ADGM announces new Crypto Mining Guidance

In January 2026, the Abu Dhabi Global Market (“ADGM”) took a significant step into the crypto-mining space by introducing a formal regulatory framework, accompanied by detailed guidance, governing the licensing and supervision of crypto-mining activities conducted within or from its jurisdiction. This development reflects ADGM’s broader commitment to establishing a clear, structured, and transparent environment for emerging digital asset activities, ensuring that operators in the crypto-mining sector are subject to defined regulatory standards, oversight mechanisms, and compliance requirements.

Why is this guidance significant for crypto mining in ADGM?

Under this guidance, ADGM recognized Digital Assets as ownable assets generated either by Mining or received as block awards. Moreover, ADGM subjected these assets to the relevant laws of commercial transactions and property. In terms of taxation, the ADGM hinted out that it is considered as a federal matter and falls outside the scope of the jurisdiction.

In addition, this guidance provides a new approach to all ADGM registered entities operating the business activity of crypto-mining by setting the expected regulatory requirements for all these entities to abide by. It also clarifies that small-scale, non-commercial crypto mining conducted by individuals for personal use falls outside the scope of the guidance and its licensing requirements.

What are the licensing requirements for a crypto mining entity?

This Guidance establishes a clear pathway for the primary licensing requirements applicable to crypto mining entities. In particular, any entity intending to undertake such activity must obtain a commercial license from the Registration Authority (“RA”) of ADGM, expressly specifying “Crypto Mining” as its registered business activity.

Secondly, the RA may require from large-scale entities to provide them with the following plans:

• Detailed operational plan: Entities must provide a comprehensive overview of their crypto-mining operations, including hardware and software specifications, expected scale (e.g., hash rate and number of machines), operational workflow, location within ADGM, and a risk management framework addressing key operational, technical, and security risks.
• Disclosure of on-chain assets plan: Entities must, upon request, disclose all blockchain wallet addresses and smart contracts they own or control.
• Infrastructure, Security, and Resilience plan: Entities are required to outline measures for physical site security, cybersecurity aligned with recognized standards (such as ISO 27001 and NIST), heat management systems, and robust business continuity and disaster recovery plans.

Transparency, Disclosure, and Supervision Procedures

ADGM imposes transparency and disclosure obligations on crypto mining entities to ensure continuous compliance with its regulatory framework. Licensed entities must adhere to specific conditions throughout their operations, including maintaining transparency through accurate and up-to-date records of ultimate beneficial ownership (UBOs), management, and corporate structure, and promptly reporting any material changes to the RA. Entities providing services to third parties are also required to clearly disclose terms, fees, risks, and asset handling practices. Additionally, the RA enhances transparency through a public register of licensed entities and may publish anonymized sector data, while also monitoring on-chain assets using third-party tools to track relevant blockchain wallets and smart contracts.

In terms of supervision over registered crypto-mining entities, the Guidance denoted that the RA will exercise its supervision on a based risk-sensitive basis. This means that the level of supervision varies depending on the nature and scale of the activity as entities operating at a larger scale or providing services to third parties may be subject to more strict regulatory oversight. This supervision will include off-site monitoring through review of reports, on-site inspections (including overseas and, where necessary, unannounced visits), and requests for independent third-party verification such as audits or attestations. It also conducts thematic reviews targeting specific sector risks, issues formal information requests, and may leverage third-party technological solutions to monitor activities.

It is worth mentioning that any material breach of the above-mentioned licensing conditions, applicable legislation of ADGM, or relevant UAE federal laws may trigger enforcement action by the RA such as formal warnings, financial penalties, mandated remedial actions, and, in more serious cases, the suspension or cancellation of the commercial license.

Can Crypto Mining Entities Operate Overseas?

This Guidance recognizes that crypto mining entities may operate as headquarters overseeing global mining activities and, accordingly, requires comprehensive transparency and risk management for such overseas operations. Entities must disclose detailed information about their international footprint, including locations, scale, ownership structures, and key personnel, while conducting robust due diligence on host jurisdictions and business partners. Moreover, it is expected from these entities to apply ADGM’s governance and compliance standards across their global operations, ensuring consistency with all applicable regulatory requirements. The RA may exercise oversight through periodic reporting, additional information requests, and cooperation with international regulators, and entities are required to promptly notify the RA of any material compliance breaches or regulatory actions arising from their overseas operations.

How Rasma Legal Can Help

If you would like to explore in details the regulatory framework of crypto-mining in ADGM or in the UAE, how its requirements can be implemented in practice, including governance frameworks, model oversight, and compliance alignment, we are pleased to fully support you at Rasma Legal.