Global Digital Finance (GDF) submitted a response to the Abu Dhabi Global Market (ADGM) Financial Services Regulatory Authority’s Discussion Paper No. 1 of 2026 on proposed guidance for crypto mining activities. The response broadly supports ADGM’s objective of establishing a risk-based, proportionate and transparent supervisory framework for commercial crypto mining activities conducted within or from ADGM.
GDF’s submission welcomes the focus on governance, operational integrity and corporate transparency, while recommending further clarification on the scope of activities captured by the regime. In particular, it highlights the need to distinguish between proof-of-work mining, proof-of-stake validator operations, incidental node activity and supporting infrastructure services, to ensure the framework remains proportionate, clear and operationally workable. The response also provides recommendations on security controls, pre-licensing assessments, confidentiality of wallet disclosures, incident reporting, supervisory tools and the treatment of overseas operations.
Submitted:
20/03/2026