January 2026 · Financial Regulation · Free Zones

Two Financial Free Zones, Two Regulators: DFSA and FSRA

By Mohammed Irfan · DeccanBridge

Financial services firms often say “ADGM and DFSA” in one breath — but the DFSA regulates the DIFC and the FSRA regulates ADGM. Knowing which rulebook applies is the first compliance decision.

The DIFC and the DFSA

The Dubai Financial Services Authority regulates financial and ancillary services in the DIFC under its own rulebook — the General Module, Conduct of Business and prudential modules. Authorisation depends on the regulated activity, the prudential category and the firm’s capital, systems and senior-management arrangements. Authorised Individuals carry personal regulatory responsibility.

ADGM and the FSRA

Abu Dhabi Global Market is regulated by the Financial Services Regulatory Authority, applying a common-law framework and FSRA rulebooks (COBS, PRU and GEN). ADGM has built distinct regimes for virtual assets, sustainable finance and innovation testing. Despite similar structures, the DFSA and FSRA rulebooks are not interchangeable.

Ongoing Obligations

Both regimes require continuing compliance: prudential returns, controllers and close-links notifications, AML/CFT supervision, client-asset rules and fitness-and-propriety of approved persons. A firm passporting an operating model from another jurisdiction should expect to rebuild its compliance monitoring programme to the relevant local rulebook.

Evidence Pack

  • 01 Regulated-activity and prudential-category analysis for the correct regulator (DFSA / FSRA).
  • 02 Authorisation pack: regulatory business plan, financial projections and systems-and-controls evidence.
  • 03 Approved/Authorised person fitness-and-propriety files.
  • 04 Compliance monitoring programme, prudential return calendar and AML supervision mapping.