GDF Response to FSRA of the ADGM Consultation paper on Proposed Regulatory Framework for Regulated Activities Involving Fiat-Referenced Tokens
GDF convened its MEA policy Working Group to analyse the Consultation Paper on The Proposed Regulatory Framework for Regulating Activities Involving Fiat-Referenced Tokens (FRTs) published by the Financial Services Regulatory Authority (“FSRA”) of the Abu Dhabi Global Market (“ADGM”).
GDF is supportive of the aim of the CP, as well as the FSRA’s broader aims of further developing their regime a comprehensive regime for crypto and digital assets, including FRTs. It is a welcome step forward in strengthening ADGM’s position as a regional leader in digital-asset regulation and advancing global alignment and regulatory interoperability.
In collaboration with our members, GDF has aimed to provide technical feedback, as well as high-level analysis on the proposals, taking into consideration the requirements that industry must also comply with in other jurisdictions. Through this process GDF members identified key areas that we believe the ADGM should consider as they move forward with their additional regulatory requirements for the use of FRTs within regulated markets. The core areas identified are:
1. FSRA’s balanced approach to regulating fiat-referenced tokens that supports both innovation and market integrity.
2. Transparency in the Accepted FRT list: FSRA should clarify the criteria, review cycle, and delisting conditions.
3. Coordination with CBUAE for AED-denominated tokens: Further guidance from the FSRA and CBUAE would ensure predictable, aligned supervision of AED-denominated stablecoins.
4. Proportionate oversight to prevent fragmentation: A token-level due-diligence model would avoid liquidity fragmentation and support a future issuer-notification regime similar to ADGM’s AVA model.
5. Regional and international interoperability: Alignment with VARA and comparable global regimes will enhance regulatory coherence and ADGM’s competitiveness as a digital-asset hub.
Submitted 07/10/25
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