ADGM Accounting and Bookkeeping: What Abu Dhabi Global Market Actually Requires

Accounting and bookkeeping for an Abu Dhabi Global Market company runs on the ADGM Companies Regulations 2020, not on UAE mainland company law. The practical consequences are a ten-year records retention period, accounts prepared under international accounting standards, a filing deadline of nine months after the accounting reference date for a private company, and an audit that must be signed by an ADGM registered auditor.

Most articles about accounting in Abu Dhabi treat the emirate as one market. It is not. A company licensed by the Abu Dhabi Department of Economic Development and a company registered in Abu Dhabi Global Market are governed by different company law, keep records for different periods, file to different registrars and answer to different auditors. Getting that wrong is not a technicality — it is the difference between a compliant file and a defective one.

This page deals only with the Abu Dhabi Global Market side. If you are looking at mainland Abu Dhabi, the monthly accounting and bookkeeping cycle for an Abu Dhabi company is a different piece of work with a different calendar.

What Abu Dhabi Global Market actually is, in law

ADGM is an international financial centre established under Abu Dhabi Law No. 4 of 2013, and that founding instrument is worth knowing because it is what gives ADGM its own civil and commercial law. English common law applies directly inside the Abu Dhabi Global Market, including the rules and principles of equity, and a schedule of English statutes on civil and commercial matters is applied as well. ADGM has its own courts of First Instance and Appeal.

The body you deal with for accounts is the Registration Authority. Its own guidance describes it as the Registrar of companies within ADGM as well as the commercial and audit regulator, responsible for licensing, registration and incorporation, and for monitoring and enforcing ADGM’s commercial legislation.

That combination — registrar and audit regulator in one body — explains a lot about how Abu Dhabi Global Market compliance feels in practice. The same authority that grants your licence also decides whether your accounts are defective and who is allowed to audit them.

Sources: ADGM Registration Authority guidance, August 2025; ADGM Companies Regulations 2020 (consolidated); Federal Decree-Law No. 32 of 2021. Checked 5 August 2026.

The records duty: what section 375 actually asks you to hold

Section 375(1) of the Companies Regulations 2020 requires every company to keep adequate accounting records. What makes ADGM unusually specific is that section 375(3) then lists the items those records must contain, rather than leaving “adequate” to argument.

The listed items are cheques, records of electronic fund transfers, invoices, contracts, the general and subsidiary ledgers, journal entries and other adjustments to the financial statements that are not reflected in journal entries, work sheets and spreadsheets supporting cost allocations, computations, reconciliations and disclosures, and a record of the assets and liabilities of the company.

Read that list against your current file structure. Two entries catch most SMEs out. The first is contracts — a signed customer or supplier agreement is part of the accounting record, not a legal file that lives elsewhere. The second is the requirement to hold adjustments not reflected in journal entries, which means the spreadsheet where someone reclassified a balance before the accounts were drafted is itself a record.

Section 375(4) adds a stock layer for companies dealing in goods: statements of stock held at each financial year end, all statements of stocktakings from which those were prepared, and — except for ordinary retail trade — statements of all goods sold and purchased, identifying buyers and sellers in sufficient detail. A trading company in Abu Dhabi Global Market therefore cannot run on a single stock figure at year end. It needs the count sheets behind it.

Where the records live, and the ten-year clock

Section 377(1)(a) lets the directors decide where records are kept — the registered office or such other place as they think fit — and section 377(1)(b) requires them to be open at all times to inspection by the company’s officers.

The complication is offshore bookkeeping, which is extremely common for Abu Dhabi Global Market entities inside international groups. Section 377(2) says that if accounting records are kept outside the Abu Dhabi Global Market, accounts and returns for that business must be sent to and kept at a place inside the Abu Dhabi Global Market, and must be open to inspection at all times.

Section 377(3) then sets the standard those returns have to meet. They must disclose with reasonable accuracy the financial position of the business at intervals of not more than six months, and enable the directors to make sure the accounts comply with the Regulations.

Section 377(4) is the sentence that should drive your archive policy: records required by section 375 must be preserved for ten years from the date on which they are made. Not ten years from the year end — ten years from the date the record was made. Section 377(5) makes this subject to other applicable ADGM regulation or law, so ten years is a floor rather than a ceiling.

If your Abu Dhabi Global Market entity is inside a group with mainland companies, do not run two archive policies. Set the whole group to the longest applicable period and stop thinking about it.

Which accounting standard an ADGM company uses

Section 387(1) requires a company’s individual accounts to be prepared in accordance with international accounting standards, described in the Regulations as IAS individual accounts. Section 389(3) applies the same standard to group accounts where they are required. Section 437(1) defines accounting standards for that Part as international accounting standards or such other standard accounting practice as the Board prescribes by rules.

The Registration Authority guidance explains the plumbing: the ADGM Companies Regulations (International Accounting Standards) Rules 2015 define IAS as current and future standards and interpretations issued or adopted by the International Accounting Standards Board, and the IASB is the body that sets IFRS.

Here is the trap for a small Abu Dhabi Global Market company that also has a UAE corporate tax position. Article 4(1) of Ministerial Decision No. 114 of 2023 requires a taxable person to apply IFRS, and Article 4(2) permits a taxable person with revenue not exceeding AED 50,000,000 to apply IFRS for SMEs instead. That federal concession is about corporate tax. It does not amend section 387 of the ADGM Companies Regulations 2020.

Small, medium and the thresholds that decide your obligations

Company size in Abu Dhabi Global Market is not a matter of judgement. Section 369(4) sets the small test and section 438(3) sets the medium test, and in both cases the company must satisfy both conditions, not one of them.

Two mechanics matter. Section 369(3) provides that where a company meets or ceases to meet the qualifying conditions on its balance sheet date, that only affects its qualification if it happens in two consecutive financial years — so you do not flip category on a single unusual year. And section 369(6) defines the employee count as a monthly average across the financial year, computed by adding the monthly headcounts and dividing by the number of months, not a headcount on the last day.

For a parent company, section 370(1) makes the group test decisive: a parent qualifies as small only if the group it heads also qualifies as small. The Registration Authority guidance adds that when assessing group size you must consider the largest group of which the company is a part, including parents and fellow subsidiaries, not only the group beneath it.

The audit exemption, and why so few ADGM companies can use it

Section 447(1) is the default: a company’s annual accounts for a financial year must be audited unless it is exempt under section 449 (small companies), section 452 (subsidiary companies) or section 455 (dormant companies).

Then come the conditions, and they are where the exemption usually fails.

Even a company that clears all of that can be pushed back into audit by federal tax law. Article 2(1)(b) of Ministerial Decision No. 84 of 2025 requires a Qualifying Free Zone Person to prepare and maintain audited financial statements. There is no revenue threshold attached to that limb — the threshold in Article 2(1)(a), AED 50,000,000, applies to taxable persons that are not tax groups, separately.

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The ADGM small company audit exemption is real, well drafted, and quietly unusable for any company that wants the 0% free zone corporate tax rate.

The Registration Authority has said so itself. Its August 2025 guidance states that if an ADGM small company, a small parent, a subsidiary whose parent is an ADGM company or a dormant company meets the criteria of a Qualifying Free Zone Person and wishes to qualify for the 0% rate, then regardless of size, subsidiary status or dormancy, the company will need to maintain audited accounts.

That guidance also records a limited transitional easing. For the first fiscal period in scope for UAE corporate tax only, the Registration Authority may adopt a no-action position where the only reason the company was audited was to comply with UAE corporate tax requirements and it would otherwise have qualified for the small companies audit exemption. That is a transition measure with defined limits, not a standing concession, and the guidance is explicit that it does not bind the FTA.

Who is allowed to sign an ADGM audit

Section 447(5) requires a company that is not exempt to appoint an auditor eligible under Part 35 of the Regulations, with additional requirements for auditors of public interest entities and financial institutions. Section 1031 defines auditor and section 1032 sets eligibility for appointment.

The Registration Authority guidance closes the obvious loophole: regardless of the purpose for which an ADGM company has its accounts audited, it must engage an ADGM registered auditor. An audit obtained solely to support a corporate tax filing is still an audit under Part 35 once the directors resolve to appoint an auditor.

Filing deadlines and the accounting reference date

Every deadline in Abu Dhabi Global Market runs from your accounting reference date. ADGM states that the ARD is set at incorporation and registration, is visible on the ADGM online registry system, and can be changed by submitting a directors resolution.

Section 416(2) sets the period for filing at nine months after the end of the relevant accounting reference period for a private company, and six months for a public company. Section 416(3) deals with a first accounting reference period longer than twelve months: the period is nine or six months from the first anniversary of incorporation, or three months after the end of the accounting reference period, whichever last expires.

Section 416(5) is the piece worth remembering under pressure: an extension has to be applied for before the existing period expires. Once the deadline has passed, the extension route has closed and you are in late-filing territory, which the Registration Authority handles through its published penalties process.

The wider ADGM annual filing calendar

Accounts are one item on a short list. The Registration Authority publishes the others with their own deadlines and, in some cases, their own fees.

Figures as published by ADGM on its annual filings pages and checked 5 August 2026. ADGM does not publish a single consolidated fine schedule for late accounts on that page, so we have not stated one — confirm the current position with the Registration Authority before relying on any number. Note also that confirmation statements apply to companies and limited liability partnerships, not to branches or foundations, although branches and foundations must still maintain accounting records.

What a monthly bookkeeping cycle looks like for an ADGM entity

The Regulations describe outcomes rather than a month-end process, so the cycle below is our working method rather than a rule. It is built backwards from what section 375, section 377 and an ADGM registered auditor will each want.

The half-yearly minimum in section 377(3) is a floor and a poor target. A six-month reporting interval means an error found in month six has been repeated five times. Monthly reporting costs slightly more and reduces audit time, which is why we run it that way for clients whose books sit outside the Abu Dhabi Global Market.

Where ADGM accounting goes wrong in practice

Some failure patterns repeat often enough to be worth naming.

How Abu Dhabi Global Market sits inside the UAE tax system

Being in ADGM does not remove you from federal tax. Corporate tax under Federal Decree-Law No. 47 of 2022 applies across the UAE, free zones included, for tax periods commencing on or after 1 June 2023. An ADGM entity can be a Free Zone Person, and where it satisfies the conditions, a Qualifying Free Zone Person taxed at 0% on qualifying income.

VAT under Federal Decree-Law No. 8 of 2017 applies as well, and there is a specific point to note. The FTA’s List of Designated Zones — issued under Cabinet Decision No. 59 of 2017 and its amendments, most recently Cabinet Decision No. 81 of 2021 — names five designated zones in Abu Dhabi: the Free Trade Zone of Khalifa Port, Abu Dhabi Airport Free Zone, Khalifa Industrial Zone, Al Ain International Airport Free Zone and Al Butain International Airport Free Zone. Abu Dhabi Global Market is not on that list, so the designated-zone place-of-supply rules for goods do not apply to an ADGM entity.

The interaction between the free zone corporate tax rules and the audit requirement is set out more fully in our note on the qualifying free zone person conditions, and the general question of which UAE entities are forced into an audit is covered in statutory audit requirements across the UAE.

What to line up before your first ADGM year end

If you have just incorporated in Abu Dhabi Global Market, six decisions taken early remove most of the pain later.

None of that requires a large finance function. It requires the decisions to be made once, written down, and diarised. For a UAE group with entities on both sides of the line, the cheapest arrangement is usually a single UAE-wide close calendar with one extra column for the Abu Dhabi Global Market entity, rather than two finance processes running in parallel.

There is one budgeting point worth being blunt about. The pool of firms eligible to sign an Abu Dhabi Global Market audit is the ADGM register, which is narrower than the wider UAE audit market, and availability tightens as year end approaches. We do not publish fee ranges for third-party auditors and we would treat any article that does with suspicion, because quotes vary enormously by size, sector and how clean the ledger is. The ledger is the part you control.

Where this leaves an Abu Dhabi Global Market company

ADGM accounting is not harder than mainland accounting. It is different, and the differences are specific enough that generic UAE advice will mislead you. Records are held for ten years rather than five. Accounts follow international accounting standards with no SME concession at company-law level. Filing runs nine months from an accounting reference date the registry already holds. The audit exemption exists but collapses the moment you want the 0% free zone corporate tax rate. And whatever the reason for the audit, only an ADGM registered auditor can sign it.

Get those five right and the annual cycle in Abu Dhabi Global Market is genuinely straightforward. Get any of them wrong and you find out at the worst possible point, which is the week the accounts were due.

Velmont Crest is a DED-licensed UAE accounting and advisory firm supporting companies across the mainland and the free zones with accounting and bookkeeping, audit assistance and corporate tax support. Read more on our insights hub or get a quote through our contact page.

Disclaimer: Velmont Crest is a DED-licensed accounting and advisory firm providing preparation, advisory and compliance support. We are not an ADGM registered auditor, a tax agent or a licensed financial-services provider, and we do not issue audit opinions. ADGM regulations, guidance and fees change; verify the current position with the ADGM Registration Authority and, where relevant, the Federal Tax Authority before acting. All provisions and figures on this page were checked on 5 August 2026.

References

• ADGM — Annual Accounts
• ADGM — Annual Filings
• ADGM Registration Authority — Guidance on financial statements for ADGM qualifying free zone persons, August 2025 (PDF)
• ADGM Companies Regulations 2020, consolidated version (PDF)
• ADGM — The English Common Law System
• ADGM — Find an auditor
• Ministerial Decision No. 84 of 2025 on Audited Financial Statements (PDF)
• Ministerial Decision No. 114 of 2023 on Accounting Standards and Methods (PDF)
• Federal Decree-Law No. 32 of 2021 on Commercial Companies
• FTA — List of Designated Zones (PDF)