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In July 2024, the Abu Dhabi Global Market (ADGM) introduced a comprehensive whistleblowing framework through its Whistleblower Protection Regulations 2024 (the Regulations), alongside amendments to the Employment Regulations 2019.
The Regulations came into force on 5 July 2024, with a compliance deadline of 31 May 2025 for all relevant ADGM entities. Supplementary guidance was published in July 2025 to support ongoing implementation. The ADGM framework is currently the broadest whistleblowing regime in the UAE, applying not just to financial services firms but to all entities registered or licensed to operate within the ADGM.
Background and Purpose
The ADGM is Abu Dhabi’s international financial centre and one of the UAE’s two major financial freezones, alongside the Dubai International Financial Centre (DIFC). Following the DIFC’s introduction of its own whistleblowing regime in 2022, the ADGM consulted on its proposals from early 2024 before enacting the Regulations in July of that year.
The Regulations form part of the UAE’s broader strategy to combat financial crime and strengthen its compliance with international standards, including those set by the Financial Action Task Force (FATF). The FATF is scheduled to conduct a mutual evaluation of the UAE in June 2026, and the ADGM’s framework is expected to be recognised as material evidence of the country’s commitment to tackling financial crime and improving transparency.
Scope: Who Does It Apply To?
The Regulations apply to all Global Market Establishments (GMEs) – that is, entities registered or licensed to operate or conduct any activity within the ADGM. This is notably broader than the DIFC regime, which applies only to entities regulated by the Dubai Financial Services Authority (DFSA).
The obligations placed on entities are proportionate to their size and complexity. Enhanced requirements apply to entities classified as Large Establishments (those with a turnover or assets under control or administration exceeding USD 13 million and more than 35 employees) and to Designated Non-Financial Businesses and Professions (DNFBPs), such as real estate agents. For simpler entities such as special purpose vehicles (SPVs) with no employees, a proportionate approach is permitted – for example, the board secretary providing a briefing to the board on the Regulations may suffice.
What Constitutes a Protected Disclosure?
Only disclosures that meet the definition of a Protected Disclosure under the Regulations attract the full protections available. A Protected Disclosure must be:
- based on the discloser’s knowledge or reasonable suspicion
- that a contravention of ADGM rules or regulations, or money laundering, fraud, or another financial crime, has occurred
- made in good faith – meaning honestly, properly, and generally in the public interest rather than solely for personal gain
- made through an internal or external reporting channel
The ADGM Guidance notes that the reasonable suspicion test does not require reasonable belief – grounds to suspect are sufficient, which is a relatively accessible threshold. Anonymous disclosures are permitted, though the Guidance cautions that anonymity can sometimes limit the effectiveness of any subsequent investigation.
The Regulations are explicitly not intended to cover general employee grievances or customer complaints, nor are they designed to protect disclosures relating to conduct outside the ADGM’s jurisdiction – in such cases, jurisdictional and conflict of laws issues may limit the protections available.
The Guidance also makes clear that deliberate false disclosures are not protected, and that disciplinary action against employees making such reports may be appropriate.
Protections Offered to Whistleblowers
A person making a Protected Disclosure is protected from retaliation. Specifically, they must not:
- face civil or contractual liability arising from the Protected Disclosure
- be dismissed or subjected to adverse employment actions by their employer or affiliated parties
Retaliation is interpreted broadly and can include withholding of promotion, changes to working hours, or any other form of detriment or disadvantage. Where retaliation occurs, a whistleblower may seek relief through the ADGM Courts.
Obligations on ADGM Entities
As of 31 May 2025, all relevant ADGM entities must have implemented and be maintaining appropriate and effective arrangements to:
- facilitate disclosures from officers and employees
- assess and escalate concerns appropriately
- protect the confidentiality of those who report
- prevent retaliation against whistleblowers
- log all disclosures and investigate them thoroughly and impartially
- retain all disclosure records, supporting documents, and related analyses for a minimum of six years after the matter has closed
For Large Establishments and DNFBPs, these arrangements must be reflected in written policies. All entities must communicate their arrangements clearly and in an accessible format to officers and employees, and must review them regularly for ongoing appropriateness.
The ADGM Guidance stresses that a whistleblowing programme is only effective if the entity has a culture that genuinely supports speaking up. Entities are encouraged to demonstrate a clear tone from the top, and to consider training, communication, and easy access to reporting channels as part of their overall approach.
Sanctions for Non-Compliance
The ADGM Registrar has explicit powers to impose sanctions on entities that contravene the Regulations. These include:
- private or public censure
- financial penalties
- suspension or withdrawal of the entity’s commercial licence
The Financial Services Regulatory Authority (FSRA) and the ADGM Registrar have both indicated that they will be monitoring compliance carefully. With the May 2025 deadline now passed, entities that have not yet implemented appropriate arrangements face a real enforcement risk.
No Financial Rewards
Unlike the United States, where whistleblowers may be eligible for financial rewards or a share in recovered assets, the ADGM regime – in common with the DIFC – does not currently offer monetary incentives for disclosures. The focus of the framework is on protection from retaliation and the safeguarding of confidentiality, rather than financial reward.
How Does the ADGM Regime Compare to the DIFC?
While the ADGM and DIFC regimes share many features, the ADGM framework is broader in scope and is supported by considerably more detailed published guidance. The key differences are as follows:
- Scope: the DIFC regime applies to DFSA-regulated entities only; the ADGM regime applies to all ADGM-registered entities, with enhanced duties for certain sectors
- Good faith: the DIFC defines this as acting honestly rather than dishonestly or maliciously; the ADGM defines it as acting honestly, properly, and in the public interest rather than solely for personal gain
- Record-keeping: the ADGM explicitly requires records to be retained for at least six years; the DIFC does not specify a retention period in its whistleblower protection provisions
- Sanctions: the ADGM explicitly sets out sanctions in both the Regulations and the Guidance; the DIFC’s sanctions are implied under the wider sanctions provisions of the Regulatory Law rather than specified in the whistleblowing provisions directly
Conclusion
The ADGM Whistleblower Protection Regulations 2024 represent the most comprehensive whistleblowing framework yet introduced in the UAE. They signal a clear direction of travel – towards greater alignment with international standards and a genuine expectation that organisations operating in Abu Dhabi’s financial centre will embed a culture of transparency and accountability. For entities within the ADGM, compliance is no longer optional, and the Registrar has made clear that it intends to monitor and enforce accordingly.
Our Recommendation
The ADGM Guidance is explicit that a whistleblowing programme only works if the culture supports it – and culture starts with infrastructure. An independently operated reporting channel is one of the most effective signals an organisation can send to its people that disclosures will be taken seriously, handled confidentially, and acted upon without fear of reprisal. For entities approaching compliance for the first time, or those reviewing arrangements put in place ahead of the May 2025 deadline, an external provider also removes the inherent conflict of interest that can arise when reports are managed internally. Given that the FSRA and ADGM Registrar are actively monitoring compliance, now is the right time to ensure your arrangements are not just in place, but genuinely effective.
How Safecall Can Help with ADGM Compliance
Safecall provides anonymous reporting channels – including dedicated telephone hotlines and secure online portals – that enable employees and officers of ADGM entities to raise concerns without fear of retaliation. Our call handlers have 25 or more years of interview experience each, and our service operates 24 hours a day, 7 days a week, 365 days a year, across more than 150 countries and in over 175 languages and dialects.
Our case management platform provides the comprehensive, auditable disclosure records that the ADGM Regulations require entities to maintain for a minimum of six years. All data is held securely in the UK and our systems are fully GDPR compliant. Safecall can help your organisation meet both the letter and the spirit of the ADGM framework – providing the independent, confidential reporting infrastructure that supports genuine speak-up culture.
References
[1] ADGM Whistleblower Protection Regulations 2024: https://adgmen.thomsonreuters.com/sites/default/files/net_file_store/ADGM1547_26684_VER01071024.pdf
[2] ADGM Supplementary Guidance on Whistleblowing (July 2025): https://assets.adgm.com/download/assets/ADGM+Supplementary+Guidance+on+Whistleblowing+July+2025.pdf/d7b5cf686ead11ef9e10d26497c121fb
[3] Herbert Smith Freehills Kramer, Updates to UAE Whistleblowing Protections (October 2025): https://www.hsfkramer.com/notes/middle-east/2025-posts/updates-to-uae-whistleblowing-protections
[4] Clyde & Co, Beyond the Deadline: Embedding Whistleblower Protections in ADGM Companies (July 2025): https://www.clydeco.com/en/insights/2025/07/whistleblower-protections-in-adgm-companies
[5] Hogan Lovells, Whistle While You Work: Are You Ready for the ADGM’s New Protection Regulations? (February 2025): https://www.hoganlovells.com/en/publications/whistle-while-you-work-are-you-ready-for-the-adgm-s-new-protection-regulations
[6] Global Investigations & Compliance Review, Time is of the Essence to Implement New ADGM Whistleblower Protection Regulations (January 2025): https://www.globalinvestigations.blog/whistleblowing/time-is-of-the-essence-to-implement-new-adgm-whistleblower-protection-regulations/
[7] A&O Shearman, Whistleblowing: Ensure Programs Are Fit for 2026 (March 2026): https://www.aoshearman.com/en/insights/cross-border-white-collar-crime-and-investigations-review-2026/whistleblowing-ensure-programs-are-fit-for-2026
The summaries provided on this website are designed for information and initial guidance only. Always seek additional specific advice from an appropriate legal specialist before making decisions based on whistleblowing legislation. Safecall can provide recommendations for appropriate legal specialists if required. Please ask for more details.