ADGM's crypto mining guidance: who needs which licence

What ADGM published

In October 2026 the Registration Authority of Abu Dhabi Global Market (the RA) published its Guidance on Crypto Mining Activities in and from ADGM. ADGM describes it as the first dedicated crypto mining guidance from an international financial centre in the region. It was issued under section 23 of the Commercial Licensing Regulations 2025, follows an eight week public consultation held earlier in the year, and is the first of two phases: the RA has said it will consult separately on a fuller regulatory framework.

The tone is welcoming. "With this Guidance, ADGM is open to responsible crypto mining," said H.E. Rashed Al Blooshi, CEO of the RA. The substance is a clear licensing route with real transparency obligations attached.

Mining is a commercial activity, not a financial service

The guidance starts from a simple position. Crypto mining is not a regulated financial service, so a mining business does not need approval from the Financial Services Regulatory Authority (FSRA). It is, however, a business activity, and no one may carry on a business activity in or from ADGM without a licence from the RA. A mining business therefore registers with the RA and obtains a Commercial Licence that lists crypto mining, business activity code 7230.

The approach is technology neutral. It covers the core activity of validating transactions and securing a blockchain network, whatever the consensus mechanism: Proof-of-Work, Proof-of-Stake or anything that comes later. Solo validation for your own account under Proof-of-Stake is treated the same way as Proof-of-Work mining.

Two things fall outside the guidance. Small scale mining by individuals for personal purposes is generally out of scope. So is running nodes or validators incidentally, as infrastructure for some other licensed business, provided the entity earns no material revenue from block rewards or validation and does not hold itself out as offering mining or validation services. The RA keeps the right to look through an "incidental" label where the scale, revenue or intent says otherwise.

Where the RA ends and the FSRA begins

The most useful part of the guidance is its perimeter test. Before applying, the RA expects an applicant to work through a four step self-assessment. The answer turns almost entirely on whose assets are involved.

The RA's commercial licence is likely to be enough where:

• the operator mines or validates using its own capital and equipment, and the rewards go to its own account; or
• the operator provides technical infrastructure only, such as node hosting or hardware, without ever holding or controlling a client's digital assets.

An FSRA permission may be needed as well where the operator:

• receives, holds or controls digital assets belonging to third parties for staking or validation;
• exercises discretion over third party assets, for example choosing staking protocols or managing validator keys for clients, which the guidance says is likely to be a regulated activity;
• pools third party capital or digital assets for collective staking or mining;
• receives, transmits or distributes staking rewards on behalf of others, or lets third parties bear the risk of losing assets under the operator's control; or
• markets a service as yielding a return on digital assets that clients deposit or entrust to it.

The regulated activities the RA has in mind are Providing Custody and Managing Assets under the Financial Services and Markets Regulations 2015. A business that does both, such as a miner that also runs a staking service for clients, applies separately to the RA and the FSRA, shows the RA which parts of the business are own account and which involve client assets, and must be able to show both regulators how it keeps those boundaries.

Anti-money laundering

Crypto mining is not a virtual asset service provider activity. A mining entity that offers no VASP services is currently outside the federal and ADGM anti-money laundering regimes. One that also safeguards or administers digital assets for others is inside them, with the full set of obligations. The RA is careful to add that mining is not free of financial crime risk, which is why the transparency and record keeping expectations below apply to everyone.

What the RA will ask for

On top of the standard licence application, the RA may ask applicants, especially larger operations, for:

• a detailed operational plan: hardware and its efficiency, software, projected scale such as hash rate and number of units, the operational workflow, the physical location in ADGM, and a risk management framework;
• an infrastructure, security and resilience plan: physical security, cybersecurity aligned with recognised frameworks such as ISO 27001 or NIST, heat management, and business continuity and disaster recovery plans; and
• disclosure of on-chain assets: the wallet and smart contract addresses that receive or manage mining or validation rewards.

The reward-flow disclosure is the novel part. The RA treats the addresses as confidential supervisory information, handled through secure channels and not published. Operators notify material or structural changes, such as moving to a new custody provider, not routine address rotation for security. The RA may use third party tools to monitor those addresses.

Ongoing obligations and supervision

A licence for crypto mining comes with specific conditions. In practice that means:

• up to date beneficial ownership, management and structure records with the RA, and prompt notice of material changes under the Beneficial Ownership and Control Regulations 2022;
• clear terms, fees, risks and asset handling information for any clients, where the miner offers services to third parties; and
• risk based supervision, which can include off-site review, information requests, third party audits or attestations, thematic reviews and on-site inspections, including overseas and in some cases unannounced.

Breaches can lead to warnings, financial penalties, directions to remediate and, in serious cases, suspension or revocation of the licence.

Running global mining from an ADGM headquarters

Many mining groups run their machines where power is cheap and their management where the law is good. The guidance anticipates this. An ADGM entity that is itself licensed for crypto mining and oversees operations abroad may have to disclose its global footprint: the countries it mines in, the scale and structure of each operation, and the ownership and key people of its overseas subsidiaries.

The RA expects proportionate due diligence on host jurisdictions and major partners, and reasonable oversight of overseas operations. That means governance and accountability, not day to day control: ADGM-standard reporting lines and, where practicable, contractual commitments from overseas subsidiaries and contractors. Significant compliance breaches or regulatory action abroad must be reported to the RA promptly. These HQ provisions do not apply to an entity licensed only as a holding company.

What the guidance does not cover

Tax is expressly outside it, because tax is a federal matter. A mining business in ADGM still needs its UAE Corporate Tax and VAT position worked through, including how block rewards are treated. Energy and environmental requirements are not set out in this phase either. Expect both to feature in the consultation on the second phase framework.

What this means for you

• If you mine or validate for your own account, ADGM now offers a defined commercial licence route with a published rulebook for what the RA expects.
• If you offer staking, pooled mining or validator services to clients, start with the FSRA analysis, not the RA application. Getting the perimeter wrong is the expensive mistake here.
• If you run mining abroad from the UAE, an ADGM headquarters is workable, but budget for the disclosure and oversight the RA will expect.

How Neo Legal helps

We run the perimeter self-assessment, prepare the RA application and the supporting operational and security documents, and, where client assets are involved, advise on the FSRA permission alongside it. Our crypto practice also covers the wider choice between ADGM, VARA and other UAE regimes.

Frequently asked questions

Do I need a licence for crypto mining in ADGM?

Yes. Crypto mining in or from ADGM needs a Commercial Licence from the ADGM Registration Authority listing crypto mining, business activity code 7230. It is not a regulated financial service, so FSRA approval is not needed for mining on your own account.

Does ADGM's crypto mining guidance cover staking?

Yes, for your own account. The guidance is technology neutral and treats solo validation under Proof-of-Stake the same as Proof-of-Work mining. Staking that involves holding, controlling, exercising discretion over or pooling other people's digital assets may be a regulated activity needing an FSRA permission as well.

When does a crypto mining business need FSRA approval in ADGM?

When it holds or controls third party digital assets, manages validator keys or chooses staking protocols for clients, pools client assets, distributes rewards on clients' behalf, or offers a return on assets clients deposit. Those activities may amount to Providing Custody or Managing Assets. Neo Legal runs this perimeter assessment before any RA application is filed.

Is a crypto mining company in ADGM subject to AML rules?

Crypto mining on its own is not a virtual asset service provider activity, so a pure mining business is currently outside the federal and ADGM AML regimes. A miner that also safeguards or administers digital assets for others is inside them. All mining entities still face the RA's transparency, disclosure and record keeping expectations.

Do I have to disclose my mining wallets to ADGM?

Yes. Applicants are expected to disclose the wallet and smart contract addresses that receive or manage mining or validation rewards. The RA treats them as confidential, may monitor them on-chain, and needs to be told about material changes such as a new custody provider, not routine address rotation.

Can an ADGM company run crypto mining operations outside the UAE?

Yes. The guidance has a dedicated section for ADGM headquarters overseeing global mining. The RA may require disclosure of overseas locations, scale, structure and ownership, expects risk based due diligence on host countries and partners, and expects reasonable governance oversight of the overseas operations.

This article is general information on the law and published guidance at the date shown and is not legal advice. The answer for any structure or business depends on its facts; speak to us before relying on it.