Finjuris advises on structuring and forming an ADGM foundation whether under the jurisdiction's general Foundations Regulations or its dedicated DLT Foundations Regulations for DAOs seeking an onshore Middle East presence within a respected common-law framework. Abu Dhabi Global Market (ADGM) was the first jurisdiction globally to introduce a foundation regime specifically designed for distributed ledger technology projects and DAOs.
ADGMSpeak to our Web3 legal team
Discuss whether an ADGM foundation fits your DAO's governance model and UAE ambitions. Receive a tailored formation and FSRA-positioning roadmap.
A Dedicated Regime for DAOs and Blockchain Foundations
ADGM's Registration Authority released the Distributed Ledger Technology (DLT) Foundations Regulations in November 2023, following a 2023 consultation, creating what ADGM describes as the world's first foundations regime built specifically for blockchain foundations and DAOs, which have long been used for conventional philanthropic and succession-planning structures. A foundation is registered by submitting a charter to the Registrar, together with a declaration of compliance and the relevant registration fee, and is governed thereafter by a Council, which manages the foundation's assets and income in accordance with the charter, with an optional Guardian able to provide additional oversight.
Why DAOs Choose ADGM
The first purpose-built DLT foundations regime globally, recognising decentralised governance and allowing token holders to participate without requiring physical presence in the UAE.
A common-law jurisdiction with its own courts, operating within the UAE but under an independent legal and regulatory framework familiar to international counsel and investors.
Strong onshore UAE banking and institutional relationships, supporting fiat banking and investor engagement more readily than several offshore alternatives.
Tax neutrality — no income tax, capital gains tax, or inheritance tax currently applies to ADGM foundations.
A clear pathway toward regulated activity through ADGM's Financial Services Regulatory Authority (FSRA) if the DAO's activities later require licensing.
ADGM Foundation at a Glance
| Feature | Position |
|---|---|
| Governing legislation | ADGM Foundations Regulations / DLT Foundations Regulations 2023 |
| Registrar | ADGM Registration Authority (RA) |
| Financial regulator | ADGM Financial Services Regulatory Authority (FSRA), for regulated activity |
| Core roles | Founder, Council (governing body), optional Guardian |
| Members / beneficiaries | Not required — foundation owns its own assets as a separate legal entity |
| Registered office | Required within ADGM, which may be shared with the foundation's Company Service Provider |
| Formation route | Applications must be submitted through an ADGM-registered Company Service Provider (CSP) |
| Taxation | No income tax, capital gains tax, or inheritance tax currently applies |
Ideal Use Cases
DAOs and protocol foundations wanting an onshore Middle East operational base.
Projects seeking proximity to UAE banking, institutional investors, and government-linked ecosystem initiatives.
Teams anticipating an eventual move into regulated activity through ADGM's FSRA.
DAOs and blockchain foundations wanting recognition of decentralised governance without requiring the community's physical presence in the UAE.
Practical Considerations and Limitations
Formation and substance requirements, including a registered office and engagement of an ADGM-registered Company Service Provider, are generally higher than for several purely offshore jurisdictions.
Foundation Council composition, reporting, and the Registrar's powers to review accounts and impose fines for non-compliance need to be built into the foundation's governance from the outset.
The regime is best suited to projects with a genuine UAE nexus — DAOs with no Middle East connection may find other jurisdictions more cost-efficient.
A foundation is not itself an FSRA licence. DAOs carrying on regulated financial activity in or from ADGM will need to obtain the relevant FSRA authorisation separately.
How Finjuris Helps
Assessing whether an ADGM foundation is the right wrapper for your DAO relative to the other jurisdictions we advise on.
Drafting the foundation's charter to reflect your on-chain governance, Council composition, and treasury-deployment process.
Coordinating with ADGM-registered Company Service Providers on registration and registered office requirements.
Advising on the pathway toward FSRA licensing where your DAO's activities extend into regulated territory.
Advising on the respective roles of the Founder, Council, and any Guardian in your foundation's governance structure.
Frequently Asked Questions
Straightforward answers to the questions ask us most often before structuring a DAO.
Structure Your DAO with an ADGM Foundation
If an onshore Middle East presence within a common-law framework fits your DAO's objectives, Finjuris will assess the fit and manage the charter drafting and registration process alongside an ADGM-registered Company Service Provider.
Book a consultation with Finjuris
Discuss your DAO's governance model and UAE ambitions with our Web3 legal team. Receive a tailored recommendation on structure, drafting, and formation timeline.
This page is provided for general informational purposes and does not constitute legal advice. Whether this structure is appropriate for a given DAO depends on its specific governance model, activities, and regulatory exposure, and should be assessed with qualified legal counsel before implementation.
