ADGM Category 4 Investment Advisor License
There have been important changes to the capital-requirement regime and physical-office options for lower-risk firms in ADGM, including asset managers. For Category 4 and other lower-risk firms, the Base Capital Requirement (BCR) is now set at USD 50,000, except in special cases (for example, where a firm operates a Private Financing Platform and holds client assets, in which case the BCR is USD 150,000). FSRA has also clarified that firms which do not hold client assets or insurance money are not required to meet the Expenditure-Based Capital Minimum (EBCM). For firms that do hold client assets or insurance money, the EBCM still applies and is calculated as 18/52 of annual audited expenditure.
In parallel, ADGM has enhanced its ecosystem for asset- and fund-management firms. Establishing the mandatory physical presence in the centre has become more cost-efficient and flexible, thanks to modern, serviced offices and flexi-desk solutions across Al Maryah Island and Al Reem Island – including business centres such as WeWork at Hub71 and Cloud Spaces in Al Sarab Tower. These desk-based packages allow firms to establish a regulatory footprint with fewer long-term lease commitments.
These regulatory and commercial improvements have helped propel ADGM’s growth as an asset-management hub. While earlier figures cited “over 130 asset and fund managers overseeing more than 160 funds,” the recent PRU update notes growth in authorised firms and reinforced ADGM’s status as a leading MENA centre for lower-risk financial services.
Why setup in the ADGM?
ADGM is emerging as one of the leading international financial centres in the MENA region. As of mid-2025, the centre reported 154 fund and asset managers operating out of its jurisdiction and overseeing 209 funds, with assets under management (AUM) increasing by about 42% year-on-year. This strategic location gives firms excellent access to Abu Dhabi’s sovereign wealth capital and regional institutional flows.
The ADGM has also built out an advanced regulatory framework for digital assets and fintech innovation. The centre’s common-law system, strong legal infrastructure and investor-confidence focus have drawn global managers and alternative investment houses alike.
Abu Dhabi continues to attract high-net-worth individuals (HNWIs) and family offices seeking a stable, well-regulated base. The combination of a growing asset-management ecosystem, robust regulator and tax-efficient jurisdiction means ADGM is increasingly on the radar of global wealth-management firms.
ADGM has also been making notable strides in the alternatives space. While global figures are still being published, the centre is clearly positioning itself as a hub for private equity, hedge funds and real-asset investors. In the first half of 2025 alone, the number of operational entities grew significantly as the platform diversified beyond traditional wealth-management structures.
The ADGM has also emerged as a vibrant business-district and lifestyle environment, offering leisure and cultural amenities in the heart of Abu Dhabi. The Galleria Mall, above which the ADGM is situated, and the nearby Al Maryah Mall, offer a variety of dining and shopping options, with more planned in the months to come.
Specific Advantages
Here are some specific advantages of establishing in the Abu Dhabi Global Market.
LEGAL AND REGULATORY FRAMEWORK
- Legal framework supports cross-border activities.
- 100% foreign ownership permitted.
- No restriction on foreign talent or employees.
- No restrictions on capital repatriation.
TAX BENEFITS
- 0 percent corporate tax subject to certain qualifications.
- Zero tax on employee income.
COUNTERPARTY CONFIDENCE
- Well regarded, independent regulator.
- Independent, English-speaking, common law judicial system.
- Distinct from the UAE legal system.
- Risk-based regulatory approach.
DIVERSE ECOSYSTEM
- Central to regional deal making.
- High concentration of international firms, investment funds, wealth management firms, banks, and financial institutions.
- World-class regional and international law and auditing firms, and other professional services.
- A growing fund domicile in the region.
GEOGRAPHIC EPICENTRE
- Management offices, holding companies and family offices are located closer to the assets they own or manage.
- The Middle East, Africa and South Asia (MEASA) is increasingly the centre of gravity for the global economy.
- The UAE plays a central role in the growing South-South trade, principally between Asia and Africa.
- Well-positioned to harness the potential of emerging markets.
ADGM Category 4 Investment Advisory and Arranging License
Firms engaging in ‘Advisory and Arranging’ activities, can apply to the ADGM for related financial service permissions, or what is colloquially called a Cat 4 License. Investment advisory, in this context, means advising clients and arranging deals or credit, but not on a discretionary basis, which comes under a separate categorisation - Cat 3C. Read more about Asset Management Licenses at the ADGM here.
Advisory and arranging activities can include:
Arranging Deals in Investments
“Arranging Deals in Investments” refers to situations where you set up, organise, or facilitate arrangements that help someone else buy or sell an investment, virtual asset, or spot commodity, or subscribe for or underwrite an investment. This applies whether that person is acting for themselves or on behalf of someone else. It also covers cases where the person you are arranging the deal for is directly involved in the arrangement itself. In essence, if you play a role in bringing parties together or putting in place the steps that enable an investment transaction to happen—even if you are not the one executing the transaction—you are carrying out the regulated activity of arranging deals in investments.
Advising on Investments or Credit
A person is considered to be “advising on investments or credit” when they give someone guidance or recommendations on whether to buy, sell, subscribe for, underwrite, or exercise rights in an investment, virtual asset, or spot commodity, or whether to enter into a credit facility such as a loan or financing arrangement. This applies when the advice is provided to someone in their capacity as an investor, potential investor, borrower, potential borrower, or to a person acting on their behalf. In simple terms, if you tell someone whether they should enter into an investment or take on credit—beyond just giving factual information—you are performing a regulated advisory activity.
Arranging Credit
“Arranging Credit” means setting up or facilitating arrangements that allow someone else to borrow money through a credit facility, whether they are acting for themselves or on behalf of another person. If you help put in place the structure, introductions, or steps needed for someone to obtain a loan or financing—without actually providing the credit yourself—you are carrying out the regulated activity of arranging credit.
The FSRA, for the purposes of authorisation and supervision, categorises investment advisory, credit advisory and insurance advisory activities under Category 4. While the Category 4 license allows firms to deal with Professional Clients only, it is possible to seek a Retail Endorsement during, or after the licensing process.
Firms interested in carrying out arranging and advisory activities from the ADGM are required to submit applications to the Financial Services Regulatory Authority, or FSRA.
What are the key staffing requirements in the ADGM?
As with other category firms, the FSRA expects that the firm be adequately staffed depending on the scale, scope and nature of the product portfolio that is proposed to be offered from the centre.
At a minimum, the FSRA would like to see the following appointments:
1. Board of Directors: a well-organized, diverse Board with Non-Executive and/or Independent Directors and robust governance policies. The Chair would have to be a non-executive Director.
2. Senior Executive Officer (SEO): Senior finance professional with over 10-15 years of core experience, ordinarily resident in the UAE.
3. Finance Officer (FO): Senior and suitably-qualified finance professional. In case of a group, the FO can be from the parent company and does not have to be resident in the UAE.
4. Risk Officer: Senior risk professional, can be from the parent entity in case of a group, or outsourced.
5. Compliance Officer (CO): Senior compliance professional with over 10 years of experience, ordinarily resident in the UAE.
6. Money-Laundering Reporting Officer: Senior AML professional with over 10 years of experience, ordinarily resident in the UAE. This function can be combined with Compliance and one individual can carry out both responsibilities.
The Finance Officer, Compliance Officer , Risk Officer and Money Laundering Reporting Officer roles can also be outsourced to a competent service provider, such as 10 Leaves.
7. Internal Auditor: Senior and suitably qualified internal audit professional. Usually outsourced to a professional firm.
8. External Auditor: Senior and suitably qualified external audit firm. The ADGM maintains a list of recognised auditors, which can be found on their website.
ADGM Capital requirements
The base capital requirement for a Category 4 Advisory license is US$ 50,000, up from US$ 10,000 a few months ago. Actual capital resources required will depend on the nature, quantum of business and forecasted annual expenditure, as per the financial model of the proposed firm.
Capital waivers may be available to the ADGM branch of a regulated financial institution having its head office in a recognized regulatory jurisdiction.
The FSRA lists out multiple ways of calculating capital, and specifies capital requirements for a firm as the highest of the Base Capital, Risk-Based capital and Expense-Based Capital. In case of Lower Prudential Risk Firms, only Base Capital applies.
These figures are calculated using the financial models that we make for the Regulatory Business Plan during the application process and so are mostly unique to the company that applies for the license.
Calculation of capital is a detailed process and involves many factors. We recommend that you contact us for more details on the application process and capital calculations.
Can ADGM firms service clients outside the centre, and in the greater UAE?
Yes, they can. ADGM-licensed firms are permitted to service clients both within and outside the financial centre, including clients across the wider UAE and internationally, provided that the regulated activity is carried on “in or from ADGM” in accordance with FSRA requirements.
Firms may market their services, meet prospective clients, and onboard Clients located anywhere in the UAE without needing an additional onshore licence, as long as their regulated operations, governance, and compliance functions remain based in ADGM. All financial promotions and client-facing activities must comply with FSRA rules, and cross-border engagements must take into account the regulations of the client’s home jurisdiction.
What is the process for licensing a Category 4 investment advisory in the ADGM?
The ADGM application process commences with formal introductions to the ADGM and the FSRA.
Following the introductory call, the FSRA issues access to an online portal where the complete application can be submitted. In some cases, a detailed Regulatory Business Plan (RBP) is prepared, along with financial projections, for a quick review by the regulator.
The comments of the regulator are incorporated into the RBP, and a comprehensive application is compiled, comprising policies, processes and other related documentation. The KYC and associated forms of all key individuals are also prepared for submissions online.
The formal application is then sent across to the FSRA, who reviews the pack over a period of 15-20 business days, and then accepts it. The detailed review process then commences, and this can take anywhere between 60 and 90 days to complete.
The regulator maintains communication with the applicant at all times during the review, reverting with an initial review 2 weeks into the application, and then follow-up reviews thereafter. The FSRA may also meet with the SEO, FO and CO/MLRO designates, and conduct a detailed interview with them.
A key milestone is the issuance of an In-Principle Approval, or IPA, which is issued once the application is successful. The applicant then proceeds to satisfy the in-principle conditions, and this involves the setting up of a legal structure, opening a bank account, and depositing the share capital in the account. Other tasks include finalisation of auditors and obtaining professional indemnity insurance for the firm.
Once done, a final submission is made to the FSRA, following which the regulator issues the Financial Service Permissions and the process is then complete. The firm is now open for business.
How much does it cost to setup a Category 4 license in the ADGM?
Setting up an ADGM Regulated Firm involves the following costs:
Financial Services Regulatory Authority (FSRA)
The FSRA is responsible for reviewing and approving all applications for financial services. Costs depend on the activities applied for, which puts the applicant in one of five categories.
Generally, there are two components of FSRA fees. One – an application processing fee, and the other, an annual licensing fee.
Application fee: US$ 15,000 for the principal activity of Advising on Investments, with US$10,000 per additional activity. Usually, there are 1-2 relevant additional activities.
License fee: US$ 15,000 for the principal activity, with US$10,000 per additional activity.
Registration Authority (ADGM RA)
The RA helps to set up the legal structure of the ADGM Regulated Firm. Shareholders can be individual, or corporate. There are many options available, such as ‘Private Company Limited by Shares’ and ‘Limited Liability Partnerships’. In case of Private Company Limited by Shares, the costs for setting up include:
1. Application for reserving a name (2 working days): US$ 200 (One Time).
2. Application for Incorporation of a Private Company Limited by Shares (3-4 working days): US$ 300 (One Time).
3. Commercial License on Incorporation (3-4 working days): US$ 200 (annual fee).
4. Business Activity Fee: US$ 16,000 (annual fee).
Data Protection:
The data protection notification is part of the process of registering a new entity in the ADGM. The costs involved are as follows:
1. Registration - US$ 300.
2. Annual renewal – US$ 300.
Office spaces:
Every regulated entity registered in the ADGM is required to lease a closed office. You may choose to secure closed office spaces in Al Maryah Island and Al Reem Island, both situated within the ADGM's jurisdiction. You may access this link to explore office options in ADGM ADGM Office Options
Prices vary, depending on the space availed and the building. Here is an indication of the prevailing rates:
1. The yearly rent for a space usually starts from US$ 10,000.
2. Fitted Offices – from US$ 55 per square foot.
Visas:
1. Establishment Card Application – US$ 297.
2. E-channel Application – US$ 1,105.
3. Visas (per visa, Outside UAE) – US$ 852.
4. Visa (Per visa, Inside UAE) - US$ 1,100.
Yearly Health Insurance Policy fee (As per actual). You may access the immigration approved health insurance companies here.
Our Services
How can we at 10 Leaves assist you?
We provide turnkey services for ADGM Category 4 Investment Advisor Licenses. From initial consultations to assistance in authorisations, to assistance in preparation of the legal documentation, 10 Leaves helps you navigate the FSRA Rulebook and submit an application that is comprehensive, complete and compliant.
Our services include assistance in:
Pre-Licensing
1. Reviewing the business model and advice on the applicable regulatory framework;
2. Preparation of the Regulatory Business Plan and comprehensive financial projections;
3. Preparation of all policies, processes and manuals required;
4. Provision of Outsourced services, including outsourced Compliance Officer, outsourced Finance Officer and outsourced Risk Officer services;
5. Assistance in recruitment of senior management;
6. Provision of well-qualified and experienced Non-Executive Directors;
7. Finalising the legal structure, including holding company setup and customisation of Memorandums; and
8. Finalisation of leased space, bank account opening and obtaining Financial Services Permissions.
Post-Licensing
1. Compliance, Finance and Risk outsourced and support services.
2. VAT and Corporate Tax services.
3. Secretarial services.
4. Variation of Permissions.
5. Compliance remedial measures.
6. Compliance audits.
7. Training.
8. Senior-level recruitment services.
Our solution focuses on comprehensive training for Directors, Senior Executive Officers, Finance Officers, and Compliance Officers. We equip them with the knowledge and skills needed to successfully clear interviews conducted by the FSRA during the authorisation process and for ongoing compliance.
A lot of our Category 4 clients are startups, where experienced investment bankers set up their own shop. In these cases, we also assist such teams with corporate and commercial documentation through our legal consultancy - 10 Leaves Legability. We assist in the drafting of:
1. Founder agreements.
2. Shareholder agreements.
3. Investor agreements.
4. Share vesting/ESOP plans.
5. Client/Supplier/Distributor agreements.
6. Employment agreements.
We also provide services in Luxembourg, Saudi Arabia, India and Mauritius.
Get in touch today! to know more about ADGM Category 4 Investment Advisor License.
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