What the ADGM Courts are
The ADGM Courts are the independent judicial system of the Abu Dhabi Global Market — Abu Dhabi's financial free zone, established by Abu Dhabi Law No. 4 of 2013 and operational since 2015. They operate at two tiers: the Court of First Instance and the Court of Appeal, with judges drawn from leading common-law jurisdictions (the UK, Singapore, Australia and Hong Kong).
The defining architectural feature of the ADGM — and the principal reason sophisticated commercial parties choose its jurisdiction — is that ADGM directly applies English common law and the body of English statutes in force at any given time, subject to ADGM-specific modifications. This is the only jurisdiction in the region to do so. The DIFC, in contrast, has its own statutory framework supplemented by English principles where there are gaps.
Opt-in jurisdiction
The ADGM Courts have jurisdiction over disputes where the parties have agreed in writing to ADGM jurisdiction, regardless of whether either party is ADGM-domiciled. Opt-in clauses are increasingly common in:
- International financial transactions involving Abu Dhabi-domiciled or sovereign-linked counterparties.
- Family-office and succession structures using ADGM Foundations, Special Purpose Vehicles and Prescribed Companies.
- Cross-border M&A involving Abu Dhabi targets where international buyers want a common-law forum.
- Crypto, virtual-asset and Web3 commercial arrangements — increasingly directed to ADGM as the FSRA's licensed framework matures.
- Joint ventures with ADNOC and other sovereign-linked Abu Dhabi entities where international counsel insist on common-law forum.
ADGM vs. DIFC: how to choose
Both jurisdictions are common-law, English-language, and English-judge-staffed. The distinctions are practical:
| Dimension | ADGM | DIFC |
|---|---|---|
| Legal framework | Direct application of English common law & statutes | DIFC's own statutory framework + English gap-filling |
| Established | 2015 (operational) | 2004 (operational 2006) |
| Case-law base | Smaller, rapidly growing | Deeper, more developed |
| Geographic emphasis | Abu Dhabi commercial & sovereign matters | Dubai financial-services & commercial |
| Court structure | Court of First Instance + Court of Appeal | Small Claims + CFI + Court of Appeal |
| Crypto & virtual assets | FSRA framework — leading regional regulator | DFSA framework — strong but more conservative |
| Family-office structures | Foundations, SPVs, Prescribed Companies | Foundations, Prescribed Companies |
| Onshore enforcement route | Direct via Abu Dhabi Courts | Via 2018 MoU with Dubai Courts |
FSRA-regulated disputes
The Financial Services Regulatory Authority (FSRA) is the ADGM's financial-services regulator. It licenses and supervises banks, asset managers, fund managers, virtual-asset service providers, fintech firms and a wide range of innovation-economy categories. FSRA-regulated entities and their counterparties bring distinctive disputes to the ADGM Courts:
- Regulator-driven enforcement actions and challenges
- Licence revocation appeals
- Misselling and suitability disputes
- Disputes between fund managers and limited partners
- Custody, settlement and clearing disputes
- Capital-markets and disclosure disputes
Crypto and virtual assets
The ADGM, through the FSRA, has been one of the leading global regulators of virtual-asset activities since 2018 — predating most major financial centres. The ADGM Courts have, in turn, become the leading common-law forum in the region for crypto and virtual-asset disputes:
ADGM as an arbitration seat
The ADGM Arbitration Centre (ADGMAC) administers arbitrations seated in the ADGM under the ADGM Arbitration Regulations 2015 and the ADGMAC Arbitration Guidelines. ADGMAC also administers arbitrations under the ICC, LCIA and UNCITRAL rules where parties have selected those institutions or rules but want the ADGM as the seat.
The ADGM is increasingly chosen as a seat for cross-border financial-services and commercial arbitrations where parties want a common-law-friendly supervisory court — the ADGM Court of First Instance — combined with international enforceability under the New York Convention. We have advised parties on the seat-selection question for both DIFC and ADGM-seated arbitrations.
What we handle in the ADGM Courts
Frequently asked questions
What are the ADGM Courts and what makes them unique?
Independent judicial system of the ADGM financial free zone, established by Abu Dhabi Law 4 of 2013. The defining feature is direct application of English common law and English statutes — unique in the region.
How is ADGM different from the DIFC?
Three differences: (i) ADGM applies English law directly, DIFC has its own framework; (ii) ADGM is younger (since 2015), DIFC has deeper case-law; (iii) ADGM dominates Abu Dhabi/sovereign matters, DIFC dominates Dubai financial-services matters.
Can non-ADGM parties opt into ADGM Courts jurisdiction?
Yes — by written agreement. Common in international financial transactions, family-office structures, M&A involving Abu Dhabi targets, crypto/Web3 arrangements, and JVs with ADNOC-linked entities.
Are ADGM judgements enforceable against onshore UAE assets?
Yes — through the Abu Dhabi Courts' Execution Department for AD-domiciled assets, and inter-emirate mechanisms for other emirates. ADGM has international MoUs that streamline cross-border enforcement.
What types of matters does Noura Almaazmi handle in the ADGM Courts?
Commercial disputes, FSRA-regulated financial services, family-office and prescribed-company disputes, ADGM employment, virtual-asset disputes, ADGM-seated arbitration, and foreign judgement/award enforcement.
Does the ADGM offer arbitration as a seat?
Yes — through ADGMAC under the ADGM Arbitration Regulations 2015. Also administers ICC, LCIA and UNCITRAL arbitrations seated in the ADGM. Increasingly chosen for cross-border financial-services arbitrations.
Last updated: 28 April 2026. General information only — not legal advice. Contact us for matter-specific advice.