UAE UAE AI strategy regulation ADGM

ADGM's Licence-First Crypto Mining Guidance Is a Credible Template for Governing Energy-Hungry Compute

Abu Dhabi's financial centre treats mining as a licensable commercial activity, not a financial service, a proportionate model the UAE's AI rules could borrow.

ADGM Crypto Mining Guidance at a Glance People of Internet Research · UAE 8 weeks Consultation length Public consultation preceded the f… 3 Bodies merged into AI authority AI Office, TDRA digital government… Jan 2022 UAE data law in force Federal Decree Law 45 of 2021 took… peopleofinternet.com
ADGM Crypto Mining Guidance at a Glanc… People of Internet Research · UAE 8 weeks Consultation length 3 Bodies merged into AI authority Jan 2022 UAE data law in force peopleofinternet.com

Key Takeaways

On 28 October 2026, the Abu Dhabi Global Market (ADGM) Registration Authority published its Guidance on Crypto Mining Activities in and from ADGM. According to The National's report, it is the first such guidance from a financial centre in the region. This is not an AI measure, and we have found no ADGM AI-specific rulebook issued recently. But mining is compute-heavy, energy-intensive activity, which is the same category of problem AI data centres pose. ADGM's approach is therefore a useful test of how the UAE regulates that category.

What ADGM actually did

The Authority classifies mining as a licensable commercial activity overseen by the Registration Authority, not as a regulated financial service. The guidance is technology-neutral and covers both proof-of-work and proof-of-stake. It follows an eight-week consultation earlier in 2026, which The National says produced 'substantive feedback'. The consultation was run as an ADGM discussion paper on crypto mining activities.

Registration Authority CEO Rashed Al Blooshi framed it as giving operators 'a clear commercial licencing pathway, proportionate supervision calibrated to scale and risk, and certainty on where the regulatory perimeter resides', as quoted by The National. The Authority calls this the first phase. A second phase will develop mining regulations, with market consultation 'in due course'.

The design is visible in the February commentary on the proposal by Clyde & Co. That commentary says mining needs no authorisation from the Financial Services Regulatory Authority, only a Registration Authority commercial licence. Small-scale, non-commercial activity by individuals is generally out of scope. Operators must keep ownership and governance records current. Supervision can include periodic reporting, third-party audits and on-site inspections, with enforcement ranging from warnings to licence revocation. Note that this describes the consultation draft. We could not read ADGM's final text, so details may differ.

The strongest case for tighter rules

The sceptic's argument deserves a fair statement. Mining is energy-intensive, can be run anonymously through opaque corporate structures, and sits close to financial-crime risk. A regulator that waits for a second-phase rulebook may leave a gap in which operators set up first and face binding obligations later. Critics of 'guidance first, regulation later' sequencing also note that guidance can be changed or withdrawn more easily than a rule. That gives operators less durable certainty than a statute would.

Those concerns are real, but the ADGM design answers more of them than it appears to. The licence is the binding step: no licence, no mining entity in ADGM. The transparency and inspection powers described in the draft attach to that licence. The perimeter question, meaning who counts as a financial service and who does not, is the very thing the guidance settles. Putting mining under the commercial regime also avoids the common error of forcing a physical, power-consuming business into rules built for custodians and exchanges.

Why proportionality is the right instinct

Three features stand out as sound policy.

The approach also respects a principle that matters for the open internet. Permissionless protocols are better governed by regulating the commercial entities that touch the real world, such as operators, premises and power contracts. Regulating the code itself is a poor target.

Read-across to the UAE's AI posture

The UAE's wider approach to AI is also principles-based. On 14 June 2026, according to Morgan Lewis, Sheikh Mohammed bin Rashid Al Maktoum announced the Federal Authority for Artificial Intelligence and Data, reporting directly to the Cabinet. It absorbs the UAE Artificial Intelligence Office, the Information and Digital Government Sector within the Telecommunications and Digital Government Regulatory Authority, and the previously announced Emirates Data Office. Its mandate includes setting unified AI and data policy and proposing legislation.

What it has not yet produced is binding private-sector AI rules. We found no enacted standalone federal AI statute. Morgan Lewis notes open questions, including that the implementing regulations for the personal data law have still not been issued. That law, Federal Decree Law No. 45 of 2021 on personal data protection, came into force on 2 January 2022. AI is currently governed through existing general frameworks, not a dedicated regime.

That is where the ADGM template becomes relevant. AI compute, like mining, is power-hungry, capital-intensive and mobile across jurisdictions. A federal framework that adopted the same sequence would be easy to defend. It would start with a clear licence or registration pathway, define the perimeter against financial and data-protection rules, calibrate supervision to scale and risk, and consult before binding rules arrive. The alternative, a broad horizontal AI statute written ahead of the evidence, risks the over-inclusive rules that have burdened startups elsewhere.

What to watch

Proportionality is a promise, and it will be tested in the second phase. Three questions will decide whether ADGM's model deserves the praise.

For now, ADGM has done the useful thing: it has told operators where they stand and what is expected, and it has committed to hearing from them again. That is a better foundation for investment than either a regulatory vacuum or a premature rulebook.

Sources & Citations

  1. UAE Government Portal: Data protection laws (Federal Decree Law 45 of 2021)
  2. ADGM Discussion Paper No. 1 of 2026 on Crypto Mining Activities
  3. The National: ADGM guidance on crypto mining
  4. Morgan Lewis: UAE establishes federal authority for AI and data
  5. Clyde & Co: Crypto mining in ADGM proposed guidance