ADGM FSRA Consultation Paper No. 6 of 2026: Fees, Late Filing and Who Is Affected

On 9 October 2026 the ADGM Financial Services Regulatory Authority (FSRA) published Consultation Paper No. 6 of 2026. It proposes amendments mainly to the Fees Rulebook (FEES), with consequential changes to the General Rulebook (GEN) and the Guidance and Policies Manual (GPM). Comments close on 6 November 2026.

Most of the paper is about what market infrastructure firms pay. The part that reaches furthest is narrower and more practical: how the FSRA proposes to charge for late Regulatory Filings. That is where we would start reading, and it is where this note spends most of its time. We have deliberately left out the amounts. They are in the paper, and they may change after consultation.

Our sources are the FSRA announcement on the ADGM website and the consultation paper and its appendices in the ADGM Rulebook.

What the paper covers, section by section

The FSRA reviewed its fees in 2023, in Consultation Paper No. 4 of 2023, but left market infrastructure out of scope. This paper picks that up. The FSRA says the timing reflects more complex trading and clearing models and a Listing Authority that is now fully operational.

The paper is organised in seven sections:

• Section A: revised application and annual supervision fees for Recognised Bodies and for operators of Multilateral Trading Facilities (MTFs) and Organised Trading Facilities (OTFs), plus a new annual supervision fee for each class of Securities admitted to the Official List
• Section B: an increased fee for late Regulatory Filings, applied in a new way
• Section C: clearer fees for varying a Financial Services Permission (FSP), including adding Virtual Assets, Fiat-Referenced Tokens or Spot Commodities to an existing activity, and adding activities under an Islamic Financial Business permission
• Section D: guidance on supplementary fees for change in control applications that amount to a substantial change
• Section E: guidance on variations of permission within 12 months of authorisation
• Section F: miscellaneous changes, including a standard 20 business days to pay a fee invoice
• Section G: implementation, proposed for 1 January 2027

The paper asks 11 questions, and a respondent can answer only those that matter to it.

How the late filing fee would work

A Regulatory Filing, as defined in the FSRA's Glossary, is the subset of returns the FSRA treats as being of particular supervisory importance. The paper confirms that this includes AML Returns submitted by DNFBPs (Designated Non-Financial Businesses or Professions). Today the late filing fee under FEES 1.2.7 is charged once per filing when the due date is missed.

The FSRA says that approach, introduced in 2023, has not reduced late filing or pushed firms to fix it quickly. It proposes a higher fee and a different mechanism. The fee would be charged automatically on the first day a filing is overdue, again on day 11 and again on day 21 if it is still outstanding. Days here are business days. After the third charge the total is capped, and the matter is referred for escalation, which may include formal enforcement action.

Three supporting points in the paper deserve as much attention as the fee. Requests for an exemption or extension would have to reach the FSRA at least 10 business days before the deadline and would be granted only in exceptional circumstances. Once applied, a late filing fee is unlikely to be waived. And the FSRA proposes removing the current carve-out in FEES 1.2.6, so an unpaid late filing fee would be treated like any other late payment.

In practice this shifts the risk. Under the proposal, a firm that misses a date and sorts it out a fortnight later has already paid twice, and a firm that lets it drift into a fourth week is heading for an enforcement conversation. If you need more time, ask early. A request made on the due date will be too late.

Permissions and change in control

Two pieces of new guidance matter to anyone planning a transaction or expansion. First, the FSRA says it will not usually grant a variation of an FSP within 12 months of issuing it, although it keeps discretion to do so. A firm that expects to add activities soon after licensing should say so in its original application.

Second, where a change in control is in substance an "FSP for Sale", with wholesale changes to ownership, business model, governance, management or activities, the supplementary fee may equal the fee for a new authorisation and the assessment may take longer. The FSRA says this is not aimed at the genuine acquisition of an operating business whose control environment stays substantially in place.

Who should read it, and who can relax

The FSRA says the paper should interest Authorised Persons, Recognised Bodies, Listed Entities, DNFBPs, prospective controllers and applicant firms, together with their professional advisers.

An ordinary ADGM company, SPV or foundation that holds no Financial Services Permission, has nothing on the Official List and is not a DNFBP deals with the ADGM Registration Authority instead. For that entity this paper is background reading. Its annual filings, accounts and register updates are governed by the Registration Authority's own rules, which the paper does not touch; our ADGM annual compliance calendar lists those dates.

The group we would most want to read Section B is ADGM DNFBPs, such as corporate service providers, accountants and real estate businesses. They can easily think of themselves as outside "regulated" financial services, yet their AML Return is a Regulatory Filing. If you are unsure whether your entity counts, our note on what an ADGM company service provider does covers what that role involves. Groups with entities in both centres should also remember that DIFC and ADGM run separate regimes, a point we made in our piece on why DIFC and ADGM authorisation does not carry across.

What we would do before 6 November

1. Read Section B and Section G in full, then the late filing wording in Appendix 1, rather than relying on a summary.
2. List every Regulatory Filing your firm makes, with its due date, owner and back-up. For a DNFBP that includes the AML Return.
3. Move internal deadlines earlier, so that any extension request can go in at least 10 business days before the real date.
4. Decide with your compliance officer whether to respond. Comments go to fsra.consultation@adgm.com with "Consultation Paper No. 6 of 2026" in the subject line. Evidence about practical effect carries more weight than general objections.
5. Diary 1 January 2027 as the proposed start date, then check the final rules when the FSRA publishes them.

For the dates falling due between now and year end, see our Q4 2026 compliance calendar for DIFC and ADGM companies. For how boards allocate this kind of ownership, our DIFC and ADGM corporate governance guide is a good starting point.

How Atlas helps

Atlas Corporate Services is a DFSA-registered corporate service provider in the DIFC. We are not an ADGM Authorised Person, and we do not advise on FSRA rules, fees or permissions or prepare regulatory returns. Our part is the corporate record behind a filing: registers, board resolutions and Registration Authority filings for ADGM companies, SPVs and foundations, delivered through our company secretarial and governance service and our SPV support. Where a board decides to review its filing calendar, we can minute that decision and keep the records straight. Tax and accounting work is delivered with GTAG, our sister company in the GTAG/Assetica group. If the consultation affects your firm, the compliance officer or a regulatory lawyer should lead.

This article is general information and does not constitute legal, tax or regulatory advice. Consultation Paper No. 6 of 2026 is a proposal and its terms may change before any rules are made. Confirm the position for your entity, and the text of the paper itself, with a qualified adviser before acting.