🇦🇪 ADGM (Abu Dhabi) vs 🇧🇭 Bahrain: crypto licensing compared
On paper, ADGM (Abu Dhabi)'s Financial Services Permission (FSP) from the FSRA to carry on one or more 'Regulated Activities' in relation to Virtual Assets under the ADGM Financial Services and Markets Regulations (FSMR), e.g. Operating a Multilateral Trading Facility (exchange), Providing Custody, Dealing in Investments as Principal/Agent (broker-dealer), Managing Assets, or Advising on Investments, each 'in relation to Virtual Assets.' The framework was originally branded 'Operating a Crypto Asset Business' (2018 Guidance) and has since been folded into the broader Virtual Asset regulated-activities regime under the 'Guidance – Regulation of Virtual Asset Activities in ADGM' (most recent version 10 June 2025). A related but separate activity/licence covers issuing Fiat-Referenced Tokens (FRTs, i.e. stablecoins). and Bahrain's Crypto-Asset Service Licence under CBB Rulebook Volume 6 (Capital Markets), Crypto-Asset Module (CRA), issued under Decree Law No. 64 of 2006 (CBB Law). Four categories: Category 1 (reception/transmission of orders, investment advice), Category 2 (Cat-1 activities plus trading as agent, portfolio management, custody), Category 3 (Cat-2 activities plus trading as principal/dealing on own account), Category 4 (operating a licensed crypto-asset exchange plus custody). A separate Stablecoin Issuance and Offering (SIO) Module (also Volume 6) now licenses stablecoin issuers. answer the same question; in practice the detail decides it. The two regimes differ on 7 of 9 tracked decision dimensions, including capital requirement and timeline to authorisation. This page compares the two side by side: the identity columns are free, the decision figures are one pass away, and every cell shows when it was last checked.
ADGM (Abu Dhabi): verified 2026-07-03 · Bahrain: verified 2026-07-02
| Dimension |
🇦🇪 ADGM (Abu Dhabi)
partly open
Verified 2026-07-03
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🇧🇭 Bahrain
partly open
Verified 2026-07-02
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|---|---|---|
| Licence type | Financial Services Permission (FSP) from the FSRA to carry on one or more 'Regulated Activities' in relation to Virtual Assets under the ADGM Financial Services and Markets Regulations (FSMR), e.g. Operating a Multilateral Trading Facility (exchange), Providing Custody, Dealing in Investments as Principal/Agent (broker-dealer), Managing Assets, or Advising on Investments, each 'in relation to Virtual Assets.' The framework was originally branded 'Operating a Crypto Asset Business' (2018 Guidance) and has since been folded into the broader Virtual Asset regulated-activities regime under the 'Guidance – Regulation of Virtual Asset Activities in ADGM' (most recent version 10 June 2025). A related but separate activity/licence covers issuing Fiat-Referenced Tokens (FRTs, i.e. stablecoins). | Crypto-Asset Service Licence under CBB Rulebook Volume 6 (Capital Markets), Crypto-Asset Module (CRA), issued under Decree Law No. 64 of 2006 (CBB Law). Four categories: Category 1 (reception/transmission of orders, investment advice), Category 2 (Cat-1 activities plus trading as agent, portfolio management, custody), Category 3 (Cat-2 activities plus trading as principal/dealing on own account), Category 4 (operating a licensed crypto-asset exchange plus custody). A separate Stablecoin Issuance and Offering (SIO) Module (also Volume 6) now licenses stablecoin issuers. |
| Regulator | Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM) | Central Bank of Bahrain (CBB) |
| Capital requirement | ADGM (Abu Dhabi) capital requirement is locked. Unlock with the £349 pass. | Bahrain capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | ADGM (Abu Dhabi) timeline to authorisation is locked. Unlock with the £349 pass. | Bahrain timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | ADGM (Abu Dhabi) local substance is locked. Unlock with the £349 pass. | Bahrain local substance is locked. Unlock with the £349 pass. |
| Application cost | ADGM (Abu Dhabi) application cost is locked. Unlock with the £349 pass. | Bahrain application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | ADGM (Abu Dhabi) ongoing cost is locked. Unlock with the £349 pass. | Bahrain ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | ADGM (Abu Dhabi) passporting is locked. Unlock with the £349 pass. | Bahrain passporting is locked. Unlock with the £349 pass. |
| MiCA CASPs approved | ADGM (Abu Dhabi) mica casps approved is locked. Unlock with the £349 pass. | Bahrain mica casps approved is locked. Unlock with the £349 pass. |
| Key restrictions | ADGM (Abu Dhabi) key restrictions is locked. Unlock with the £349 pass. | Bahrain key restrictions is locked. Unlock with the £349 pass. |
| Recent changes | June 10, 2025: FSRA implemented major amendments, shifted from FSRA pre-approval for Virtual Assets to a notification-based process built on applicant self-assessment; introduced express prohibition on privacy tokens and algorithmic stablecoins; revised capital requirements and fees for VA firms; added product-intervention power for virtual assets. September 2025 (Abu Dhabi Finance Week): FSRA published Consultation Paper No. 10 of 2025 proposing a staking framework. Finalised Fiat-Referenced Token (FRT) framework followed, with FEES Rulebook amendments effective 1 January 2026 (published 31 October 2025). April 29, 2026: FSRA finalised the Virtual Asset staking regulatory framework after consultation. December 2025/January 2026: Binance received FSRA approval (announced 7 December 2025) to operate its global Binance.com platform in ADGM via three regulated entities, described as the first global platform-level licence of this kind under the ADGM framework, operations beginning 5 January 2026. | CONFIRMED: In July 2025 the CBB issued a new Stablecoin Issuance and Offering (SIO) Module, added to Rulebook Volume 6, creating Bahrain's first dedicated stablecoin licensing framework. It covers issuance, minting, burning, and reserve management of single-currency stablecoins backed by BHD, USD, or other CBB-accepted fiat currencies; requires issuers to incorporate as a Bahraini B.S.C.; mandates perpetual redemption rights for holders; and explicitly permits yield-bearing stablecoins (subject to CBB-set limits), a more permissive stance than many other jurisdictions. This confirms the '2025 stablecoin module' claim. Separately, CBB granted a new Category 3 crypto-asset licence to Fasset Financial Services W.L.L. in January 2025. |
| Difficulty rating | ADGM (Abu Dhabi) difficulty rating is locked. Unlock with the £349 pass. | Bahrain difficulty rating is locked. Unlock with the £349 pass. |
The two regimes differ on 7 of 9 tracked decision dimensions, including capital requirement and timeline to authorisation. Unlock the pass to see each figure with its source and verification date.
What changed recently
🇦🇪 ADGM (Abu Dhabi) (verified 2026-07-03): June 10, 2025: FSRA implemented major amendments, shifted from FSRA pre-approval for Virtual Assets to a notification-based process built on applicant self-assessment; introduced express prohibition on privacy tokens and algorithmic stablecoins; revised capital requirements and fees for VA firms; added product-intervention power for virtual assets. September 2025 (Abu Dhabi Finance Week): FSRA published Consultation Paper No. 10 of 2025 proposing a staking framework. Finalised Fiat-Referenced Token (FRT) framework followed, with FEES Rulebook amendments effective 1 January 2026 (published 31 October 2025). April 29, 2026: FSRA finalised the Virtual Asset staking regulatory framework after consultation. December 2025/January 2026: Binance received FSRA approval (announced 7 December 2025) to operate its global Binance.com platform in ADGM via three regulated entities, described as the first global platform-level licence of this kind under the ADGM framework, operations beginning 5 January 2026.
🇧🇭 Bahrain (verified 2026-07-02): CONFIRMED: In July 2025 the CBB issued a new Stablecoin Issuance and Offering (SIO) Module, added to Rulebook Volume 6, creating Bahrain's first dedicated stablecoin licensing framework. It covers issuance, minting, burning, and reserve management of single-currency stablecoins backed by BHD, USD, or other CBB-accepted fiat currencies; requires issuers to incorporate as a Bahraini B.S.C.; mandates perpetual redemption rights for holders; and explicitly permits yield-bearing stablecoins (subject to CBB-set limits), a more permissive stance than many other jurisdictions. This confirms the '2025 stablecoin module' claim. Separately, CBB granted a new Category 3 crypto-asset licence to Fasset Financial Services W.L.L. in January 2025.
Quick answers
Who regulates crypto licensing in ADGM (Abu Dhabi) and Bahrain?
ADGM (Abu Dhabi): Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM). Bahrain: Central Bank of Bahrain (CBB).
What licence do you need in ADGM (Abu Dhabi) compared with Bahrain?
In ADGM (Abu Dhabi) the authorisation route is Financial Services Permission (FSP) from the FSRA to carry on one or more 'Regulated Activities' in relation to Virtual Assets under the ADGM Financial Services and Markets Regulations (FSMR), e.g. Operating a Multilateral Trading Facility (exchange), Providing Custody, Dealing in Investments as Principal/Agent (broker-dealer), Managing Assets, or Advising on Investments, each 'in relation to Virtual Assets.' The framework was originally branded 'Operating a Crypto Asset Business' (2018 Guidance) and has since been folded into the broader Virtual Asset regulated-activities regime under the 'Guidance – Regulation of Virtual Asset Activities in ADGM' (most recent version 10 June 2025). A related but separate activity/licence covers issuing Fiat-Referenced Tokens (FRTs, i.e. stablecoins).; in Bahrain it is Crypto-Asset Service Licence under CBB Rulebook Volume 6 (Capital Markets), Crypto-Asset Module (CRA), issued under Decree Law No. 64 of 2006 (CBB Law). Four categories: Category 1 (reception/transmission of orders, investment advice), Category 2 (Cat-1 activities plus trading as agent, portfolio management, custody), Category 3 (Cat-2 activities plus trading as principal/dealing on own account), Category 4 (operating a licensed crypto-asset exchange plus custody). A separate Stablecoin Issuance and Offering (SIO) Module (also Volume 6) now licenses stablecoin issuers.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full ADGM (Abu Dhabi) vs Bahrain comparison?
The interactive benchmark lets you pin either jurisdiction and add up to five peers; a Founder Pass or Pro subscription unlocks every gated figure with its source and verification date. This page stays free at /crypto/compare/adgm-abu-dhabi-vs-bahrain.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.