Applicant categories
Exempt vs Non-exempt Applicants
Every ADGM SPV applicant falls into one of two categories. Exempt applicants do not need to appoint a Company Service Provider for the application and management of the SPV. Non-exempt applicants must appoint an ADGM licensed Company Service Provider before lodging the application, and that CSP is responsible for both formation and administration of the SPV.
Bizzone UAE
Business Setup Consultants in Dubai, UAE
Who qualifies as an Exempt applicant
A body corporate that is a subsidiary undertaking of certain entities need not have a company service provider. The Registrar assesses the application against the categories set out in the regulations and may request further information and supporting documentation as it considers appropriate.
- Subsidiary of a person exempt under the Commercial Licensing Regulations 2015 (Exemptions) Order 2020
- Subsidiary of an authorised person under the Financial Services and Markets Regulations 2015
- Subsidiary of a person licensed or regulated by the Central Bank of the UAE
- Subsidiary of a company whose shares trade on a regulated market in the UAE, including ADGM
- Subsidiary of a company demonstrating substantial UAE assets, turnover and employees
- In each case, adequate governance policies and procedures must be evidenced
Evidence of substantial resources, experience and personnel
Licences and operations
Current commercial licences of operating legal entities in the UAE, issued by the relevant local regulatory authorities.
Assets and turnover
List of physical assets — buildings, machinery, factories — together with annual turnover and headcount figures.
People and immigration
Establishment or immigration cards for each operating entity and the list of UAE residency visas issued under each licence.
Governance structure
Organisation charts per operating entity, board and committee composition, reporting lines and decision governance.
Compliance function
Detail of compliance, in-house legal or company secretarial resources, full time headcount, qualifications and roles.
Supporting material
Website links evidencing board information, plus any other information demonstrating substantial assets.
Non-exempt applicants and the CSP requirement
Non-exempt applicants are those who do not meet the Exempt conditions. They must appoint an ADGM licensed company service provider before lodging the application with the ADGM Registration Authority. The CSP is then responsible for the formation and ongoing administration of the SPV, including the registered address and filings.
CSP appointed before the application is lodged
CSP submits the application on the SPV's behalf
CSP provides the registered office address and filing services
The Registrar may request further information at any stage
How we assess your category
Ownership review
We identify the incorporating shareholder and the entities directly or indirectly owned or controlled by it.
Evidence gathering
We assemble licences, asset and headcount data, immigration records and organisation charts to support an Exempt claim.
Governance pack
We review your policy suite against the Registrar's expectations and flag gaps before submission.
Route to filing
If Exempt status is not achievable, we introduce and coordinate with an ADGM licensed Company Service Provider.
Adequate governance policies and procedures
Exact requirements depend on the authority, activity and nationality. We confirm your list before submission.
- Business ethics policy
- Corporate governance policy or statement of structure
- Compliance policy
- Bribery and corruption policy
- Economic substance policy
- Risk management policy
- Anti-money laundering policy
FAQ
Frequently asked questions
Can't find your answer? A consultant can walk you through the detail in a short call.
No. The Registrar assesses each application and reserves the right to request additional information to decide whether an applicant should be exempt from appointing a company service provider.
The Registrar may consider the company's UAE assets, turnover and employees, its governance policies and procedures, and any rules or guidance issued by the Board or Registrar.
The exemption categories are framed around bodies corporate that are subsidiary undertakings of qualifying entities. Individual applicants will typically need an ADGM licensed Company Service Provider.
ADGM publishes a list of licensed company service providers. We work with established providers and coordinate the appointment as part of your setup.
Free consultation
Speak with a Bizzone UAE consultant
Tell us what you plan to do in the UAE and we will map out the licence, visa and compliance path that fits.
- +971 50 121 6915
- info@bizzoneuae.com
- Office No. 105, Alkhayyal Building, Near Karama Medical Fitness Center, Al Karama, Dubai, UAE
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