For many ADGM entities, 30 September 2026 is an important compliance date. If your company has a 31 December 2025 Accounting Reference Date (ARD), your Annual Accounts will generally need to be filed by 30 September 2026.
While the deadline may seem straightforward, preparing for an ADGM Annual Accounts filing involves more than simply submitting financial statements. Companies need to establish which requirements apply to them, ensure their accounting records are in order, address audit requirements where applicable and provide the required information through the ADGM Online Registry.
With the deadline approaching, understanding what needs to be filed and when can help avoid last-minute compliance issues.
Why is 30 September important for ADGM companies?
ADGM requires to file the Annual Accounts within the applicable period following their Accounting Reference Date.
For a private company or LLP with a 31 December ARD, the general filing period is nine months.
This means:
Accounting Reference Date: 31 December 2025
Annual Accounts filing deadline: 30 September 2026
As many businesses operate on a calendar-year financial cycle, 30 September is therefore a significant annual filing date for a large number of ADGM entities.
However, it is important to remember that 30 September is not a universal deadline for every ADGM entity. The applicable deadline depends on the entity’s type, Accounting Reference Date and specific filing requirements.
What are ADGM Annual Accounts?
Annual Accounts provide the financial reporting information required by the ADGM Registration Authority for the relevant accounting period.
Depending on the entity and applicable requirements, the process may involve:
- Preparation of financial statements
- Maintenance and review of accounting records
- Audit of the accounts, where applicable
- Providing prescribed financial and company information through the ADGM Online Registry
- Ensuring the filing is completed within the prescribed deadline
The objective is not simply to meet an administrative requirement. Proper annual reporting allows the Registration Authority to maintain up-to-date information about the financial and corporate position of registered entities.
Does every ADGM company have to file Annual Accounts?
Yes, but not necessarily in the same way.
The filing requirements can differ depending on the type of ADGM entity, its size, applicable exemptions and other circumstances.
For example, certain entities may qualify for exemptions from particular accounting or audit requirements, while others may have additional obligations.
This is why businesses should avoid assuming that another company’s filing treatment automatically applies to them.
The correct starting point is to determine the requirements applicable to your specific ADGM entity.
Annual Accounts vs Confirmation Statement: Don’t confuse the two
Another common compliance mistake is treating Annual Accounts and the Confirmation Statement as the same annual filing.
They serve different purposes.
Annual Accounts
Annual Accounts relate primarily to the entity’s financial reporting obligations and are filed according to the applicable accounting reference period.
For entities with a 31 December ARD, this is why the deadline can fall on 30 September.
Confirmation Statement
The Confirmation Statement, formerly referred to as an Annual Return, is different.
It is used to confirm that the corporate information held by the ADGM Registration Authority remains accurate and up to date. Its deadline is generally linked to the entity’s incorporation anniversary rather than a fixed 30 September date.
Therefore, completing one filing does not necessarily mean the entity has satisfied all of its annual ADGM compliance obligations.
What information should businesses review before filing?
Before approaching the deadline, ADGM entities should review both their financial records and corporate information.
1. Accounting records
Make sure the accounting records for the relevant financial period are complete, properly maintained and available to support the accounts.
2. Financial statements
The financial statements should be prepared in accordance with the accounting requirements applicable to the entity.
3. Audit requirements
Where an audit is required, businesses should factor sufficient time into their compliance calendar for the audit to be completed before the filing deadline.
Entities should also determine whether they qualify for any applicable audit exemption rather than assuming an exemption applies.
4. Corporate information
Annual Accounts filing should not be viewed in isolation. Businesses should also review whether there have been changes to information such as directors, shareholders, registered office or other company particulars that may require separate filings.
5. Online Registry requirements
ADGM has introduced additional information requirements within its Online Registry for annual accounts filings.
This means businesses should have the relevant financial and corporate information available before starting the online submission rather than treating the filing as a simple document upload.
What happens if you miss the deadline?
ADGM applies penalties for late filings.
More importantly, a missed filing can create an avoidable compliance issue for the entity and may require additional follow-up to regularize its position.
For businesses with a 30 September deadline, waiting until the final few days can therefore create unnecessary pressure particularly where accounts, audit work or supporting information are still outstanding.
A practical timeline for the 30 September deadline
A simple internal timeline can make the process considerably easier.
- Before September:
Confirm the entity’s ARD and applicable filing requirements.
- Early September:
Finalise accounts and resolve outstanding accounting or audit matters.
- Mid-September:
Review the information required for the Online Registry filing and check corporate details.
- Before 30 September:
Submit the Annual Accounts and retain evidence of the filing.
The key is to treat 30 September as the filing deadline, not the preparation deadline.
Is your ADGM entity ready for 30 September 2026?
If your ADGM entity has a 31 December 2025 Accounting Reference Date, the 30 September deadline should already be on your compliance calendar.
But Annual Accounts are only one part of maintaining an ADGM entity in good standing. Depending on the entity, there may also be Confirmation Statement, license, tax, accounting, audit and other regulatory obligations to consider.
A review ahead of the deadline can help identify what applies to your entity and what still needs to be completed.
Need help with your ADGM annual compliance?
MS can support ADGM entities with Annual Accounts, corporate tax and wider regulatory compliance requirements, helping businesses identify their filing obligations and stay ahead of key deadlines.
Contact our team to review your ADGM compliance requirements before 30 September 2026.
