Sep 3, 2026
Key takeaways
Across jurisdictions, regulators are increasingly looking at oversight and compliance as enablers of growth, rather than a block to innovation. This is no different in the DIFC and ADGM. To support the continued growth of the markets, the Dubai Financial Services Authority (DFSA) and the ADGM's Financial Services Regulatory Authority (FSRA) are refreshing their regulatory approach to maintain the integrity of the regime while increasing flexibility for market participants seeking a DIFC and/or ADGM presence.
With respect to the DIFC in particular, this was reinforced in the DFSA's annual report published in June. Managing Director of Supervision, Justin Baldacchino, highlights that 'strong and sustainable growth depends on maintaining high standards of governance, risk management and oversight as firms expand’. Recent supervisory activity further demonstrates this approach in practice. Across 2025, the DFSA expanded its programme of thematic reviews, examining a range of areas including fund management self-custody structures and governance arrangements in high-growth businesses. The regulator also continues to conduct more AML risk assessments and enhance its engagement with newly authorised firms to ensure the compliance and board supervision frameworks are robust from the outset.
Similarly, the ADGM continues to evolve its regulatory framework to attract innovative businesses and investment structures while maintaining a strong focus on governance and accountability. As greater flexibility is introduced for market participants, boards are expected to demonstrate that decision-making, oversight and risk management arrangements remain fit for purpose.
While governance frameworks may appear straightforward on paper, demonstrating effective oversight in practice often depends on one critical factor: a board's ability to show how decisions are reached, how risks are assessed and how actions are followed through.
Some of the most common governance challenges include board packs being distributed too close to meeting dates to allow for meaningful review, minutes that do not adequately capture the rationale behind decisions or evidence board challenge, and inadequate tracking of actions between meetings.
A board may agree on actions, but without clear documentation or a follow-up mechanism, it can be difficult to show that oversight or risk analysis continued beyond a meeting agenda point. When responsibilities become blurred between the board, service providers, investment managers, administrators and other stakeholders, accountability can weaken and gaps in oversight can emerge.
As an entity grows, so do expectations. Expansion into new markets and new rounds of investment come with increased regulatory scrutiny that often places greater demands on governance frameworks. Processes that once worked well can quickly become obstacles if they fail to keep pace with the business.
Boards that invest in effective record-keeping and scalable governance processes are better positioned to respond to stakeholder expectations and seize new opportunities with confidence.
As expectations continue to evolve, boards need the right support to stay organised, informed and focused on what matters most. Building on our established CSP offering in the DIFC and ADGM, our Board Support Services team helps boards run more effectively and demonstrate good governance in practice. Combining governance expertise with practical administrative support, we help boards strengthen accountability, maintain accurate records and enhance outcomes.
Our services include:
By taking care of the administrative and oversight processes, we help boards spend less time on logistics and more time on strategic decision-making and long-term value creation.
If you would like to discuss how our Board Support Services team can support your DIFC or ADGM entity, please get in touch.
Director, WPS Middle East/British Virgin Islands/Dubai
KEY CONTACTS
Director, WPS Middle East
British Virgin Islands
Dubai
Company Secretary
Dubai
