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ARTICLE · 13 OCTOBER 2026

Recent Changes To ADGM And DIFC Funds Framework

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The FSRA has introduced a new “Sub-Threshold Fund Manager” (STFM) category, designed to provide a proportionate regulatory approach for managers of smaller funds.

United StatesFinance and Banking
Andrea Dougall
Andrea Dougall
Wael Jabsheh
Wael Jabsheh
Tim Pearce
Tim Pearce
Mazen Baddar
Mazen Baddar
Syed Rizvi
Syed Rizvi
Marie-Sophie Bandeira Vieira
Marie-Sophie Bandeira Vieira
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Introduction

Both of the United Arab Emirates’s (UAE) major financial free zones are actively reshaping their fund management frameworks. On September 16, 2026, the Abu Dhabi Global Market (ADGM) Financial Services Regulatory Authority (FSRA) published amendments to several key Rules that took effect immediately, while the Dubai International Financial Centre (DIFC) regulator, the Dubai Financial Services Authority (DFSA), recently closed its consultation on a comprehensive overhaul of its own funds regime.

This alert covers:

  1. ADGM: The FSRA’s newly enacted amendments to the fund management regulatory framework, introducing specialized fund manager categories, a framework for Employee Investment Vehicles and tightened requirements for Foreign Fund Managers.

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