How to Apply for an FSRA Virtual Asset Licence in ADGM
An ADGM virtual asset licence is a Financial Services Permission granted by the Financial Services Regulatory Authority covering one or more ordinary Regulated Activities under the Financial Services and Markets Regulations 2015, because ADGM abolished its bespoke crypto category in February 2020 and now maps virtual asset business onto the underlying Regulated Activities, subject to the virtual asset rules in COBS Chapter 17.
ADGM is the jurisdiction where the thing most people search for does not exist. There is no ADGM crypto licence, because the FSRA abolished that category in February 2020, and there is no central FSRA list of approved tokens, because the rules make each firm publish its own. Both absences are deliberate design choices, and both change how an application is scoped. This guide follows the FSRA’s published framework and marks the points where the record stops rather than filling them in. LEXNOVA is not a law firm. It is a lawyer-matching service; it does not prepare, submit or assess licence applications and does not give legal advice.
LAST REVIEWED 22 SEPTEMBER 2026
WHO THIS GUIDE IS FOR
Exchanges, brokers, custodians, asset managers, advisers and token teams considering ADGM as a base; firms already holding a Financial Services Permission who are adding virtual asset business; compliance leads building an Accepted Virtual Asset assessment process; and anyone outside ADGM working out whether their promotions are capable of having an effect inside it.
ADGM Abolished Its Crypto Category in February 2020
In February 2020 the FSRA abolished the bespoke category Operating a Crypto Asset Business and mapped virtual asset business onto the underlying Regulated Activities instead, renaming Crypto Asset to Virtual Asset to align with FATF terminology. There has been no standalone crypto licence in ADGM since.
The regime runs under the Financial Services and Markets Regulations 2015, with principal guidance in Guidance – Regulation of Virtual Asset Activities in ADGM, version VER07.100625 of 10 June 2025. The modules that bite are COBS Chapter 17 plus COBS 3, 6, 12, 14, 15 and 16; GEN; the AML Rulebook; MIR for multilateral trading facilities; PRU Chapter 3 for capital; CMC for market abuse; and FEES.
A Virtual Asset is a digital representation of value that can be digitally traded and functions as a medium of exchange, a unit of account, or a store of value, but has no legal tender status in any jurisdiction. It is expressly distinguished from fiat currency, e-money, a Specified Investment, a Fiat-Referenced Token and a Spot Commodity.
The Seven VA Regulated Activities, and Mapping Your Business
A firm needs a Financial Services Permission covering the relevant VA Regulated Activity. Seven apply: Dealing in Investments as Principal; Dealing in Investments as Agent; Advising on Investments or Credit; Arranging Deals in Investments; Managing Assets; Providing Custody; and Operating a Multilateral Trading Facility.
The FSRA’s own mapping is direct. A crypto exchange maps to Operating a Multilateral Trading Facility, bringing MIR with it. Custody maps to Providing Custody. Dealing maps to Dealing in Investments as Principal or as Agent. Advising maps to Advising on Investments or Credit, and discretionary management maps to Managing Assets.
Because the mapping runs through ordinary Regulated Activities, the application is an ordinary FSP application with virtual asset rules layered on it, not a separate track. That is helpful, but it means scoping must be precise: the permission defines what you may do, and a product that quietly grows into a second activity has grown outside it.
Accepted Virtual Assets: COBS 17.2.1 Is the Gate
COBS Rule 17.2.1 states that an Authorised Person conducting any VA Regulated Activity shall not conduct such Regulated Activity with a Virtual Asset which is not an Accepted Virtual Asset. The permission lets you carry on the activity; the AVA rule determines which assets you may carry it on with.
That is a second, independent constraint, and the one most likely to be discovered late. A firm can hold exactly the right permission and still be unable to list, custody or trade a token that has not been through the AVA process, so a listing pipeline has to be built around the assessment and notification sequence.
The Seven COBS 17.2.2 Assessment Criteria
Under COBS Rule 17.2.2 the firm assesses each Virtual Asset against seven criteria: traceability and on-chain monitoring capability; security and private-key safeguarding; market profile, covering duration in existence, demand, volatility controls and sanctions screening; availability on suitably regulated exchanges; DLT infrastructure and ecosystem, covering consensus security, stress testing and decentralisation; innovation and efficiency; and practical application and functionality.
This is a self-assessment, which does not make it a light one. Several criteria — sanctions screening, consensus security, stress testing — are technical exercises requiring evidence rather than opinion, and the assessment has to stand up when the FSRA looks at it. A repeatable template with defined evidence per criterion is the practical response.
Notification: At Least Five Business Days Before Use
Having assessed a Virtual Asset, the firm submits the Notification to the FSRA of assessment of Virtual Asset for Accepted Virtual Asset status no later than five Business Days before using the Virtual Asset. The deadline runs backwards from first use, so a listing date fixes the notification date.
It is a notification rather than an application for approval, which is the source of much confusion. The firm assesses; the FSRA is told. That does not make the FSRA passive — the 10 June 2025 amendments introduced a new specific product intervention power for virtual assets — but nobody is going to tell a firm that a token is acceptable.
COBS 17.2.6: There Is No Central FSRA Token List
Anyone searching for the ADGM approved token list is looking for something that does not exist. There is no central FSRA list. COBS Rule 17.2.6 instead requires each Authorised Person to maintain, on its own website, a current list of the Accepted Virtual Assets it uses.
That list must show the name and symbol of each asset, the network it operates on, smart contract addresses where applicable, and any trading or usage restrictions. It is a public-facing compliance artefact that has to stay accurate as tokens are added and removed.
The design consequence is that the AVA universe in ADGM is firm-by-firm rather than market-wide. Two authorised firms may legitimately use different token lists, and neither list is the ADGM list, because there is no such thing.
Privacy Tokens and Algorithmic Stablecoins Are Prohibited
Two categories are prohibited outright and no assessment can bring them in. Privacy Tokens are tokens that obscure tokenholder details or transaction history through design features that cannot be disabled. Algorithmic Stablecoins are tokens using algorithms as the only or principal means to stabilise price or maintain a peg.
Neither may be issued, sold, purchased, transferred or held in custody. The Guidance cites FSMR section 5A(4), and the 10 June 2025 amendments enshrined the prohibitions in rules where they had previously been supervisory approach. A project in either category has no structuring route into ADGM.
Virtual Asset Capital, and Why It Must Be Held in Fiat
The Guidance sets virtual asset specific capital requirements. For Providing Custody, the requirement is the higher of a Base Capital Requirement of USD 250,000 or an Expenditure-Based Capital Minimum of six months of Annual Audited Expenditure. For Operating a Multilateral Trading Facility, under COBS 17.3 and MIR 3.2, it is six months of operational expenses plus a buffer of up to a further six months unless the FSRA directs otherwise. These are regulatory capital requirements, not fees.
All regulatory capital must be held in fiat form. For a crypto-native balance sheet that is substantive rather than technical: capital cannot be held in the assets the business trades, which changes treasury policy, banking requirements and the sizing of a fundraise.
This guide publishes no ADGM prudential Category 1 to 5 mapping for virtual asset activities, because that mapping is not established on the sources checked. Where the prudential category drives a structuring decision, confirm it with the FSRA and a lawyer rather than inferring it.
Fiat-Referenced Tokens Are a Separate Asset Class
A Fiat-Referenced Token is expressly excluded from the definition of a Virtual Asset in ADGM. It is a separate asset class with its own rules, so the Accepted Virtual Asset machinery does not govern an FRT, and a firm cannot reason across from one regime to the other.
Phase 1 was announced on 5 December 2024 following Consultation Paper No. 7 of 2024, making the issuance of an FRT a distinct Regulated Activity. The requirements, as the FSRA describes them, include strict requirements on the constituents of reserve assets, minimising variability in FRT value, holder rights to redeem at par value within defined timeframes, clear capital adequacy requirements and business restrictions, and periodic independent attestation and stress testing.
Phase 2, reaching beyond issuance, was finalised on 31 October 2025 following Consultation Paper No. 9 of 2025 and took effect on 1 January 2026, through the FSRA Rules (Fiat-Referenced Tokens) and the FSRA FEES Rules (Fiat-Referenced Tokens). The granular rule text — permitted reserve currencies, redemption timeframes, exact capital figures and custody-of-reserves requirements — is not established on the sources checked, and no numbers for it appear here.
Staking, and the 10 June 2025 Amendments
The FSRA Rules (Staking) were finalised on 29 April 2026 following Consultation Paper No. 10 of 2025. Only certain categories of Authorised Person may stake clients’ virtual assets; rewards are limited to Accepted Virtual Assets and Accepted Fiat-Referenced Tokens; prescribed key terms, client disclosures and client reporting apply; and the rules extend to non-Proof-of-Stake models with materially similar characteristics. The commencement date is not established on the sources checked.
The 10 June 2025 amendments, following Consultation Paper No. 11 of 2024 and taking immediate effect, revised the process for accepting virtual assets as Accepted Virtual Assets, refined capital requirements for virtual asset firms, introduced a new specific product intervention power for virtual assets, enshrined the privacy token and algorithmic stablecoin prohibitions in rules, and expanded the investment scope for Venture Capital Funds.
The product intervention power is the one to watch commercially. It gives the FSRA a targeted tool aimed at virtual assets specifically, sitting behind the self-assessment model — firm-led acceptance is not the same as an absence of regulatory control.
FSMR Section 16 and Section 18: Who Is Caught
FSMR section 16(1) is the perimeter: no person may carry on a Regulated Activity by way of business in the Abu Dhabi Global Market, or purport to do so, unless he is an Authorised Person or an Exempt Person. As in Dubai, purporting to do so is enough.
Section 18(1) restricts financial promotion: a person must not, in the course of business, communicate an invitation or inducement to engage in investment activity. For a communication originating outside ADGM, section 18(3) applies the restriction only if the communication is capable of having an effect in the Abu Dhabi Global Market — a wider test than it first looks.
Section 18(2) provides exemptions: the person is an Authorised or Exempt Person; the person is licensed by a UAE financial regulator; the content is approved by an Authorised or Exempt Person; or the communication is exempt under Schedule 2 to the FSMR.
Reverse Solicitation in ADGM Is Not Settled
The DIFC position is express: a communication made to a person as a result of an unsolicited request by that person is exempt from the DIFC Financial Promotions Prohibition. The ADGM position is not express in the same way. No unsolicited-request exemption appears in the text of FSMR section 18 itself, and whether one sits in Schedule 2 could not be retrieved for this guide.
This page therefore neither asserts that ADGM has a reverse-solicitation carve-out nor asserts that it has none. What can be said is the comparison: the DIFC carve-out is written down and the ADGM position is not established on the sources checked. A group running one cross-border marketing policy on the assumption that reverse solicitation works identically across UAE perimeters is relying on something unverified — and in Dubai outside the DIFC, on something that demonstrably does not exist.
Mind and Management in ADGM — and How LEXNOVA Helps
The virtual asset Guidance requires Authorised Persons to commit substantive resources within ADGM across all business functions, with mind and management located in ADGM. This is a substance requirement, not a registered-address one, and it shapes hiring, seniority and where decisions are actually taken.
Two adjacent points come up alongside an ADGM build. The current employment instrument is the ADGM Employment Regulations 2024, not the 2019 Regulations. And ADGM’s Employment Affairs Office states expressly that the UAE Wage Protection System does not apply in ADGM — worth knowing before payroll is designed on a mainland template.
LEXNOVA is a lawyer-matching service, not a law firm. It does not prepare, submit, review or assess an FSP application, advise on which Regulated Activities your business falls into, carry out or check an Accepted Virtual Asset assessment, or represent anyone before the FSRA. It helps you describe your position clearly enough to be matched with a lawyer whose practice fits. Every match is reviewed by a person, and no outcome, scope or timeline is promised.
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