Beyond the deadline: Embedding whistleblower protections in ADGM companies

As of 31 May 2025, all relevant entities within the Abu Dhabi Global Market (ADGM) were required to have implemented formal whistleblowing policies and procedures in line with the Whistleblower Protection Regulations 2024 (‘the Regulations’). These regulations, enacted on 5 July 2024, introduced a structured framework to protect individuals making good faith disclosures and to enhance regulatory compliance and ethical business conduct across the ADGM. Now that the deadline has passed, we provide a recap of what was required and what ADGM companies should now have in place.

Who was required to comply?

The Regulations applied to a range of Global Market Establishments, including:

• Authorised Persons (as defined under the Financial Services and Markets Regulations 2015);
• Recognised Bodies – such as exchanges or clearing houses operating in the ADGM;
• Designated Non-Financial Businesses or Professions – including law firms, accounting practices, and trust or company service providers;
• DLT Foundations – governed by the DLT Foundations Regulations 2023; and
• Large Establishments (defined as having more than USD 13.5 million in turnover or assets and more than 35 employees in any financial year). 

Importantly, once an entity fell into one of these categories, it remained subject to the requirements even if it no longer met the relevant threshold.

What were the core requirements?

From 31 May 2025 onwards, covered entities were expected to have:

• Implemented written whistleblowing policies and procedures, tailored to their size and operational complexity;
• Put in place confidential and accessible reporting channels for individuals to make protected disclosures, including anonymous reports;
• Assigned appropriate personnel or functions to receive, investigate, and escalate reports of misconduct or regulatory breaches;
• Established safeguards to protect whistleblowers from retaliation, including from dismissal or any form of disadvantage;
• Recorded and maintained documentation of all protected disclosures and any subsequent findings or investigations, with a minimum retention period of six years; and
• Reviewed their arrangements periodically to ensure policies remained effective, proportionate, and up to date.

What constitutes a protected disclosure?

Under the Regulations, a disclosure qualifies for protection if:

• It is made in good faith;
• It concerns actual or suspected breaches of Applicable Law, including financial crime; and
• It is made to an approved recipient, such as:
  • Management or designated whistleblowing officers within the company;
  • Registered auditors;
  • ADGM regulators (e.g., Registrar, Financial Services Regulator, Office of Data Protection);
  • UAE law enforcement; or
  • Other specified authorities.

Whistleblowers were not required to identify themselves to benefit from the protections provided.

Legal protections for whistleblowers

Those who made protected disclosures were entitled to:

• Immunity from civil or contractual liability;
• Protection from termination or adverse employment actions;
• Access to the ADGM Courts for relief in cases of retaliation or loss.

Non-compliance: Regulatory consequences

The ADGM Registrar is empowered to take enforcement action where a Global Market Establishment has failed to meet its obligations. This includes:

• Private or public censures;
• Financial penalties (up to Level 8 on the standard fine scale); and
• Suspension or revocation of commercial licences.

What now?

With the deadline behind us, ADGM entities should have their whistleblowing frameworks fully operational. Those that have met the requirements are now better positioned to:

• Detect and address regulatory breaches early;
• Foster a culture of transparency and accountability; and
• Minimise reputational and legal risks.

For those still refining their arrangements, it’s crucial to treat this as an ongoing compliance obligation. Regular reviews, staff awareness training, and updates to internal policies will ensure that protections remain meaningful and that organisations remain on the right side of the regulations.

Looking ahead

The ADGM Whistleblower Protection Regulations 2024 have set a new standard for corporate governance and ethical conduct in the jurisdiction. As the regime matures, further guidance from the Registrar may help to shape best practice. Entities that continue to invest in robust whistleblowing mechanisms will not only remain compliant, but also build long-term trust with their stakeholders.

To discuss the Regulations reach out to Ben Brown, Sara Khoja or Sarit Thomas.