ADGM Family Office Setup: Structures, Requirements and Process

Abu Dhabi Global Market has become an important base for wealthy families that want to manage investments, operate businesses and plan succession from the UAE.

What makes an ADGM family office setup interesting is the range of structures available. You can establish a Single Family Office, operate a regulated Multi-Family Office or create a wealth-holding structure using foundations, SPVs and trusts. The right choice depends on what you actually want the structure to do.

If the office will manage the affairs of your own family, the regulatory route is relatively straightforward. If you plan to advise or manage wealth for several unrelated families, Financial Services Regulatory Authority (FSRA) approval may be required.

This guide explains the current requirements, structures, costs and application process.

What Is an ADGM Family Office?

A family office is an organisation created to manage the financial and, in some cases, personal affairs of a wealthy family. Depending on the family's needs, the office may deal with investment administration, accounting, wealth planning, property, family businesses, risk management and succession matters.

The official ADGM family office framework currently provides three broad routes: a Single Family Office, a Multi-Family Office and structuring-only solutions using vehicles such as foundations and SPVs.

ADGM operates an independent legal framework based on the direct application of English common law. This is one reason international families consider it for long-term ownership and succession structures.

ADGM Family Office Structures

1. Single Family Office

   A Single Family Office, or SFO, serves one family.

   ADGM currently states that the family must have at least USD 10 million in net assets. This is worth checking carefully because older online material may still refer to a USD 30 million threshold. The current ADGM family office guidance lists USD 10 million.

   An SFO can perform several functions for the family, such as:

   • Investment and wealth planning

   • Accounting and financial administration

   • Risk management

   • Family business oversight

   • Tax planning coordination

   • Property and lifestyle administration

   • Holding family assets

   • Succession-related administration

   An SFO serving its qualifying family does not require a Financial Services Permission from the FSRA under ADGM's current family office framework. It is instead treated as a controlled licence activity.

   Families wanting greater privacy may also consider a Restricted Scope Company (RSC). An RSC provides more limited public disclosure while still providing full information to the ADGM Registrar. An additional USD 3,100 RSC registration or renewal fee currently applies on top of standard fees.

2. Multi-Family Office

   A Multi-Family Office, or MFO, provides services to more than one family.

   That changes the regulatory position.

   ADGM states that MFOs are generally regulated by the FSRA under a Category 4 Financial Services Permission, commonly covering activities such as advising on investments and arranging investment transactions.

   The FSRA will look at the exact activities proposed. If your office plans to manage assets on a discretionary basis, hold client assets or conduct other regulated activities, additional permissions and higher prudential requirements may apply.

   The authorisation process examines areas such as senior management experience, governance, financial resources, systems, internal controls and the proposed regulatory plan.

   This makes an MFO considerably more involved than an SFO.

3. Foundation, SPV and Trust Structures

   You do not necessarily need a full operating family office.

   Some families already have investment managers and advisers elsewhere. They mainly need a UAE structure to hold assets or organise succession.

   ADGM therefore allows families to use several wealth structuring vehicles.

   ADGM Foundation: A foundation is a separate legal entity without conventional shareholders. It can hold assets for beneficiaries according to its Charter and By-laws. The required initial assets can be as little as USD 100.

   ADGM SPV: A Special Purpose Vehicle can hold investments, company shares, intellectual property or other assets while separating liabilities between different holdings. ADGM SPVs must demonstrate an appropriate connection, or nexus, to ADGM, the UAE or the GCC.

   ADGM Trust: A trust creates a relationship between the settlor, trustee and beneficiaries. Unlike a foundation, it does not generally operate as a separate incorporated legal person.

   This layered approach can work well. For example, a foundation may sit at the top of the ownership structure while separate SPVs hold real estate, operating-company shares and investment portfolios.

   If your structure involves several corporate entities, Nexture's guide to a UAE shareholder agreement can help you understand how ownership and governance arrangements are documented.

ADGM Family Office Requirements

• The requirements depend on the route you choose.
• For a Single Family Office, you should generally be ready to demonstrate:

• At least USD 10 million in family net assets

• A genuine single-family relationship

• A clear business plan

• Proposed activities of the family office

• Ownership and governance structure

• Details of directors and authorised signatories

• Ultimate beneficial ownership information

• Source of wealth or supporting financial evidence where requested

• An ADGM registered office

• Compliance with applicable data protection requirements

ADGM notes that the Registrar can request source-of-wealth documents for shareholders or UBOs. These may include recent bank statements and supporting declarations.

Documents You May Need

Your exact checklist will depend on the legal entity and shareholders, but commonly requested information includes:

• Passport copies of shareholders, directors and authorised signatories

• Emirates ID copies where applicable

• Proof of residential address

• Business plan

• Family ownership or relationship information

• Corporate structure chart

• Ultimate Beneficial Owner details

• Source-of-wealth evidence if requested

• Articles of Association

• Incorporation resolution

• Registered office information

• Details of share capital

• Data protection information

Corporate shareholders may also need their certificate of incorporation, shareholder register, constitutional documents and a board resolution approving the ADGM entity.

ADGM's registration and incorporation guidance provides the relevant checklists and templates.

How to Set Up a Family Office in ADGM

1. Decide What the Family Office Will Do

   Start with the services. Are you simply holding family investments? Will staff actively manage the family's wealth? Will the office provide services to unrelated families?

   This determines whether you need an SFO, MFO or asset-holding structure.

2. Design the Ownership Structure

   Decide whether you need a foundation, holding company or SPVs around the operating family office.

   Do this before incorporation. Restructuring major assets afterwards can create extra legal, banking and tax work.

3. Prepare the Business Plan

   ADGM specifically requires a business plan before beginning the Single Family Office and SPV application process.

   Explain the family's assets, proposed activities, governance arrangements, funding and expected operations clearly.

4. Obtain FSRA Approval if Required

   A pure SFO generally does not follow the FSRA financial-services authorisation route. An MFO normally does.

   For regulated financial activities, you first engage with the FSRA, submit the regulatory application and work through its review and in-principle approval process. You then proceed with Registration Authority incorporation.

5. Submit the ADGM Registration Application

   Create an account through the ADGM online registry, complete the application and upload the supporting documents.

   ADGM states that correctly prepared registration applications can be completed within a few days, although complex ownership or regulated structures can take considerably longer.

6. Open the Bank Account and Complete Post-Setup Compliance

   After incorporation, you can begin the corporate banking process. Banks will usually review the ownership chain, source of wealth, expected transactions, investment activities and the reason for establishing the structure.

How Much Does an ADGM Family Office Cost?

ADGM currently publishes the following indicative figures:

Additional name reservation, RSC, office, visa, regulatory and professional-service costs may apply. ADGM also states that third-party provider charges vary.

For non-exempt SPVs and foundations, an ADGM-licensed Company Service Provider may also be mandatory. 

Conclusion

An ADGM family office setup can work well when your family needs a structured base for investments, family businesses and long-term succession planning.

The main decision is choosing the right level of structure. A Single Family Office can suit one wealthy family with at least USD 10 million in net assets. An MFO makes more sense when services will be provided to multiple families but brings FSRA regulation with it. Families focused mainly on ownership and succession may prefer a foundation, SPV or combination of vehicles instead.

Get the ownership, regulatory and tax design clear before submitting the application. Those decisions are much harder to change after the family's major assets have already been transferred into the structure.

Frequently Asked Questions