Reporting & Disclosure in United Arab Emirates

Key dates

2026-10-23

ADGM’s Registration Authority announced the enforcement action and the total USD 88,000 penalties against MCA Auditors and its registered Audit Principal.

Suggested considerations

• Registered audit firms should consider performing a documented file-by-file review of risk assessments, fraud-risk responses, group-audit instructions and evaluations, communications with those charged with governance, and sufficient appropriate audit evidence for material balances and disclosures.
• Registered Audit Principals should consider documenting substantive involvement at planning, risk assessment, supervision, review, consultation, resolution of significant matters and completion stages, rather than relying on evidence of a final sign-off alone.
• Firms should consider mapping each engagement to the applicable requirements in the Companies Regulations (Auditors) Rules 2023 and the relevant International Standards on Auditing, with evidence of review and clearance of identified deficiencies.
• Audit firms should consider maintaining a formal root-cause analysis, remediation plan, ownership allocation, target dates and effectiveness testing process so that remediation can be demonstrated during a subsequent RA inspection.
• Audit committees and other those charged with governance at ADGM-registered entities should consider challenging the auditor on fraud risks, group-audit scope, significant judgments, material evidence and the registered principal’s oversight before approving or relying on the audit.
• ADGM audit firms should consider preparing for continued RA monitoring and inspections, including ensuring that working papers and governance communications are complete, contemporaneous, retrievable and internally consistent.

What changed

This is an enforcement action rather than a new rule or amendment. It applies the Companies Regulations (Auditors) Rules 2023, including the obligations for Registered Auditors and Registered Audit Principals to conduct audit work in accordance with applicable technical and professional standards, including International Standards on Auditing, and to exercise due skill, care and diligence. The action signals that ADGM inspections will assess the complete audit evidence trail and the registered principal’s documented involvement across the engagement, not merely the final audit opinion.

Key dates

2026-10-09

FSRA published Consultation Paper No. 6 of 2026 on proposed revisions to the FEES and GEN Rulebooks.

2026-11-06 Deadline

Consultation closes and written comments are due to the FSRA.

2027-01-01

Implementation is proposed by independent market commentary to begin, subject to consultation feedback and final FSRA rulemaking; this is not yet an adopted effective date.

Suggested considerations

• Compliance teams may wish to review the consultation paper, Appendix 1 amendments to FEES, Appendix 2 amendments to GEN and Attachment 1 amendments to the GPM, and submit written comments to [email protected] by 2026-11-06.
• Market-infrastructure operators may wish to model the proposed application, annual supervision, Official List and trading-related charges against current budgets and assess whether the proposals affect pending applications or planned launches.
• Virtual-asset MTF operators and applicants may wish to recalculate total regulatory costs using the proposed USD 100,000 base MTF application fee, USD 40,000 base annual supervision fee, USD 25,000 virtual-asset application fee and USD 20,000 virtual-asset annual fee.
• Authorised Persons may wish to inventory permissions covering Virtual Assets, Fiat-Referenced Tokens and Spot Commodities and determine whether a proposed permission addition would trigger a separate variation or activity fee.
• Regulatory reporting owners may wish to test filing calendars, escalation controls and management information against the proposed USD 1,000, USD 2,000 and USD 3,000 late-filing stages, while recognising that the proposed regime is not yet binding.
• Applicants and compliance officers may wish to review change-in-control and variation-of-permission procedures, including whether proposed applications require additional supporting information or revised fee calculations.
• Firms may wish to prepare implementation plans for a possible 2027-01-01 commencement while continuing to apply the existing FEES and GEN requirements until final amendments are published.

What changed

The consultation proposes completing the FSRA's review of market-infrastructure fees by revising charges payable by Recognised Bodies and by operators of Multilateral Trading Facilities and Organised Trading Facilities. For a virtual-asset MTF, independent analysis of the proposed FEES amendments identifies a proposed underlying MTF application fee of USD 100,000 and annual supervision fee of USD 40,000, plus proposed virtual-asset-specific fees of USD 25,000 on application and USD 20,000 annually, producing proposed totals of USD 125,000 and USD 60,000 before any applicable trading levy or...

Key dates

2026-10-09

ADGM's Registration Authority published the enforcement action and announced total penalties of USD 100,000 against PKF and its registered audit principal.

Suggested considerations

• Compliance teams at ADGM-registered audit firms should consider performing a documented review of current audit files against the applicable ISA requirements, with particular attention to fraud-risk assessment, audit evidence, audit documentation and the basis for audit conclusions.
• Registered audit principals should consider ensuring that their involvement, review work, judgments and approval of audit reports are clearly evidenced in the engagement file rather than relying on undocumented supervision.
• Audit firms should consider reviewing engagement acceptance, staffing, supervision, consultation, quality-control and file-completion processes to determine whether they support the required standard of due skill, care and diligence.
• Firms should consider conducting a targeted look-back across comparable ADGM engagements and retaining evidence of any remediation, especially where the same audit principal, methodology or documentation weaknesses may recur.
• ADGM entities and their boards or audit committees should consider confirming that their appointed auditor is appropriately registered and that significant audit judgments, fraud-risk procedures and evidence supporting the audit opinion are adequately documented.
• Senior management and professional-indemnity stakeholders should consider the possibility of separate financial and reputational consequences for the audit firm and the responsible registered audit principal.

What changed

This publication does not introduce a new rule or compliance deadline; it applies existing requirements under the Companies Regulations (Auditors) Rules 2023 to a specific audit engagement. The RA imposed USD 65,000 on PKF and USD 35,000 on its registered audit principal, demonstrating that enforcement exposure can attach separately to both the audit firm and the responsible individual.

Key dates

2026-10-01

ADGM published Consultation Paper No. 4 of 2026 proposing the Strata Regulations 2026.

2026-10-22 Deadline

Public consultation closes; comments should be submitted through the ADGM Registration Authority Consultation Portal by this date.

Suggested considerations

• Compliance and legal teams may wish to review the proposed Strata Regulations 2026 and Model Articles against existing strata governance, management agreements, building management statements and developer rights.
• Developers may wish to assess the proposed single Registrar approval process, required disclosure statement and strata management statement, staged-development arrangements, bank-guarantee exposure and six-month handover obligations.
• Existing strata developments may wish to map the likely automatic establishment of an Association when the Regulations commence, including legal-entity, contracting, banking, governance and record-keeping implications.
• Property-management businesses may wish to assess whether they hold, or can obtain, the required ADGM licence to act as an Association Manager and whether their service model supports competitive quotations and Registrar-approved budgets.
• Associations and developers may wish to model general-fund and reserve-fund requirements, including the three-year minimum reserve-fund study cycle, annual reserve forecast and restrictions on reserve-fund expenditure.
• Relevant stakeholders may wish to review defect-reporting, remediation, structural-integrity and Registrar-notification processes and identify evidence, escalation and document-retention controls.
• Developers, owners and advisers may wish to submit comments through the ADGM Registration Authority Consultation Portal by 22 October 2026; comments sent only to the consultation email address may not be considered.
• Firms should avoid treating the proposals as operative requirements because ADGM states that stakeholders should not act on them until the Regulations are enacted and published.

What changed

The proposed regime would replace the existing two-step strata-plan approval process with a single process administered by the Registrar. Developers would submit a proposed strata plan, disclosure statement and strata management statement; the Registrar could approve, condition, defer, request amendments to, or reject the application, and could defer registration until construction completion and required folios or subdivisions were established.

Key dates

2026-07-09

DFSA issued Consultation Paper No. 174 for public consultation.

2026-08-24 Deadline

Public-comment deadline identified in independent commentary on CP 174.

2026-10-01

DFSA published the feedback statement and the relevant final rule-making instruments.

2026-10-02

PIB Rule-Making Instrument No. 443 of 2026 came into force, implementing final prudential-reporting amendments.

2027-01-01

COB Rule-Making Instrument No. 444 of 2026 comes into force, implementing final COB amendments relevant to the CP 174 workstream.

Suggested considerations

• Compliance teams may wish to obtain and review PIB Rule-Making Instrument No. 443 of 2026 and its appendices, identifying changes to applicable prudential reporting forms, data fields, validation controls and submission procedures.
• Affected PIB firms should consider testing reporting systems and reconciliations against the amended requirements and documenting ownership for any revised regulatory returns that are already effective.
• Credit rating agencies may wish to map existing independence, conflict-of-interest, employee-related restriction and rating-announcement disclosure controls against COB Rule-Making Instrument No. 444 of 2026 before its 1 January 2027 commencement.
• Firms should distinguish the final PIB and COB amendments from the still-pending Crypto and Investment Token proposals and avoid treating the latter as current DFSA requirements.
• Governance and regulatory-change teams may wish to retain the CP 174 feedback statement, final instruments and archived prior rulebook versions to evidence implementation decisions and change impact assessments.

What changed

The DFSA published final rule-making instruments for amendments arising from CP 174. The PIB Rule-Making Instrument No. 443 of 2026, covering prudential reporting requirements, came into force on 2 October 2026. The COB Rule-Making Instrument No. 444 of 2026, which contains final amendments relevant to the credit rating agency framework, will come into force on 1 January 2027.

Key dates

2026-10-02

The prudential reporting amendments, including the redesigned Form B110 framework, came into force.

2027-01-01

The amended credit rating agency requirements come into force.

Suggested considerations

• Credit rating agencies should map existing conflicts-of-interest policies, relationship assessments and escalation controls against the new principles-based requirements before 2027-01-01.
• Credit rating agencies should review rating-announcement templates, annual disclosures and website disclosures to identify content that can be removed or consolidated, while retaining enough information for users to understand how each rating was determined.
• Credit rating agencies should document how they will identify relationships that may reasonably be perceived as conflicts, not only relationships that create an actual conflict.
• All authorised firms should review the redesigned Form B110 and its applicable data items, reporting frequency and submission instructions, including data previously maintained for Forms B180 and B120.
• Compliance and regulatory-reporting teams should reconcile the first B110 submission against prior B120 and B180 returns and update reporting ownership, source-system mappings, validation controls and governance records.
• Firms should confirm whether any firm-specific DFSA direction or prudential-category exception affects the B110 data items they must submit.
• Firms should retain evidence of implementation, including amended procedures, reporting mappings, control testing and approvals, in case the DFSA reviews the transition.

What changed

For credit rating agencies, the DFSA will assess relationships that may cause, or may reasonably be perceived as causing, a conflict of interest under a more principles-based framework rather than through unnecessarily prescriptive requirements. The amendments remove duplicative or overly detailed disclosure obligations while retaining the overarching requirement to provide sufficient information for users to understand how a credit rating was determined.