The confusion that comes up most often is between an auditor's base registration and the Additional Permits required for public interest entities and Financial Institutions, and between the ADGM filing deadline and the UAE Corporate Tax return that often lands on the same date. This guide covers how to verify an ADGM auditor today, how the framework evolved from Recognised to Registered Auditors, and what an ADGM Qualifying Free Zone Person specifically needs to check under Ministerial Decision No. 84 of 2025.
ADGM Audit and Corporate Tax Requirements
| Topic | Key Data | Source |
|---|---|---|
| Who regulates | ADGM Registration Authority (RA) | ADGM |
| Current framework | Companies Regulations (Auditors) Rules 2025(A), effective 28 October 2025 | ADGM RA |
| Base registration vs Additional Permits | Base registration covers standard entities; a Public Audit Permit or FI Audit Permit is required for public interest entities and Financial Institutions | ADGM RA |
| Where to verify | ADGM Public Register (adgm.com, "Find an Auditor") | ADGM official |
| CT connection | ADGM Registered Auditors are confirmed eligible to audit Taxable Persons for UAE Corporate Tax purposes | ADGM RA, 11 Nov 2024 |
| QFZP audit requirement | QFZPs must maintain audited financial statements regardless of revenue | Ministerial Decision No. 84 of 2025, Article 2(1) |
| Filing deadline | 9 months from Accounting Reference Date (RA) and 9 months from tax period end (FTA), often the same date | ADGM RA / FTA |
On This Page
What an ADGM Registered Auditor Is (and Why No Static List Is Reliable)
An ADGM Registered Auditor is a firm the ADGM Registration Authority has approved to sign statutory audits for companies incorporated in ADGM. No other credential substitutes for it.
The RA keeps this as a live public register, not a fixed document. Firms are added, removed, and have permits attached or withdrawn as their circumstances change. A PDF list, a blog post, or a directory that was accurate six months ago can be wrong today.
- Firms move on and off the register as registrations lapse, get suspended, or are newly approved.
- Additional Permits change independently of base registration, so a firm’s scope of eligible work can shift without its base status changing.
- Regulatory action can affect status mid-year, which a static source has no way to reflect.
Under ADGM’s Companies Regulations 2020, any company subject to a statutory audit must engage an ADGM Registered Auditor, regardless of the purpose the audit serves. That applies whether the audit is triggered by the small companies regime falling away, a lender’s requirement, or a UAE Corporate Tax obligation.
From Recognised to Registered: How the ADGM Auditor Framework Evolved (2021 → 2025)
ADGM’s current auditor framework traces back to a single reform, then two further rewrites in four years.
The ADGM Board approved the Auditors’ Framework on 25 August 2021. It came into force on 1 December 2021, replacing the earlier Recognised Auditors regime with Registered Auditors and giving the RA stronger oversight powers. The Companies Regulations (Auditors) Rules 2023 followed, then the Companies Regulations (Auditors) Rules 2025 on 7 January 2025. On 28 October 2025, ADGM introduced the Companies Regulations (Auditors) Rules 2025(A), which repealed the January 2025 Rules and is the operative framework today.
Each rewrite tightened registration criteria for firms and individual Audit Principals. Each also extended the RA’s electronic register to show Additional Permits held, and aligned ADGM’s audit oversight more closely with international standards. If you engaged your auditor several years ago and never revisited the appointment, the framework that governed that engagement is not the one governing it now.
From the Practice: Your ADGM Audit and Your Corporate Tax Return Are One Exercise, Not Two
I work with a number of Corporate Tax clients who are also ADGM-registered. The single most useful thing I tell them in my practice is this: they cannot produce two separate sets of financial statements for two separate audiences. IFRS, which both the ADGM RA and the FTA require for IFRS-compliant accounts, does not permit multiple sets of general purpose financial statements for the same entity.
That means the audited financial statements filed to the ADGM portal are the exact same statements the Corporate Tax return is built on. If a Qualifying Free Zone Person’s income isn’t clearly segregated between qualifying and non-qualifying in the accounts themselves, not just in the CT workings, both filings inherit the same problem.
In practice, I still see this treated as two parallel exercises: one person preparing the ADGM accounts, another preparing the CT return, with nobody checking the two are entirely consistent. That gap is where FTA cross-referencing catches inconsistencies the client didn’t know existed.
Registered Auditor vs Additional Permits: Which One Your Entity Needs
Base registration and Additional Permits are two different questions, and confusing them is the most common auditor-appointment mistake I see.
Base registration: what it covers
An ADGM RA Registered Auditor has met the eligibility criteria under the Companies Regulations (Auditors) Rules and appointed at least one Registered Audit Principal with a recognised professional qualification. That base registration is sufficient to audit standard, non-regulated ADGM entities: SPVs, holding companies, and most operating QFZPs.
Additional Permits: when they’re required
The RA’s Additional Permits sit on top of base registration and apply to public interest entities and Financial Institutions specifically. A Registered Auditor auditing one of these entity types must also hold the corresponding permit under the Rules.
I’ve seen the gap this creates play out directly. An entity engaged a reputable audit firm, went through a full audit, and received a signed report. The firm was ADGM Registered, but it did not hold the permit its client’s classification required. The RA rejected the submission, and the entire audit had to be redone with a properly permitted firm, costing time, cost, and a late filing risk that was entirely avoidable.
The pattern I see most often involves financial services entities specifically: asset managers, investment firms, payment service providers, and wealth management entities. These businesses often reappoint an auditor they’ve used for mainland work or another group entity, without checking whether that firm holds the specific permit their ADGM classification requires. From the client’s side, there is no visible signal anything is wrong. The audit report looks identical either way.
Before engaging an auditor, ask directly which permits they hold and confirm it against your entity’s classification, not just against the base Registered Auditor list.
How to Verify an ADGM Auditor Right Now
Verification takes minutes and should happen before you sign an engagement letter, not after.
- Open the RA’s live public register at adgm.com under “Find an Auditor,” not a search result or a firm’s own website claim.
- Search the firm name and confirm its registration status shows as active, not lapsed or suspended.
- Check the Additional Permits field against your entity’s classification if you hold any financial services activity or public interest status.
- Confirm at least one Registered Audit Principal is listed against the firm, since a firm cannot practise without one.
- Re-verify before every renewal, since registrations and permits change and a firm approved for last year’s audit may not hold the same status this year.
An honest note here: my own firm is not on the ADGM Registration Authority’s Registered Auditor list, and I don’t sign ADGM statutory audits. Where I add value for ADGM clients is coordinating their UAE Corporate Tax and VAT position in Abu Dhabi. I work alongside whichever ADGM-registered firm handles the statutory audit, not as a substitute for it.
If You're an ADGM QFZP: This Audit Also Decides Your Corporate Tax Position
For a Qualifying Free Zone Person, the ADGM audit is not a separate compliance box. It is the foundation the entire Corporate Tax position rests on.
The small company exemption no longer applies to QFZPs
ADGM’s Companies Regulations 2020 let small companies, those with turnover under USD 13.5 million and fewer than 35 employees, file an unaudited balance sheet instead of full audited accounts. Many ADGM entities relied on that for years to avoid audit costs.
Under Ministerial Decision No. 84 of 2025, any entity claiming QFZP status must maintain audited financial statements regardless of revenue, size, or what the small company regime would otherwise allow. The RA confirmed this directly: the Corporate Tax obligation overrides the small company exemption for QFZPs. A narrow no-action position applied only to the first CT period where the audit obligation arose solely from CT law, and that transitional window has closed for most entities now.
The dual deadline that catches businesses off guard
The ADGM RA filing deadline and the FTA Corporate Tax return deadline are both nine months from the relevant period end. For a December year-end, both land on 30 September. I treat the audit, the RA filing, and the CT return as a single integrated timeline for every ADGM QFZP client. Engaging an auditor in June or July for a December year-end leaves almost no margin if the fieldwork runs into complexity.
The businesses that manage this well start early and use one advisor who understands both frameworks. The ones that struggle treat the two filings as unrelated tasks that happen to share a deadline, and discover the conflict in August.
What Happens If You Don't Comply
The consequences run on two tracks that can both apply at once: the ADGM RA’s commercial penalties, and the FTA’s Corporate Tax consequences.
- Late or rejected RA filings can trigger fines against the company and its directors. A rejected submission, such as one signed by an unpermitted auditor, sends you back to square one on the audit itself.
- Losing QFZP status for failing to meet any condition, including the audited financial statements requirement, means the entity is taxed at 9% on its full income under Article 18(2) of the Corporate Tax Law. That rate applies for the tax period of the failure and the four subsequent periods, a five-year consequence, not a one-year correction.
- An audit signed by the wrong class of auditor is treated as if the audit requirement was not met at all. That puts both the RA filing and the QFZP position at risk at the same time.
If you’re comparing ADGM to other UAE financial free zones before setting up, the audit and compliance profile differs by jurisdiction. The comparisons of DIFC approved auditors and DMCC approved auditors walk through how each register works.
Ameer's Compliance Notes: ADGM Auditors
- Verify the permit, not just the registration. If your entity holds any financial services activity, confirm the specific Additional Permit against your classification before signing an engagement letter, not after the report is issued.
- Start the audit by June for a December year-end. I tell every QFZP client the same thing: the dual 30 September deadline leaves no room for a late start. Fieldwork needs enough runway for both filings.
- Build income segregation into the accounts, not just the CT workings. Qualifying and non-qualifying income needs to be visibly split in the financial statements themselves, or the FTA’s cross-referencing will flag it.
- Re-check your auditor’s status every renewal cycle. A firm properly registered and permitted last year is not guaranteed to hold the same status this year. The RA’s current register governs, not last year’s engagement letter.
- Treat the ADGM audit and the CT return as one project with one owner. In my experience, the cleanest outcomes come from a single advisor coordinating both, rather than two separate preparers who never compare notes.
If you’re an ADGM QFZP working through the overlap between your audit and your Corporate Tax filing, I offer a no-obligation review of how your ADGM accounts and Corporate Tax position line up, coordinated in Abu Dhabi alongside your ADGM-registered auditor. Get in touch to walk through your timeline before the September deadline.
This article is for general informational purposes and does not constitute professional tax advice. For guidance specific to your business structure, consult an ACCA-qualified tax advisor.
Not Sure Which Register Your Auditor Needs to Be On?
Frequently Asked Questions
Where can I find the official ADGM approved auditors list?
The only reliable source is the ADGM Registration Authority’s live public register, on adgm.com under “Find an Auditor.” Treat any PDF, directory, or blog list as a starting point for names, not a source of current status.
What's the difference between an ADGM Registered Auditor and a Recognised Auditor?
“Recognised Auditor” was the term used before ADGM’s Auditors’ Framework came into force on 1 December 2021. Since then, the correct and current term is “Registered Auditor,” governed today by the Companies Regulations (Auditors) Rules 2025(A).
Does my ADGM auditor need an Additional Permit?
Only if your entity is a public interest entity or a Financial Institution. Standard ADGM companies, including most QFZPs, are covered by an auditor’s base registration. Confirm your entity’s classification and check the permit against it before appointment.
What documents does ADGM typically require for the annual audit?
Requirements vary by entity, but audited financial statements, the board resolution approving the accounts, and supporting IFRS-compliant records are standard. Your registered auditor will confirm the exact document list for your entity type.
Does my ADGM audit affect my UAE Corporate Tax filing if I'm a QFZP?
What happens if I use an auditor who isn't ADGM-registered?
How does ADGM's audit framework compare to DIFC or DMCC?
About the Author
Ameer Hamza
Ameer Hamza (ACCA) is the Managing Partner at AH Chartered Accountants. With 7+ years of expertise advising over 50 UAE businesses, he specialises in statutory audits, corporate tax strategy, and corporate financial modelling.
Ameer authors our technical content to ensure business leaders receive precise, FTA-compliant guidance directly from an active industry expert.
Get to know Ameer Hamza and the team at AH Chartered Accountants on our About Us page.
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