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September 16, 2026
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ME-ALLIANCE LEGAL INSIGHT
ADGM Proposes Regulatory Framework for Crypto Mining
The Abu Dhabi Global Market (ADGM) Registration Authority (RA) has issued a discussion paper and proposed guidance setting out a framework for the licensing and supervision of crypto mining as a commercial activity conducted in or from ADGM.
The proposals seek to provide greater regulatory clarity for crypto-mining businesses while maintaining a distinction between commercial crypto-mining activities and regulated financial services.
Classification and Licensing
Under the proposed framework, crypto mining will not constitute a regulated financial service and therefore will not require authorisation from the Financial Services Regulatory Authority (FSRA) solely for conducting mining activities.
Instead, commercial crypto-mining operations will be treated as a licensable commercial activity. Entities conducting such activities will be required to obtain and maintain an ADGM Commercial Licence for “Crypto Mining” and comply with applicable ADGM commercial legislation and relevant UAE Federal laws.
Small-scale, non-commercial mining activities conducted by individuals are generally outside the proposed licensing scope.
Legal Status of Mined Digital Assets
A significant aspect of the proposed guidance is the recognition of digital assets lawfully generated through mining as property under ADGM law.
This provides a clearer legal basis for the ownership and transfer of mined assets and may facilitate commercial arrangements involving such assets, including financing, collateral and security interests. However, mining operators will need reliable records demonstrating the origin, quantity, timing and valuation of mined assets.
Proper accounting and record-keeping will therefore become increasingly important, particularly where mined assets are used in commercial or financing arrangements or are subject to applicable federal tax obligations.
Licensing and Compliance Expectations
The RA is expected to apply enhanced scrutiny to larger or more complex mining operations. Applicants may be required to provide information concerning:
• operational and business plans;
• infrastructure and cybersecurity arrangements;
• business continuity and operational resilience;
• security measures; and
• on-chain activity and disclosures.
Mining entities will also be expected to maintain accurate records of their ultimate beneficial ownership (UBO), governance and corporate structure, and notify the RA of material changes.
Where mining-related services are provided to third parties, operators may also be required to provide clear information concerning applicable terms, fees, risks and the handling of client assets.
Risk-Based Supervision and Enforcement
The proposed framework adopts a risk-based supervisory approach. The RA may use regulatory tools including periodic reporting, thematic reviews, third-party audits and on-site inspections.
Depending on the nature and severity of non-compliance, enforcement measures may include warnings, remediation directions, financial penalties and suspension or revocation of a commercial licence.
Practical Implications
The proposed framework represents an important development in the regulation of digital-asset infrastructure within ADGM. By bringing commercial crypto-mining activities within a defined licensing framework, ADGM seeks to provide greater certainty while establishing expectations around corporate transparency, governance, cybersecurity, operational resilience and regulatory oversight.
Businesses considering establishing or managing crypto-mining operations from ADGM should assess their licensing, governance, record-keeping and compliance arrangements in advance and monitor the final framework following the consultation process.
Middle East Alliance Legal Consultancy recommends that prospective operators consider the proposed requirements at an early stage, particularly where mining activities involve significant infrastructure, third-party services, cross-border operations or the commercial use of mined digital assets.
ADGM Registration Authority Publishes Discussion Paper on Crypto Mining Activities
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