Crypto mining in ADGM: The Registration Authority's proposed guidance

The Abu Dhabi Global Market (ADGM) Registration Authority (RA) has issued a discussion paper and proposed guidance that formalise how crypto mining will be licensed and supervised as a commercial activity conducted in or from ADGM.

While crypto mining remains outside the financial services perimeter, the proposals set clear expectations on licensing, corporate transparency, operational resilience, and supervision.

Classification and scope

Crypto mining is not a regulated financial service within ADGM; no Financial Services Regulatory Authority (FSRA) authorisation is required. 

Under the discussion, crypto mining is a licensable commercial activity. Entities must obtain and maintain an RA Commercial Licence for “Crypto Mining”, and comply with ADGM’s Commercial Licensing Regulations, Companies Regulations, and applicable UAE Federal laws. 

Small scale, non commercial activity by individuals is generally out of scope.

Legal status of mined assets

The guidance confirms that digital assets lawfully generated through mining are recognised as property under ADGM law. Consequently, mined assets fall within the ordinary rules of property and commercial transactions. Although taxation is a federal matter and not governed by the RA, the proposals acknowledge potential tax implications underscoring the need for early tax and accounting alignment.

Recognising mined assets as property does more than confirm that mining rewards can be owned and transferred, it also creates a foundation for more sophisticated commercial arrangements. Once digital assets are treated as property, operators can structure financing, collateral, and security interest arrangements over predictable future reward flows. This allows lenders and investors to assess the value and enforceability of those rights with far greater confidence. However, such arrangements only work if the operator can evidence a clear and traceable record of how those assets were generated. This is why consistent valuation methods, and detailed records of activity become essential. Without well maintained ledgers; capturing timestamps, wallet addresses, and valuation points; counterparties may view the mining operation as opaque or difficult to verify, which can limit funding options or increase the cost of capital. Precise record keeping also reduces the potential for tax disputes where federal tax obligations apply, since regulators and auditors will expect mining entities to substantiate the origin, quantity, and value of mined assets with accuracy.

Licensing expectations and pre application evidence

Applicants, particularly entities conducting larger or more complex mining operations, should expect the RA to request detailed materials that go beyond basic trade licence filings. These may include:

• Detailed Operational Plans
• Infrastructure, Security, and Resilience Plans: 
• On chain Disclosure

Corporate transparency and client facing services

Under the proposal, mining entities must maintain up to date records of ultimate beneficial ownership (UBO), governance, and corporate structure with the RA, notifying it promptly of material changes. Where services are offered to third parties, the RA expects clear, accurate, and accessible information on terms of service, fees, risks, and any handling of client assets. The RA maintains a public register of licensed entities and may publish anonymised, aggregated sector data.

Risk-based supervision and enforcement

Supervision is suggested to be risk sensitive. The RA’s toolkit, as part of the discussion paper includes periodic reporting, thematic reviews, third party audits, and on site inspections, potentially unannounced and, where applicable, at overseas locations managed from ADGM. Enforcement options range from warnings and remediation directions to financial penalties and licence suspension or revocation.

in our view, ADGM’s latest guidance on crypto mining marks a meaningful elevation in the regulatory treatment of digital asset infrastructure. By setting out a technology neutral, commercially focused licensing regime, the framework has the potential to finally bring structure and predictability to an activity that has rapidly scaled but often without clear supervisory anchors. The proposed requirements, ranging from beneficial ownership transparency and rigorous governance standards to operational resilience, cybersecurity expectations, and risk based oversight, reflect a deep understanding of both the innovation and the vulnerabilities inherent in mining operations. The guidance also addresses a long standing industry gap by clarifying how entities headquartered in the jurisdiction should manage and supervise their global mining portfolios, reinforcing the need for consistent standards across borders. Overall, this is a significant step toward aligning global mining operations with mature regulatory principles while preserving space for responsible technological evolution.

Conclusion

ADGM’s proposals elevate crypto mining to a professionally governed, transparently supervised commercial activity. For serious operators, the framework offers legal certainty on asset status, a credible licensing route, and a robust platform for regional or global headquarters balanced by heightened expectations on governance, security, disclosure, and cross border oversight. Proactive preparation during the consultation window will position market participants to meet, and help shape, the final standards.

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