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by Anne Agbo , j.awan & partners
The ADGM Registration Authority's Regulatory Priorities 2026–2027, published in October 2026, set out ten areas of supervisory focus and the Key Performance Indicators (KPIs) by which the RA will measure progress. We explain what each means for ADGM businesses.
With more than 14,000 licensed entities now in the ADGM, against over 11,000 reported in the previous year's edition, the RA must decide where to focus. Its Regulatory Priorities, a non-binding guide that creates no new obligations, show where monitoring, supervision and enforcement will be directed and how success will be judged. The consistent message: the RA intends to measure outcomes, not activity alone.
Two enforcement actions taken within the past fourteen months show what that looks like in practice, and both are discussed below.
The ten priorities
Accurate and timely filings and license renewals. The RA wants annual filings and license renewals that are accurate and on time. KPIs: on-time filing rates for renewals, annual accounts and confirmation statements (external); identification and escalation of repeat late filers (internal). Implications: persistent lateness will be escalated, not simply penalised. Boards should know who owns each filing deadline, in-house or at their CSP.
Audit quality, auditor conduct and corporate reporting. The RA seeks reliable financial statements and auditors who justify that reliance. KPIs: planned inspections completed and findings issued on time (internal); remediation plans agreed and followed up, with enforcement where appropriate (external). Implications: audit quality depends on the client too. Directors should keep records audit-ready and resolve reporting issues rather than defer them.
Data-driven supervision of higher-risk firms. Supervision will be steered by data towards higher-risk licensed persons. KPIs: data-driven firm selection, an annual risk assessment cycle, thematic reviews and Phase 1 of digital supervisory capabilities (internal); supervisory actions tracked to closure (external). Implications: in our view, a firm's own filings will increasingly shape its risk profile, so inconsistent data may itself draw attention.
Beneficial ownership transparency. The RA wants adequate, accurate and current beneficial ownership (BO) information. KPIs: BO data-validation exercises (internal); filing timeliness, inconsistencies remediated, and escalation of serious or repeated non-compliance (external). Implications: filed BO data will be tested, not merely received. Registers should be updated promptly after changes, and CSPs should keep evidence of verification.
Responsible innovation in emerging technology. The RA supports innovation through risk-based oversight of emerging technology structures within its remit; its published resources here include guidance on DLT Foundations. KPIs: planned assessments, guidance delivered and technology-enabled monitoring coverage (internal); supervisory issues identified and remediated (external). Implications: novel structures will be assessed, so boards should be ready to explain their governance and controls.
Fair retail practices and consumer protection. The RA will promote fair, transparent retail practices and stronger consumer protection. KPIs: complaints handled within target timeframes and outreach delivered (internal); retailer monitoring and remediation outcomes tracked (external). Implications: retailers should review pricing, refund and complaints processes. Complaints that reach the RA are a supervisory input, so resolving issues at source matters.
AML, CFT and TFS supervision of DNFBPs. Under a delegation from the FSRA, the RA supervises DNFBPs' AML, CFT and TFS compliance. KPIs: planned assessments and outreach completed (internal); remediation plans agreed and enforcement referrals where appropriate (external). Implications: DNFBPs should expect assessment. Risk assessments, customer due diligence, sanctions screening and training records should be current and evidenced.
Quality and professionalism of CSPs. The RA treats CSPs as gatekeepers and aims to raise their quality, professionalism, governance and compliance. KPIs: planned CSP assessments (internal); remediation plans, enforcement where appropriate, and improved compliance across assessed CSPs (external). Implications: success will be judged by better outcomes, not inspections alone. CSPs should test onboarding, record-keeping and filing controls now; clients should ask whether their CSP's controls would withstand assessment.
Unlicensed activity and misleading license claims. The RA will act against unlicensed activity, activity beyond license scope, and false or misleading claims about ADGM license status. KPIs: high-risk matters assessed promptly (internal); action taken, public alerts issued where necessary, and misconduct remediated or stopped (external). Implications: boards should confirm that activities and marketing match the license as issued.
Timely, decisive and proportionate enforcement. The RA will take timely, decisive and proportionate enforcement action, including with other authorities. KPIs: referrals assessed and acted on within target timeframes, based on risk (internal); proportionate outcomes, remediation secured and coordinated action where necessary (external). Implications: the RA publishes its regulatory actions and a Register of Disqualified Directors, so the exposure is reputational and can extend to individuals.
The gatekeeper question
Read together, Priorities 4, 7 and 8 describe a single supervisory idea. The RA is not only asking whether an entity's records are correct; it is asking whether the professional who prepared, filed and maintained them did so to an adequate standard.
That idea is already reflected in the framework. In October 2025 the RA published the Commercial Licensing Regulations (Conditions of Licence and Branch Registration) Rules 2025 and the Commercial Licensing Regulations (Controlled Activities) Rules 2025, introducing enhanced controls for legal, tax and company service providers. Priority 8 sets out how that framework will now be supervised, and by what measure.
The measure is the part worth noting. The external KPI is improved compliance across assessed CSPs, not the number of assessments performed. A CSP that is inspected, agrees a remediation plan and does not complete it has not satisfied that KPI. Neither has its client, whose filings and beneficial ownership records remain the entity's own responsibility regardless of who maintains them.
What does this mean for ADGM businesses?
The priorities are guidance, not new law. In our view, four questions are worth asking now:
Your data is your first impression. Is every filing deadline owned, and are beneficial ownership records reconciled to the register?
Remediation is the measure. Can the business evidence how past audit or regulatory findings were resolved?
Gatekeepers are in focus. Does each CSP and auditor engagement clearly allocate who verifies what?
License and reality must match. Do current activities and marketing sit within the license as issued?
Conclusion
The 2026–2027 priorities do not rewrite ADGM's rules. They show where the RA will look and what it will count as success, giving businesses the chance to test their arrangements against the regulator's own yardstick first. The enforcement actions of the past fourteen months suggest the RA will not wait long to apply them.
About
J. Awan & Partners is a licensed Corporate Service Provider in the ADGM and the DIFC, supporting entities with incorporation and structuring, company secretarial and CSP services, corporate governance and ongoing regulatory compliance. As an ADGM-licensed CSP, the firm is among those within the scope of Priority 8. To discuss how the RA's priorities affect your business, contact info@jawanpartners.com.
Sources
Primary
ADGM Registration Authority, Regulatory Priorities 2026–2027 (September 2026)
ADGM, ADGM's Registration Authority Publishes Regulatory Priorities for 2026-2027, announcement, 1 October 2026
ADGM, Financial Penalties of USD 100,000 against PKF Accountants and its Registered Audit Principal, announcement, 9 October 2026
ADGM, Financial Penalties of USD 37,500 against Half Moon Investments Limited and its Three Directors, announcement, 26 August 2025
ADGM, Financial Penalties against Half Moon and its Three Directors, announcement, March 2023
ADGM, Enhanced Controls for Legal, Tax and Company Service Providers, announcement, 16 October 2025
ADGM guidance and registers
Ten Priorities, One Message: What the ADGM Registration Authority Expects from Businesses in 2026–2027
At the beginning of this month the ADGM Registration Authority published ten supervisory priorities for 2026–2027, each with the KPIs it expects to be judged against. The list is the part that will get quoted, however the KPIs underneath it are the part worth reading. Here is what each priority asks for, and four questions worth answering before a supervisory conversation rather than during one.
Ten Priorities, One Message: What the ADGM Registration Authority Expects from Businesses in 2026–2027
At the beginning of this month the ADGM Registration Authority published ten supervisory priorities for 2026–2027, each with the KPIs it expects to be judged against. The list is the part that will get quoted, however the KPIs underneath it are the part worth reading. Here is what each priority asks for, and four questions worth answering before a supervisory conversation rather than during one.
by Anne Agbo , j.awan & partners
The ADGM Registration Authority's Regulatory Priorities 2026–2027, published in October 2026, set out ten areas of supervisory focus and the Key Performance Indicators (KPIs) by which the RA will measure progress. We explain what each means for ADGM businesses.
With more than 14,000 licensed entities now in the ADGM, against over 11,000 reported in the previous year's edition, the RA must decide where to focus. Its Regulatory Priorities, a non-binding guide that creates no new obligations, show where monitoring, supervision and enforcement will be directed and how success will be judged. The consistent message: the RA intends to measure outcomes, not activity alone.
Two enforcement actions taken within the past fourteen months show what that looks like in practice, and both are discussed below.
The ten priorities
Accurate and timely filings and license renewals. The RA wants annual filings and license renewals that are accurate and on time. KPIs: on-time filing rates for renewals, annual accounts and confirmation statements (external); identification and escalation of repeat late filers (internal). Implications: persistent lateness will be escalated, not simply penalised. Boards should know who owns each filing deadline, in-house or at their CSP.
Audit quality, auditor conduct and corporate reporting. The RA seeks reliable financial statements and auditors who justify that reliance. KPIs: planned inspections completed and findings issued on time (internal); remediation plans agreed and followed up, with enforcement where appropriate (external). Implications: audit quality depends on the client too. Directors should keep records audit-ready and resolve reporting issues rather than defer them.
Data-driven supervision of higher-risk firms. Supervision will be steered by data towards higher-risk licensed persons. KPIs: data-driven firm selection, an annual risk assessment cycle, thematic reviews and Phase 1 of digital supervisory capabilities (internal); supervisory actions tracked to closure (external). Implications: in our view, a firm's own filings will increasingly shape its risk profile, so inconsistent data may itself draw attention.
Beneficial ownership transparency. The RA wants adequate, accurate and current beneficial ownership (BO) information. KPIs: BO data-validation exercises (internal); filing timeliness, inconsistencies remediated, and escalation of serious or repeated non-compliance (external). Implications: filed BO data will be tested, not merely received. Registers should be updated promptly after changes, and CSPs should keep evidence of verification.
Responsible innovation in emerging technology. The RA supports innovation through risk-based oversight of emerging technology structures within its remit; its published resources here include guidance on DLT Foundations. KPIs: planned assessments, guidance delivered and technology-enabled monitoring coverage (internal); supervisory issues identified and remediated (external). Implications: novel structures will be assessed, so boards should be ready to explain their governance and controls.
Fair retail practices and consumer protection. The RA will promote fair, transparent retail practices and stronger consumer protection. KPIs: complaints handled within target timeframes and outreach delivered (internal); retailer monitoring and remediation outcomes tracked (external). Implications: retailers should review pricing, refund and complaints processes. Complaints that reach the RA are a supervisory input, so resolving issues at source matters.
AML, CFT and TFS supervision of DNFBPs. Under a delegation from the FSRA, the RA supervises DNFBPs' AML, CFT and TFS compliance. KPIs: planned assessments and outreach completed (internal); remediation plans agreed and enforcement referrals where appropriate (external). Implications: DNFBPs should expect assessment. Risk assessments, customer due diligence, sanctions screening and training records should be current and evidenced.
Quality and professionalism of CSPs. The RA treats CSPs as gatekeepers and aims to raise their quality, professionalism, governance and compliance. KPIs: planned CSP assessments (internal); remediation plans, enforcement where appropriate, and improved compliance across assessed CSPs (external). Implications: success will be judged by better outcomes, not inspections alone. CSPs should test onboarding, record-keeping and filing controls now; clients should ask whether their CSP's controls would withstand assessment.
Unlicensed activity and misleading license claims. The RA will act against unlicensed activity, activity beyond license scope, and false or misleading claims about ADGM license status. KPIs: high-risk matters assessed promptly (internal); action taken, public alerts issued where necessary, and misconduct remediated or stopped (external). Implications: boards should confirm that activities and marketing match the license as issued.
Timely, decisive and proportionate enforcement. The RA will take timely, decisive and proportionate enforcement action, including with other authorities. KPIs: referrals assessed and acted on within target timeframes, based on risk (internal); proportionate outcomes, remediation secured and coordinated action where necessary (external). Implications: the RA publishes its regulatory actions and a Register of Disqualified Directors, so the exposure is reputational and can extend to individuals.
The gatekeeper question
Read together, Priorities 4, 7 and 8 describe a single supervisory idea. The RA is not only asking whether an entity's records are correct; it is asking whether the professional who prepared, filed and maintained them did so to an adequate standard.
That idea is already reflected in the framework. In October 2025 the RA published the Commercial Licensing Regulations (Conditions of Licence and Branch Registration) Rules 2025 and the Commercial Licensing Regulations (Controlled Activities) Rules 2025, introducing enhanced controls for legal, tax and company service providers. Priority 8 sets out how that framework will now be supervised, and by what measure.
The measure is the part worth noting. The external KPI is improved compliance across assessed CSPs, not the number of assessments performed. A CSP that is inspected, agrees a remediation plan and does not complete it has not satisfied that KPI. Neither has its client, whose filings and beneficial ownership records remain the entity's own responsibility regardless of who maintains them.
What does this mean for ADGM businesses?
The priorities are guidance, not new law. In our view, four questions are worth asking now:
Your data is your first impression. Is every filing deadline owned, and are beneficial ownership records reconciled to the register?
Remediation is the measure. Can the business evidence how past audit or regulatory findings were resolved?
Gatekeepers are in focus. Does each CSP and auditor engagement clearly allocate who verifies what?
License and reality must match. Do current activities and marketing sit within the license as issued?
Conclusion
The 2026–2027 priorities do not rewrite ADGM's rules. They show where the RA will look and what it will count as success, giving businesses the chance to test their arrangements against the regulator's own yardstick first. The enforcement actions of the past fourteen months suggest the RA will not wait long to apply them.
About
J. Awan & Partners is a licensed Corporate Service Provider in the ADGM and the DIFC, supporting entities with incorporation and structuring, company secretarial and CSP services, corporate governance and ongoing regulatory compliance. As an ADGM-licensed CSP, the firm is among those within the scope of Priority 8. To discuss how the RA's priorities affect your business, contact info@jawanpartners.com.
Sources
Primary
ADGM Registration Authority, Regulatory Priorities 2026–2027 (September 2026)
ADGM, ADGM's Registration Authority Publishes Regulatory Priorities for 2026-2027, announcement, 1 October 2026
ADGM, Financial Penalties of USD 100,000 against PKF Accountants and its Registered Audit Principal, announcement, 9 October 2026
ADGM, Financial Penalties of USD 37,500 against Half Moon Investments Limited and its Three Directors, announcement, 26 August 2025
ADGM, Financial Penalties against Half Moon and its Three Directors, announcement, March 2023
ADGM, Enhanced Controls for Legal, Tax and Company Service Providers, announcement, 16 October 2025
ADGM guidance and registers