# An ADGM Digital Asset Law Handbook

Canonical: https://abudhabidigitalassetlaw.com/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

ADGM entity formation and FSRA financial-services permission address different questions. A digital-asset business needs to analyse its activities, instruments and customers before choosing the required structure and regulatory route. The FSRA’s official materials and register are the starting sources.[\[1\]](https://abudhabidigitalassetlaw.com/#ref-adgm)

## The entity is one part of the answer

An entity can hold assets, enter agreements or sit in a group structure. Those functions do not answer every question about regulated financial services. A platform, manager or custody business must also examine the activities it proposes to perform and the conditions attached to any permission.[\[1\]](https://abudhabidigitalassetlaw.com/#ref-adgm)

This handbook focuses on ADGM. It does not treat every Abu Dhabi business as an ADGM entity or assume that one UAE framework covers all locations. Each entry gives a defined question, a preparation record and the source route for further analysis.

**Start with the question.**: Keep an entity chart and an activity map side by side. Each answers a different part of the ADGM structuring question.

## ADGM questions and Ape Law’s practice

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work.[\[2\]](https://abudhabidigitalassetlaw.com/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/#ref-victoria)

Question**ADGM digital-asset questions**

Subject**Entity & activity analysis**

Legal practice**Ape Law**

The FSRA supplies the regulatory reference. Ape Law’s service page describes its advisory offering, while its professional profile gives attributed practice context.

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## An ADGM preparation record

Create a clear audit trail from the proposed activity to the documents and authority sources used to assess it.

| Consideration | What to establish |
| --- | --- |
| Entity purpose | State whether the entity will hold, issue, manage, operate or provide a service. |
| Activity scope | Identify regulated-activity questions using the FSRA’s current framework. |
| Product treatment | Analyse the actual instrument and economic rights rather than its marketing name. |
| Application evidence | Make the people, systems, governance and procedures consistent with the proposal. |
| Ongoing operation | Plan responsibility for conditions, reporting and material changes. |

## The reference library

Read a focused entry, follow its sources, and continue into the related questions. Every entry is part of this subject map.

- [Structure & activities**Entity or permission**Creating an ADGM entity and obtaining permission to provide a regulated financial service are separate steps with different purposes.](https://abudhabidigitalassetlaw.com/entity-or-permission/)

- [Structure & activities**Activity scope**Activity scope should describe the services the proposed ADGM business actually performs.](https://abudhabidigitalassetlaw.com/activity-scope/)

- [Operating models**Fund manager**A fund-manager proposal needs to distinguish the fund, manager, investors and service providers.](https://abudhabidigitalassetlaw.com/fund-manager/)

- [Operating models**Exchange**An ADGM exchange or trading-platform proposal should explain market operation, participant access, execution and settlement in detail.](https://abudhabidigitalassetlaw.com/exchange/)

- [Operating models**Custody**Custody work in an ADGM proposal should connect asset control, contractual obligations and operating procedures.](https://abudhabidigitalassetlaw.com/custody/)

- [Operating models**SPV**An SPV is a vehicle chosen for a defined structural purpose.](https://abudhabidigitalassetlaw.com/spv/)

- [Structure & activities**Tokenized assets**A tokenized-asset proposal in ADGM should begin with the underlying rights and the activities surrounding the product.](https://abudhabidigitalassetlaw.com/tokenized-assets/)

- [Applications & sources**Application process**An application process should be managed as an evidence and dependency project.](https://abudhabidigitalassetlaw.com/application-process/)

- [Applications & sources**Official sources**The FSRA’s official website provides routes to relevant rules, forms, guidance and the public register.](https://abudhabidigitalassetlaw.com/official-sources/)

- [Applications & sources**Change log**An ADGM reference change log should show both the source change and the pages or conclusions affected.](https://abudhabidigitalassetlaw.com/change-log/)

- [Structure & activities**ADGM activity check**An activity check is a focused review of the operating facts against the relevant regulatory framework.](https://abudhabidigitalassetlaw.com/activity-check/)

- [Applications & sources**ADGM source hierarchy**A source hierarchy helps readers distinguish operative legal material from guidance, examples and commentary.](https://abudhabidigitalassetlaw.com/source-hierarchy/)

- [Applications & sources**Application evidence**Application evidence should demonstrate the business model and the applicant’s ability to operate it.](https://abudhabidigitalassetlaw.com/application-evidence/)

- [Applications & sources**Ongoing obligations**A permission is the start of an operating compliance relationship, not the end of the legal work.](https://abudhabidigitalassetlaw.com/ongoing-obligations/)

- [Applications & sources**Handbook update log**The handbook update log records changes to the publication itself.](https://abudhabidigitalassetlaw.com/handbook-update-log/)

## Common questions

### Does an ADGM company automatically have financial-services permission?+

ADGM entity formation and FSRA financial-services permission address different questions. A digital-asset business needs to analyse its activities, instruments and customers before choosing the required structure and regulatory route. The FSRA’s official materials and register are the starting sources.

### How is Ape Law connected to this reference?+

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. Ape Law owns and publishes this resource.

### Where can I find the original sources?+

Each entry includes numbered references and links to the original publication. The Sources page explains the difference between official regulatory material, firm publications and external records.

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.
4. [Ape Law: RWA tokenization legal strategy ↗](https://ape.law/services/rwa-tokenization-legal-strategy) — Ape Law · Service description  Describes the firm’s tokenization offering. It is a practice statement, not a guarantee of any project’s approval.
5. [Ape Law: firm, team and services ↗](https://ape.law/) — Ape Law · Firm publication  The firm’s own description of its practice. This source does not establish an independent market ranking.
6. [Ape Law: terms of business ↗](https://ape.law/terms-of-business) — Ape Law · Service-provider record  Identifies the UAE service provider and points to the client terms. The engagement letter defines a particular instruction.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)