Release Date
The Financial Services Regulatory Authority (FSRA) of the ADGM has issued Consultation Paper No. 10 of 2025 proposing a new regime for staking of virtual assets (VAs) in the ADGM.
Principal takeaways include:
Who can provide staking services
Entities licensed to Provide Custody (VA Custodians) and/or Manage Assets (VA Asset Managers) are permitted to provide staking services.
- VA Asset Managers may stake client VAs on a discretionary or instructed basis.
- VA Custodians may stake only on specific client instruction (discretion requires an asset management licence).
Assets Eligible for Staking
Only Accepted Virtual Assets (AVAs) may be staked.
Scope of Staking Activities
- Solo staking would not be regulated as participants operate without intermediation and carry out staking on their own account.
- Staking-as-a-service would not be regulated if services are purely technical, without holding or controlling client VAs.
- Other yield-generating activities involving VAs, including liquidity mining and yield farming (often referred to in the VA sector as “staking”), are considered distinct activities and are therefore not addressed by the proposal.
- Liquid Staking Tokens (LSTs), or enabling staking arrangements in or from ADGM whereby clients may receive LSTs, are not covered in the proposal.
Compliance and Approval Requirements
Before staking a client’s VAs, the licensed entity must notify the FSRA in writing and obtain its written non-objection.
Key Contacts
Divya Abrol Gambhir, Partner, d.abrol@tamimi.com
Ashish Banga, Senior Associate - Consultant, a.banga@tamimi.com
Praveena Pechetti, Associate, p.pechetti@tamimi.com
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