Substantial Public Interest Conditions Rules 2025: A New Step In ADGM's Data Protection Framework

On September 9, 2025, the Abu Dhabi Global Market (“ADGM”) took a significant step in advancing its data protection framework with the adoption of the Data Protection Regulations (Substantial Public Interest Conditions) Rules 2025 (the “Rules”). These new provisions build on the Data Protection Regulations 2021 and introduce targeted conditions that permit the processing of special categories of personal data, commonly known as “sensitive personal data”, in circumstances where doing so is necessary for reasons of substantial public interest. 

The Rules mark a further evolution of ADGM's data protection regime, reinforcing its ambition to create a regulatory environment that both protects individuals and enables innovation-driven businesses to thrive.