Guide

ADGM courts litigation and DIFC courts: how the two systems differ

Updated 2026-08-15

The legal system is the difference people cite most and evidence least. Here is what the two authorities' own legal frameworks say, and where we stop short.

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Question 1

What will the business actually do?

Pick the closest description. If several apply, pick the one that would need the heaviest permission.

How each zone was constituted

ADGM states its constitutional basis on every page of its legal framework: it was established under Federal Decree No. (15) of 2013, creating a financial free zone in the Emirate of Abu Dhabi.

Its legal framework index also lists Federal Law No. (8) of 2004, the federal financial free zones law, and Abu Dhabi Law No. 4 of 2013.

For DIFC, the equivalent statement we can verify today comes from its regulator. The DFSA describes itself as a body established under Dubai law as the independent regulator of financial services and related activities for the DIFC.

Where the law comes from

ADGM's commercial legislation index includes a set of regulations named the Application of English Law Regulations. DIFC instead enacts its own body of DIFC laws, drafted in a common law style but standing on their own. That distinction is the substance of most DIFC and ADGM comparisons you will read.

We have deliberately not summarised what the Application of English Law Regulations do. The regulation text was not readable to us at source, and characterising a constitutional instrument from memory is exactly the error this site exists to avoid. Read the regulations on ADGM's legal framework site before you rely on the difference.

ADGM courts litigation and the DIFC Courts

Each zone runs its own courts, with their own procedural rules, published in the same legal frameworks. ADGM's courts legislation, courts regulations, courts rules and courts procedures are all indexed alongside its commercial legislation. DIFC Courts publish separately at difccourts.ae. Both zones also have their own arbitration regulations.

What this means for the choice

If your counterparties are used to English law drafting, both zones will feel familiar, and the difference is a matter for your litigators rather than your finance director.
If enforcement matters most, the question is where a judgment will actually be enforced, which is about treaties and assets, not about which zone issued the licence.
If nothing is contentious yet, this factor is usually less decisive than premises, regulator relationship and where your clients sit.

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Questions, answered directly

Is ADGM a free zone?

Yes, a financial free zone. ADGM states on its own legal framework that it was established in accordance with Federal Decree No. (15) of 2013 on the establishment of a financial free zone in the Emirate of Abu Dhabi.

Do DIFC and ADGM have separate courts?

Yes. Each zone publishes its own courts legislation, regulations, rules and procedures, and each has its own arbitration framework. They are separate court systems, not branches of one.

Sources

This site's own datasets, every figure quoted from its source and dated:

The Centre Firm Register carries 3 published figures read from 3 sources' own pages, from 10,018 to 13,353 count, read 11 November 2026.
The Freezone Registry Fee Schedule carries 14 published figures read from 6 sources' own pages, from 100 to 16,700 USD, read 7 November 2026.
The Regulator Authorisation Tariff carries 41 published figures read from 9 sources' own pages; the 39 published figures given by category run from 0 to 10,000,000 USD, read 7 November 2026.
For ADGM, the median published figure in the Setup Provider Pricing is 7,800 USD across 3 figures from the sources' own pages (range 1,400 to 8,000 USD), read 11 November 2026.

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