The ADGM Registration Authority has proposed making business centre services a controlled activity, with public liability insurance, minimum capital, pricing disclosure and wind-down planning for operators. Comments close on 6 November 2026. Here is what the paper says and who should read it.
The short answer
- ADGM Registration Authority Consultation Paper No. 7 of 2026 proposes making the provision of business centre services a controlled activity when carried on by way of business.
- Licensed business centre operators would need public liability insurance of at least USD 1,000,000 per claim and minimum regulatory capital of USD 50,000 in immediately available funds.
- Operators could not sign client agreements running beyond their own right to occupy the premises, and would have to disclose pricing, packages and exclusions in writing before signing.
- Operators would have to notify the Registrar within 5 business days of a material event such as headlease non-renewal, and keep a wind-down and contingency plan covering clients' premises and registered office.
- The draft Fees Rules add a USD 100 fee for the Annual LSP Return and a late filing fee for Annual CSP and LSP Returns of USD 150 per month or part, up to 90 calendar days.
- Comments must be submitted through the RA Consultation Portal by 6 November 2026; the RA says comments sent by email may not be considered.
Last reviewed 21 October 2026
ADGM Registration Authority Consultation Paper No. 7 of 2026 proposes that providing business centre services in ADGM becomes a controlled activity, with specific licence conditions for operators on public liability insurance, minimum capital, pricing disclosure, notification of material events and wind-down planning. The stated aim is to protect business centre tenants and the continuity of their premises and registered office. Comments close on 6 November 2026 and must be made through the RA Consultation Portal.
The ADGM Registration Authority (the RA, or the Registrar) announced the paper on 15 October 2026. It proposes amendments to the Commercial Licensing Regulations (Controlled Activities) Rules, the Commercial Licensing Regulations (Conditions of Licence and Branch Registration) Rules and the Commercial Licensing Regulations (Fees) Rules. The consultation paper and its three draft rule appendices are listed on the ADGM public consultations page. Everything below is taken from the paper and those drafts. The drafts can still change.
Why is the RA proposing this?
The paper is direct about the gap. Current commercial legislation does not set business-centre-specific licence conditions covering the relationship between an operator, its landlord and its tenants. The RA identifies three risks: a business centre may grant occupancy rights that run beyond its own headlease, may fail to disclose material limits in its pricing or premises arrangements, or may stop operating without adequate notice or transition support.
The RA also notes that the impact can spread across many tenants at once, particularly where a tenant is a Company Service Provider whose underlying clients use the same address. Losing or failing to renew a headlease can leave tenants without access to their premises and registered office, force urgent changes to public records, disrupt operations and bring unexpected costs.
What would count as a business centre?
Under the draft Controlled Activities Rules, providing business centre services would be a controlled activity if carried on by way of business. The draft defines it as providing furnished office accommodation together with ancillary business support services, including reception, telephone answering, mail handling, internet access and access to meeting rooms, for use by other persons in conducting their business, where those services form part of an integrated business centre offering.
The integrated offering is the key element. The definition describes the familiar serviced-office or flexi-desk model rather than a plain lease of space.
What licence conditions would operators face?
The draft Conditions of Licence Rules add a new rule 16 and a new Schedule 4 for business centres. The main conditions are summarised below.
| Condition | What the draft requires | When it would apply |
|---|---|---|
| Public liability insurance | Cover appropriate to the nature, size and occupancy of the business, minimum USD 1,000,000 for any single claim, with a copy provided to the Registrar on request | New applicants on publication; existing centres 6 months after publication |
| Pricing disclosure | All pricing, packages and exclusions recorded in writing and disclosed before the client signs any written agreement | As above |
| Agreement term | No client agreement may run beyond the operator's own right to occupy the premises | As above |
| Material event notification | Notify the Registrar within 5 business days of becoming aware of an event affecting, or reasonably likely to affect, its ability to keep operating, such as headlease non-renewal, restructuring or loss of premises | As above |
| Wind-down and contingency plan | Cover client communications, key transition milestones and practical support for clients who must change premises or registered office; provide to the Registrar on request and notify material changes within 10 business days | As above |
| Minimum regulatory capital | USD 50,000 in immediately available funds, replenished within 7 business days if reduced | New applicants on publication; existing centres 6 months after publication |
| Principles | Integrity, due skill, care and diligence, transparency, and open dealings with the Registrar | From publication |
The capital may be applied to fines and fees owed to the Registrar or to claims by the operator's clients, where the operator has no other funds to meet them. Rule 16 also sets general conditions, including that the operator and its connected persons must not be subject to criminal penalties or abandon the business in ADGM.
What about cash?
The draft adds business centre services to the list of licensed activities whose providers may not accept or distribute cash in connection with those activities. That list already covers company, legal, tax, accountancy, audit, insolvency and certain real estate services. The paper says the prohibition would be subject to a threshold of USD 3,000 per transaction, with a process for returning cash received by mistake. Bank transfer, cheque, regulated payment instruments and other traceable channels acceptable to the Registrar remain permitted, and the Registrar could grant an exemption in exceptional circumstances.
Who is affected?
The RA says the paper will interest existing and prospective business centre operators, people using or intending to use business centre services, company service providers and other affected stakeholders. In practice the groups look like this.
Business centre operators. They carry the new obligations. An existing operator would have six months from publication of the final rules to put the insurance, disclosure, notification, wind-down and capital requirements in place.
ADGM entities using a flexi-desk, serviced office or business centre address. The conditions are not imposed on tenants, but they are written for tenants' protection. If your company's premises or registered office sits with a business centre, the proposals touch the arrangement your public record depends on. Our note on ADGM registered office services explains why that address matters.
Company, legal and tax service providers. The paper proposes miscellaneous amendments to the professional indemnity insurance requirements for these providers, clarifying cover for third-party liabilities arising from dishonest, fraudulent, criminal or malicious acts, errors or omissions by staff or others acting for the provider, and for legal and professional costs of claims. Our guide to the ADGM company service provider role gives the wider context.
What changes in the Fees Rules?
The paper says the Fees Rules would include a fee for submitting the Annual Legal Service Provider (LSP) Return, and a late filing fee for late Annual Company Service Provider (CSP) Returns and Annual LSP Returns. In the draft Fees Rules, the Annual LSP Return submission fee is USD 100, the same as the Annual CSP Return, and the late filing fee for either return is USD 150 per month or part of a month, up to a maximum of 90 calendar days, on top of the submission fee and other fees.
These sit alongside the FSRA's separate proposals in Consultation Paper No. 6 of 2026 on fees and late filing, which closes on the same day. CSPs and LSPs should add both returns to their ADGM annual compliance calendar once the rules are final.
How do you respond before 6 November 2026?
Comments must go through the RA Consultation Portal at raconsultations.adgm.com. Registering for an account is a one-time step. The paper warns that comments sent to ra.consultation@adgm.com may not be considered; that address is for portal issues only, such as registration, access or technical problems.
The paper asks nine questions, covering the insurance amount (Q1), pricing disclosure (Q2), the agreement term restriction (Q3), material event notification (Q4), the wind-down plan (Q5), minimum capital (Q6), the professional indemnity changes (Q7), the cash prohibition (Q8), and any broader feedback (Q9). A useful response answers the questions that affect you, explains the practical effect with reasons, and suggests alternative wording where you disagree.
A business centre tenant might comment on whether the wind-down plan should give a minimum notice period before a registered office has to move. An operator might comment on the six-month transition or the capital level. Keep a copy of what you submit.
What happens next?
After the consultation closes, the Registrar will consider whether changes are needed, and the ADGM Board of Directors and the Registrar will then enact the rules in final form. The RA says no one should act on the proposals until the final rules and any guidance are issued, and that a notice will appear on the ADGM website when they are.
How Atlas helps
Atlas Corporate Services is a DFSA-registered corporate service provider based in the DIFC, and we also administer ADGM entities. We keep the registered office, company secretarial and filing records for the entities we look after, so we can help you check where an ADGM company's premises and registered office sit, what the agreement behind them says, and which filings would follow a change of address. Our company secretarial and governance service covers that work. We do not give legal or regulatory advice, draft consultation responses for clients, or act as a business centre operator, so for views on the drafts themselves please speak to your legal adviser.
This article is general information and does not constitute legal, tax or regulatory advice. It summarises a consultation paper and draft rules that may change before they are made final. Check the final rules issued by the ADGM Registration Authority before acting.
Frequently Asked Questions
What is ADGM Consultation Paper No. 7 of 2026 about?
It is a consultation by the ADGM Registration Authority on amendments to three sets of commercial licensing rules: the Controlled Activities Rules, the Conditions of Licence and Branch Registration Rules, and the Fees Rules. The main proposal is to make providing business centre services a controlled activity in ADGM, with specific licence conditions on insurance, disclosure, notification, wind-down planning, capital and cash handling. Comments close on 6 November 2026.
What counts as a business centre under the ADGM proposal?
The draft defines providing business centre services as providing furnished office accommodation together with ancillary business support services, such as reception, telephone answering, mail handling, internet access and access to meeting rooms, for use by other persons in conducting their business, where these are provided as part of an integrated business centre offering. It is a controlled activity only when carried on by way of business.
Does CP7 of 2026 change anything for ADGM companies that rent a desk in a business centre?
The draft conditions are imposed on business centre operators, not on their tenants. The Registration Authority's stated purpose is to protect tenants and support continuity of their premises and registered office arrangements. Tenants would benefit from written pricing disclosure, agreements limited to the operator's own occupancy term, and a wind-down plan if the operator ceases trading. Tenants can still respond to the consultation.
When would the new business centre conditions apply?
Nothing applies yet. The Registration Authority says the rules should not be acted on until final rules are issued. Under the drafts, the insurance, operational and capital conditions would apply to new applicants from the date the final rules are published, and to existing licensed business centres six months after publication. The conduct principles would apply to licensed operators from publication.
How do I respond to ADGM Consultation Paper No. 7 of 2026?
Register for an account on the RA Consultation Portal at raconsultations.adgm.com, a one-time process, and submit comments there by 6 November 2026. The paper says comments sent to the ra.consultation@adgm.com address may not be considered; that address is only for portal problems such as registration or access. The paper asks nine questions, the last inviting broader feedback.