DFSA and FSRA rulebooks, read directly
DIFC vs ADGM company setup: which do you need?
The choice is rarely about the emirate. It is about whether the activity is a regulated financial service at all, which prudential category it falls into, and what each regulator's rulebook demands in base capital for that category. Answer a few questions to see which regulator you are dealing with and what the capital floor looks like on both sides.
Question 1
What will the business actually do?
Pick the closest description. If several apply, pick the one that would need the heaviest permission.
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Scope of this checker
- Whether the activity needs a financial services licence at all
- Which regulator, the DFSA in DIFC or the FSRA in ADGM, would authorise it
- The prudential category the activity falls into under each rulebook
- Base capital requirements as stated in DFSA PIB 3.6.2 and FSRA PRU 3.3.2
- ADGM licence fee categories as published in the Registration Authority fee schedule
- It does not cover DIFC fee amounts, which DIFC publishes on its own site
DIFC vs ADGM is an independent information site operated by Ellul Solutions Ltd. It is not affiliated with, endorsed by or connected to the Dubai International Financial Centre, the Dubai Financial Services Authority, Abu Dhabi Global Market or the Financial Services Regulatory Authority, and nothing here is legal, regulatory or tax advice. Rulebooks and fee schedules change, confirm every figure against the current rule text and the relevant authority before committing capital.
Base capital by prudential category, DFSA against FSRA
Last updated
The single comparison that decides most DIFC and ADGM questions with a number rather than an opinion. Base capital is the floor a firm must hold in Common Equity Tier 1 capital at authorisation and at all times afterwards. Both columns are taken from the regulators' own rulebooks.
Read from DFSA Rulebook PIB 3.6.2 (Prudential Investment, Insurance Intermediation and Banking Module, version VER53/07-26) and FSRA Rulebook PRU 3.3.2 (version VER20.270426) on the dates shown as our updated date. Headline figures only: both rulebooks carve out lower or higher amounts for specific permissions inside several categories, noted in the right hand column. Amounts are US dollars. The categories are numbered the same way in both zones but the activity definitions are not identical, so match on the activity, not the number.
| Category | Typical activity | DIFC, DFSA | ADGM, FSRA | Carve-outs to check |
|---|---|---|---|---|
| 1 | Accepting deposits, banking | US$10 million | US$10 million | None |
| 2 | Providing credit, dealing as principal | US$2 million | US$2 million | DFSA drops to US$500,000 for matched principal dealing; the FSRA classes matched principal as 3A |
| 3A | Dealing as agent, operating a trading facility | US$200,000 | US$500,000 | FSRA raises to US$2 million for OTC leveraged products with retail clients |
| 3B | Custody for a fund, fund trustee, crypto custody | US$500,000 to US$2 million | US$4 million | DFSA sets US$1 million for crypto custody, US$2 million for acting as fund trustee |
| 3C | Managing assets, managing a fund, trust services | US$500,000 | US$250,000 | Fund manager floors: DFSA US$140,000 or US$40,000, FSRA US$150,000 or US$50,000 |
| 3D | DFSA-only category | US$200,000 | No equivalent | The FSRA rulebook has no Category 3D |
| 4 | Arranging, advising, insurance intermediation, fund administration | US$30,000 | US$50,000 | DFSA US$140,000 for crowdfunding or money transmission; FSRA US$150,000 for a private financing platform |
| 5 | Islamic institution managing an unrestricted PSIA | US$10 million | US$10 million | None |
- DIFC and ADGM require identical base capital for a bank, US$10 million, but differ by two and a half times for a firm dealing in investments as agent: US$200,000 under DFSA PIB 3.6.2 against US$500,000 under FSRA PRU 3.3.2.
- For advisory and intermediation firms, the lightest prudential category in either zone, DIFC's base capital floor is US$30,000 and ADGM's is US$50,000.
- ADGM publishes a full registration fee schedule: US$17,000 to register a financial Category A entity, US$5,800 for a non-financial Category B entity, US$2,800 for retail, US$1,900 for a specialised vehicle and US$1,000 for a foundation, each including a US$300 data protection fee.
Cite this page
“Base capital by prudential category, DFSA against FSRA”, DIFC vs ADGM, https://difcvsadgm.com/ (updated 2026-08-15). Read from DFSA Rulebook PIB 3.6.2 (Prudential Investment, Insurance Intermediation and Banking Module, version VER53/07-26) and FSRA Rulebook PRU 3.3.2 (version VER20.270426) on the dates shown as our updated date. Headline figures only: both rulebooks carve out lower or higher amounts for specific permissions inside several categories, noted in the right hand column. Amounts are US dollars. The categories are numbered the same way in both zones but the activity definitions are not identical, so match on the activity, not the number.
Need this scoped properly before you apply?
Tell us what the business will do and we will introduce you to a regulatory or corporate services adviser who handles DIFC and ADGM applications.
The detail
Sourced, dated, kept current.
- DIFC licence fee and ADGM fees: what each authority publishes
ADGM publishes a full registration and licensing fee schedule in US dollars. DIFC publishes its own on difc.ae. What each covers, and the costs neither schedule includes.
- DFSA and FSRA licence categories compared
Both regulators sort firms into numbered prudential categories, but the definitions differ. What each category covers in DIFC and in ADGM, and where they part company.
- DIFC and ADGM courts and law: how the two systems differ
Both zones run their own courts and their own body of law. Where each derives that law, and what we can and cannot verify about the difference between them.
Questions, answered directly
What is the difference between DIFC and ADGM?
They are two separate financial free zones, DIFC in Dubai regulated by the DFSA and ADGM in Abu Dhabi regulated by the FSRA, each with its own registrar, rulebook, courts and fee schedule. The practical differences are the prudential category your activity falls into, the base capital that category requires, and the cost of premises in each zone.
Which is cheaper, DIFC or ADGM?
It depends on the activity, and on fee schedules published separately by each authority. ADGM's schedule prices a non-financial entity at US$5,800 to register and US$5,300 a year. We do not quote DIFC fees on this site because we have not read the DIFC schedule at source. On base capital, DIFC is lower for Category 3A and Category 4 firms and ADGM is lower for Category 3C.
Do I need a DFSA or FSRA licence?
Only if the business carries on a regulated financial activity: deposits, credit, dealing, advising, arranging, managing assets or funds, custody, trust services, insurance intermediation or the digital asset activities each rulebook lists. Professional services, consultancy, holding vehicles and retail businesses are licensed by the zone's registrar instead.
What is the minimum capital for an ADGM financial licence?
It depends entirely on the category. The FSRA rulebook sets base capital at US$10 million for Category 1 and 5, US$4 million for 3B, US$2 million for 2, US$500,000 for 3A, US$250,000 for 3C and US$50,000 for Category 4, with lower floors for some fund managers and higher ones for specified activities.
Can a company be in both DIFC and ADGM?
A group can hold entities in both, but each entity is registered and licensed in one zone and must maintain premises and meet requirements there. That doubles the registrar fees, the premises cost and the regulatory relationship, so it is normally driven by a specific commercial reason rather than optionality.
Does UAE corporate tax apply in DIFC and ADGM?
Yes. The Ministry of Finance states that juridical persons established in a UAE free zone are within the scope of corporate tax as taxable persons and must comply with the Corporate Tax Law. A free zone person that meets the conditions to be a Qualifying Free Zone Person can then benefit from a 0% rate on its Qualifying Income.
Sources
- DFSA Rulebook. PIB 3.6.2, base capital requirement by category
- DFSA Rulebook, PIB 1.3, categorisation of authorised firms
- ADGM FSRA Rulebook. PRU 3.3.2, base capital requirement by category
- ADGM FSRA Rulebook, PRU 1.3, categorisation of authorised persons
- ADGM Registration Authority, Overview of Fees
- ADGM legal framework, commercial legislation index
- ADGM, setting up
- Ministry of Finance, corporate tax and free zone persons
Route the activity before you pick the zone.
Six questions, then the regulator, the category and the capital floor on both sides.
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