept for six years from the date of receipt.

Rule 14.6.1-14.6.314.6 Client Accounts and Master List

Firms must hold Client Accounts with third-party agents in the prescribed name and keep a current master list of Client Accounts, retained for at least six years after closure.

Rule 14.6.3-retRecord Retention — Client Account master list details

Firms must retain Client Account master list details for six years from Client Account closure date.

Rule 14.7.1-14.7.714.7 Third-Party Agent Appointment

A firm must assess and conclude that a third-party agent is suitable before depositing client money with it, obtain written segregation and no-set-off acknowledgement, and monitor suitability ongoing.

Rule 14.8.1-14.9.314.8-14.9 Payment out of Client Accounts and Client Disclosure

Firms must authorise all client account withdrawals for permitted purposes only, prevent cross-client use of client money, and disclose money holding basis and protections to clients in writing, with opt-out acknowledgments from market counterparties.

Rule 14.10.1-14.10.314.10 Client Reporting

Firms must send Retail Clients a Client Money statement at least monthly, prepared within one calendar month, showing balances and movements since the last statement.

Rule 14.11.1-14.11.914.11 Reconciliation

Client Accounts must be reconciled at least monthly and completed within 10 days, with senior review, notification of material discrepancies, and records kept for six years.

Rule 14.11.9-retRecord Retention — Client Money reconciliation records

Client Money reconciliation records must be retained for six years from the date of the reconciliation.

Rule 14.12.1-14.13.614.12-14.13 Deemed Trusts and Client Money Distribution

Client money must be held in deemed-trust, with distributions made per priority during a Pooling Event, and shortfalls covered by the account provider's funds.

Rule 15.2.2-15.3.315.2-15.3 General Requirements and Recording

Authorised persons must comply with Safe Custody Rules, hold safe custody assets separately from their own investments, and control mandate accounts through recorded instructions and current lists.

Rule 15.4.1-15.4.615.4 Client/Reserve Accounts and Master List

Firms must hold client custody assets in properly titled accounts, keep a master list for six years after closure, and use client assets only with written permission.

Rule 15.4.3(b)-retRecord Retention — Client/Reserve Account master list details

Licensed firms must retain Client and Reserve Account master list details for six years from the date the account is closed.

Rule 15.5.1-15.6.215.5-15.6 Third-Party Agents and Safe Custody Agreements

Firms must assess a Third-Party Agent's suitability before placing Safe Custody Assets with it, obtain its written acknowledgement, disclose offshore asset holding, and keep records for six years.

Rule 15.6.2-retRecord Retention — Safe Custody Asset records held by a Third-Party Agent (assets, agreements, inst

Records of Safe Custody Assets held by a Third-Party Agent, including assets, agreements and instructions, must be retained for a minimum of six years while the assets remain held.

Rule 15.7.2-15.8.315.7-15.8 Client Disclosure and Reporting

Firms must disclose required information to clients prior to custody services and provide retail clients with account statements every 6 months.

Rule 15.9.1-15.9.615.9 Reconciliation

Firms must reconcile third-party agent statements monthly, count and reconcile held assets and client ledger balances every six months, and notify the Regulator of unrectified material discrepancies.

Rule 15.11.1-15.11A.515.11-15.11A Collateral and Title Transfer Collateral Agreements

Collateral holders must disclose holding terms, send six-monthly collateral statements, avoid title transfer collateral agreements with retail clients, and keep title transfer collateral agreement records for six years after termination.

Rule 15.11A.5-retRecord Retention — Title Transfer Collateral Agreement records (incl. instructions/notifications)

Firms must keep title transfer collateral agreement records, including instructions and notifications, for six years from the date the agreement is terminated.

Rule 15.12.1-15.13.115.12-15.13 Record Keeping and Notification of Non-Compliance

Firms must retain Safe Custody records for six years after account closure and notify the Regulator in writing without delay of material non-compliance.

Rule 15.12.2-retRecord Retention — Safe Custody Rules compliance records (Safe Custody Assets and Collateral entrie

Safe custody compliance records, including safe custody assets and collateral entries, must be retained for six years from client account closure.

Rule 16.2.1-16.2.1416.2 Resolution Pack Maintenance and Retrieval

Firms must maintain a resolution pack retrievable within 48 hours of insolvency appointment, correct material inaccuracies within 5 days, and notify the regulator of any inability to comply immediately.

Rule 16.3.1-16.4.216.3-16.4 Core Content Requirements

Firms must include in the Resolution Pack the master retrieval document, identification documents, executed third-party and Group agreements, procedures manual, and specified client money records.

Rule 17.2.1-17.2.617.2 Accepted Virtual Assets

Firms may only conduct regulated activities using Accepted Virtual Assets, must notify the Regulator five business days before activity with any new asset, and maintain a published list.

Rule 17.2A.117.2A Accepted Fiat-Referenced Tokens

Only Accepted Fiat-Referenced Tokens may be used for any regulated activity involving fiat-referenced tokens, such as transfer, safekeeping or payment.

Rule 17.5.117.5 Technology Governance and Controls

Firms must maintain systems and controls for wallet lifecycle management, private and public key management, transaction monitoring, a security plan, and a risk management plan.

Rule 17.6.117.6 Additional Disclosure Requirements

Firms must disclose all material risks of products, services, Virtual Assets and the specific Accepted asset clearly, fairly and not misleadingly before the initial transaction with a Client.

Rule 17.7.2-17.8.517.7-17.8 MTF and Custody-specific Adaptations

Virtual asset MTF operators must follow MTF and market integrity requirements, while virtual asset custodians must give retail clients monthly statements, reconcile weekly, and vet third-party custodians.

Rule 17.9.117.9 Client Money Reconciliation Adaptation

Virtual asset-related authorised persons holding client money must reconcile client accounts at least weekly, within five days.

Rule 17.10.2-17.10.717.10 Staking

Staking client virtual assets requires prior regulator advice, disclosure of staking terms and risks, client termination rights, and due diligence plus a written agreement with any provider.

Rule 18.3.1-18.4.118.3-18.4 Access, Publication and Due Diligence

Obtain client risk acknowledgment prior to access; only publish compliant financing proposals after due diligence on PFP prospects.

Rule 18.5.1-18.5.218.5 Disclosure

Platforms must publish prescribed disclosures on risks, conflicts, custodian details, wind-down and exit arrangements, and update them promptly with notice to clients on material changes.

Rule 18.6.1-18.7.118.6-18.7 Client Assets and Record Keeping

Client assets must be held only through an eligible custodian or under client money or safe custody rules, intermediary bodies must be ADGM-domiciled, and due diligence and transaction records kept for six years.

Rule 18.7.1-retRecord Retention — PFP disclosures, transaction documentation and due-diligence records

Records of PFP disclosures, transaction documentation and due-diligence records must be retained for six years from the date each record was created.

Rule 18.8.2-18.8.318.8 Exit Facility

When offering an exit facility, provide specific information to clients and restrict certain activities as outlined.

Rule 19.2.1-19.4.119.2-19.4 Contracts and Pre-Contract Information

Payment service providers must give the prescribed framework contract information before the user is bound, provide two months' notice of changes, and observe termination and no-charge rules.

Rule 19.5.1-19.5.319.5 Post-Initiation Information

After a Payment Order initiation, immediate provision of essential payment information is required to both Payer and Payee.

Rule 19.7.1-19.8.119.7-19.8 Safeguarding and Record Keeping

Physical cash may only be handled via regulated financial institution intermediaries; relevant money and fiat-referenced tokens must be safeguarded in restricted-use payment accounts, with records kept six years.

Rule 19.8.1-retRecord Retention — Payment Service Provider records (Relevant Money/FRT received, agreements, Payme

Payment Service Providers must retain records of Relevant Money or FRT received, agreements, and Payment Transactions for six years from the date each record was created.

Rule 19.10.1-19.12.119.10-19.12 Authorisation, Instrument Limits and Unknown-Amount Transactions

Payment transactions are authorised only with the payer's consent, subject to withdrawal rights; spending limits and blocking of payment instruments require prompt payer notice and regulator incident reporting, and unknown-amount card transactions may only block funds under prescribed conditions.

Rule 19.13.1-19.15.519.13-19.15 Refunds, Execution Time and Stored Value

Rules require refunds of qualifying payee-initiated transactions within an eight-week request window, next-day crediting of payee accounts, and stored value redemption at par value.

Rule 19.16.119.16 Authentication

Strong Customer Authentication is mandatory for online access and risk-bearing transactions, with security measures for protecting Personalised Security Credentials.

Rule 19.17.1-19.21.519.17-19.21 Notification, Liability and Defective Execution

Firms must refund unauthorised transactions by the day after becoming aware, bear the burden of proving authentication, and remedy non-executed or defective transactions, including tracing on request.

Rule 19.22.1-19.23.219.22-19.23 Dispute Resolution and Risk Mitigation

Firms must maintain complaint procedures resolving complaints within 15 days, publish dispute-resolution details, run an operational and security risk framework, assess risk annually, and report major incidents to the Regulator promptly.

Rule 19.24.1-19.24.219.24 Purchase and Sale of Fiat-Referenced Tokens

Before buying or selling fiat-referenced tokens with customers, establish a non-discriminatory commercial policy and publish pricing, fee and limit information on the website.

Rule 19A.2.1-19A.2.419A.2 White Paper

Issuers must submit a white paper to the regulator at least 20 days before issuance, publish and maintain it while the token circulates, and update it for inaccuracies or annually.

Rule 19A.3.1-19A.4.119A.3-19A.4 Restricted Activities and Redemption

Regulated Activities related to FRTs must not exceed incidental aspects, and token redemption must occur at par within T+2 following customer due diligence completion.

Rule 19A.5.1-19A.6.119A.5-19A.6 Reserves and Segregation

Issuers of fiat-referenced tokens must hold proceeds as client money or reserve investments, denominate reserves in fiat currency, segregate reserves per token, and notify the regulator before material investment changes.

Rule 19A.7.1-19A.8.319A.7-19A.8 Minimum Value and Stress Testing

Reserve Assets' market value must at all times equal or exceed outstanding redemption claims, verified by daily valuation, with immediate notice of breaches and annual stress testing.

Rule 19A.9.1-19A.10.219A.9-19A.10 Attestation and Audit

Licensed firms must obtain monthly independent third-party attestation of reserve or relevant money adequacy, and an annual independent audit of reserve investments and internal controls submitted within four months of year end.

Rule 19A.11.1-19A.11.619A.11 Treatment of Holder Claims

Firms holding client money or reserve assets must recognise holders' pro-rata claims, take steps to give holders priority over other creditors for assets held outside ADGM, and liquidate and distribute reserve investments on minimum-value breaches or pooling events.

Rule 20.2.1-20.3.220.2-20.3 Governing Contract and Transaction Information

Firms must sign a Governing Contract with prescribed content before providing Third Party Services, give at least two months' notice of changes, provide post-initiation Transaction information, and observe termination-notice and no-charge-after-six-months rules.

Rule 20.5.1-20.6.120.5-20.6 Record Keeping and Outsourcing

Firms must retain transaction records, specified information and onboarding information for at least six years from creation, and ensure outsourced third-party operational functions comply with rules.

Rule 20.5.1-retRecord Retention — Third Party Provider records (transactions, agreements, Specified Information re

Firms must retain records of Third Party Provider transactions, agreements and Specified Information requests or access for 6 years from the date each record was created.

Rule 20.7.1-20.9.320.7-20.9 Authorisation and Authentication

Third Party Transactions are authorised only with customer consent, subject to withdrawal and revocation rights; firms must protect personalised security credentials and apply strong customer authentication.

Rule 20.10.1-20.12.620.10-20.12 Notification, Evidence and Liability

Firms must handle customer reports of unauthorised third-party transactions within 12 months, refund qualifying ones by the next day, and bear the burden of proving authentication.

Rule 20.13.1-20.15.120.13-20.15 Dispute Resolution, Risk Mitigation and Interfacing Systems

Firms must maintain complaint resolution procedures resolving complaints within 15 days, an operational and security risk framework with annual risk assessment, and Interfacing System attestations supported by independent third-party reports.

Rule 21.3.2-21.3.621.3 Administering a Specified Benchmark

Benchmark administrators must maintain governance arrangements and a benchmark administration manager, use representative data, report to the Regulator, monitor manipulation, and grant fair access.

Rule 21.4.2-21.4.421.4 Specified Benchmark Information Providers

Specified benchmark information providers must maintain conflict-free governance, information integrity controls, communication records, cooperation with regulators, and documented rationale for judgments.

Rule 22.2.1-22.3.222.2-22.3 Accepted Spot Commodities and Sustainable Sourcing

Firms may only deal in Accepted Spot Commodities approved by the Regulator and must maintain arrangements ensuring responsible and sustainable sourcing standards such as ISO 14001, ISO 45001 and OECD due diligence guidance.

Rule 22.4.1-22.5.122.4-22.5 Delivery, Storage and Title

Delivery and storage facilities must meet specified regulatory and insurance standards, with required monitoring and control arrangements for various operational aspects.

Rule 22.7.1-22.8.322.7-22.8 MTF/OTF and Custody Adaptations

Operators of exchanges, MTFs or OTFs in accepted spot commodities must apply COBS Chapter 8, and custodians must apply COBS Chapters 14-16 with weekly reconciliations.

Rule 22.9.1-22.9.322.9 Spot Commodity Auction Platforms

Auction Platforms must operate with Regulator approval, ensuring fair practices through effective systems, transaction recording, and market integrity measures.

Rule 23.3-23.4.823.3-23.4 Marketing and Risk Disclosure Statement

Marketing and educational material must link to the risk disclosure statement, which must be provided to retail clients before onboarding, annually, and published on the website.

Rule 23.5.1-23.5.323.5 Appropriateness Assessment

Firms must assess retail client skill, experience, knowledge, financial resources and risk tolerance before offering or advising on OTC leveraged products, reassess annually or on material change, and retain records.

Rule 23.6-23.823.6-23.8 Margin, Close-Out and Negative Balance Protection

Firms must require prescribed margin before opening retail positions, close out positions when net equity falls below 50% of margin, and limit retail client liability to trading account funds.

Rule 23.9-23.1123.9-23.11 Incentives, Referrals and Liquidity Providers

Retail clients must not receive promotions or bonuses, and firms must ensure that their brokers do not promote or reward unregulated referrals.

Rule 23.12.1-23.12.323.12 Additional Restrictions

Firms must not offer retail clients OTC leveraged products lacking two-way pricing or resembling binary options, nor copy trading without managing assets permission, and must prevent credit card funding.