The Abu Dhabi Global Market (ADGM) Registration Authority (RA) has recently taken a major step toward clarifying how cryptocurrency mining activities should be governed within its jurisdiction. On 28 January 2026, the RA published Discussion Paper No. 1 of 2026, inviting industry feedback on proposed guidance that would formalize the legal status, licensing, governance, and supervision of crypto mining operations conducted in or from ADGM.
Why This Matters
Historically, crypto mining — the resource-intensive process used to validate network transactions and create new digital assets — has often operated in a legal grey area across many global markets. ADGM’s new proposal aims to introduce legal clarity and regulatory certainty, striking a balance between supporting innovation and safeguarding operational resilience, transparency, and market integrity.
Classification and Legal Status
One of the central tenets of the RA’s proposal is the formal classification of crypto mining as a commercial activity. Rather than treating mining as a regulated financial service under the Financial Services Regulatory Authority (FSRA), the RA proposes that it should instead be regulated under ADGM’s Commercial Licensing Regulations. This places mining squarely within the RA’s remit and aligns it with other commercial enterprises operating in the free zone.
In doing so, the RA also confirms that digital assets generated through mining will be recognized as property under ADGM law. This has important implications: mined assets can be legally held, transferred, used as collateral, or structured into commercial arrangements — provided that entities keep accurate and traceable records of how those assets were generated and managed.
Licensing and Pre-Application Expectations
Under the proposed guidance:
- Entities engaged in crypto mining must obtain and maintain an ADGM commercial licence specifically for “Crypto Mining.”
- Applicants — especially those involving larger or more complex operations — should be prepared to provide detailed documentation on operational plans, infrastructure security, resilience strategies, and on-chain disclosures.
- Small-scale personal mining by individuals, however, generally remains outside the scope of this regime.
These expectations reflect the RA’s intention to ensure that licensed operators are equipped with robust governance structures and compliance frameworks befitting an international finance centre.
Governance, Transparency & Compliance
Clear governance and transparency are at the centre of the RA’s proposals. Key expectations for mining entities include:
- Ongoing disclosure of ultimate beneficial ownership (UBO) and corporate structures.
- Accurate, up-to-date records of the entity’s mining activities, including timestamps, wallet addresses, and valuation points.
- Where services are offered to third parties, the RA expects transparent terms, clear disclosures of risks and fees, and proper handling of client-related digital assets.
These requirements not only align ADGM’s mining regime with international standards on accountability and anti-money laundering transparency, but also build investor confidence by enabling rigorous oversight and verifiable audit trails.
Risk-Based Supervision
The RA’s proposed supervisory framework is risk-based and tailored to the scale and complexity of the mining operation. The authority would deploy a range of tools, such as:
- Periodic reporting and thematic reviews,
- Third-party audits,
- On-site inspections (potentially unannounced), even at overseas locations if the entity’s operations are managed from ADGM.
Enforcement mechanisms could include formal warnings, remediation orders, financial penalties, or even licence suspension or revocation for non-compliance.
Global Operations and Headquarters Oversight
Recognizing the inherently global nature of crypto mining — where infrastructure and data centres often span multiple jurisdictions — the RA also proposes a framework for ADGM-registered entities that manage overseas mining operations. Under this model, governance, cybersecurity, and compliance standards applied in ADGM are expected to extend across the entity’s entire global footprint, ensuring consistent oversight and risk management regardless of where physical mining assets are located.
Consultation and Next Steps
The RA is currently seeking public responses and industry feedback on the draft guidance, with the consultation open until 20 March 2026. Stakeholders — including ADGM-registered entities, service providers, technology vendors, auditors, and global headquarters that oversee mining operations — are invited to contribute views that could help shape the final guidance.
