In January 2026, the ADGM Registration Authority published Discussion Paper No. 1 of 2026 on proposed guidance for crypto mining activities. The paper is a published consultation. It does not change current authorisation requirements. It sets out the RA's intended approach to recognising crypto mining as a commercial activity carried on in or from ADGM.
The proposed regime sits under ADGM's Commercial Licensing Regulations and Companies Regulations, together with applicable UAE Federal laws. Crypto mining will not be a regulated financial service. No Financial Services Regulatory Authority authorisation will be required. Entities will need an RA Commercial Licence with the activity code for Crypto Mining. Licensees must observe ADGM beneficial ownership and AML/CFT obligations. The proposal is technology-neutral and covers proof-of-work and proof-of-stake consensus methods.
The direct addressees are ADGM-incorporated companies and branches that conduct or intend to conduct crypto mining in or from the free zone. The RA will allow ADGM entities to operate or oversee international mining operations from the free zone. Energy procurement, equipment imports and data centre arrangements remain subject to UAE customs and federal energy rules. Group governance, internal controls and risk management must reflect the cross-border footprint.
Crypto mining linked to stablecoin issuance or other regulated activities may still trigger FSRA requirements. Firms already operating Virtual Asset activities under the FSRA crypto rulebook do not gain automatic permission to mine. The discussion period closed on 20 March 2026. Final guidance is expected to follow.
We may advise on ADGM commercial licence applications for crypto miners. We can call on a partner network of UAE counsel for federal-level filings. Contact us to scope a piece of work. Work we undertake includes RA licence applications, beneficial ownership submissions, AML/CFT programmes, energy procurement contracts and group governance policies for cross-border mining operations.
Source: ADGM Registration Authority, Discussion Paper No. 1 of 2026: Proposed Guidance on Crypto Mining Activities, January 2026, https://www.adgm.com/media/announcements/adgm-registration-authority-publishes-discussion-paper-on-crypto-mining-activities
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