ADGM Puts DLT Foundation Audits and Disclosure in Focus

Abu Dhabi Global Market (ADGM) has put the accounting obligations of blockchain foundations into sharper focus, explicitly detailing how DLT Foundations must audit, file and publicly disclose their annual accounts — requirements that could bring greater financial visibility to some of the most prominent blockchain organizations established in Abu Dhabi.

The clarification appears in Version 2.0 of ADGM Registration Authority's Annual Accounts Guidance, published in September 2026. For the first time in the Registration Authority's annual accounts guidance, the consolidated document includes a dedicated section covering the accounts and audit requirements of Distributed Ledger Technology (DLT) Foundations.

The requirements themselves are not new. They originate from ADGM's DLT Foundations Regulations 2023. The significance of the latest guidance is that the Registration Authority has now brought them directly into its broader annual accounts framework, spelling out what they mean for foundations operating under the regime.

That distinction matters as ADGM's DLT framework moves beyond its initial registration phase. Since the regime was introduced in 2023, foundations connected to IOTA, TON, Stacks, Bitgrit and ADI have established themselves under the framework or been publicly identified as DLT Foundations within ADGM's ecosystem.

Now, attention increasingly turns from who is registering to what ongoing financial transparency under the regime actually requires.

No Audit Exemption for DLT Foundations

The clearest point in the new guidance is also one of the most consequential: DLT Foundations have no audit exemption.

Unlike companies that may qualify for exemptions under certain circumstances, a DLT Foundation cannot avoid the audit requirement because of its size or because it was dormant during the financial year.

ADGM states that each DLT Foundation must appoint an independent auditor eligible under the ADGM Companies Regulations — in practice, an ADGM-registered auditor.

The foundation's councillors must prepare annual accounts for every financial year, while the underlying regulations require those accounts to be prepared according to applicable international accounting standards. The councillors must also be satisfied that the accounts fairly represent the foundation's assets, liabilities, financial position and profit or loss.

For blockchain organizations, that potentially brings an important part of their operations into a conventional financial reporting framework.

Many DLT foundations exist to support blockchain protocols, administer ecosystems, issue or manage tokens, fund development and coordinate grants or other ecosystem activities. ADGM itself defines a DLT Foundation as a separate legal person established to use, deploy, develop, facilitate or support distributed ledger technology, or to issue tokens.

The audit requirement therefore connects the decentralized structures of blockchain ecosystems with the financial accountability expected of a recognized legal entity.

The Accounts Are Meant to Become Public

The disclosure requirement goes beyond submitting documents privately to the regulator.

For each financial year, DLT Foundations must deliver both their annual accounts and auditor's report to the ADGM Registrar. The annual accounts filed with the Registrar are subject to public disclosure.

In addition, each DLT Foundation must publish its annual accounts on its own website. Under the underlying regulations, publication must occur no later than the applicable filing deadline or, if earlier, when the accounts and auditor's report are actually delivered to the Registrar.

The standard filing period is nine months after the end of the relevant accounting reference period, although different calculations can apply to a foundation's first reporting period or where its accounting reference period has been changed. The Registrar can also grant an extension for a special reason, subject to limits set by the regulations.

This means the precise date on which a particular foundation's accounts become due cannot be inferred simply from the date its ADGM registration was announced. Its accounting reference period and any applicable adjustments or extensions also matter.

That is an important distinction as some of ADGM's earliest DLT Foundations move further into their reporting cycles.

From IOTA to a Broader DLT Ecosystem

When ADGM launched its DLT Foundations framework in 2023, it described it as a purpose-built regime for blockchain foundations, decentralized autonomous organizations and the wider Web3 industry, including structures capable of issuing tokens.

IOTA became the first DLT Foundation registered under the framework in November 2023. At the time, IOTA said itsAbu Dhabi foundation would be seeded with more than $100 million in IOTA tokens, vested over four years to support ecosystem development.

Unlock Blockchain covered that establishment at the time, including the size of the planned token commitment and the role the new foundation was expected to play in expanding IOTA's ecosystem in the Middle East.

TON followed, announcing its registration under the DLT Foundations framework in December 2024 as part of its expansion across MENA and Asia-Pacific.

Stacks Asia subsequently established a DLT Foundation in ADGM, becoming the first Bitcoin-based foundation to establish a presence under the framework, according to ADGM.

Bitgrit also established a DLT Foundation in 2025 around its BGR Network and blockchain infrastructure for AI assets.

ADI DLT Foundation has meanwhile become another DLT Foundation operating within Abu Dhabi's digital infrastructure ecosystem, including through collaborations with ADGM Academy and its wider institutional activities.

These foundations differ substantially in purpose, scale and ecosystem design. But their establishment under the same legal framework subjects them to a common baseline of financial reporting and audit obligations.

What Could the Accounts Actually Reveal?

The importance of the regime becomes clearer when looking beyond the headline requirement to "have an audit."

The 2023 regulations require DLT Foundations to maintain adequate accounting records and prepare annual accounts under international accounting standards. They also prescribe disclosures relating to matters including employee costs and councillor remuneration where applicable.

The regulations specifically contemplate disclosures around councillor remuneration that can include gains from token options, long-term incentive benefits, payments for loss of office and certain payments involving connected persons. They also address advances, credit and guarantees involving councillors.

That does not mean every DLT Foundation will necessarily disclose every category; the applicable disclosures depend on its circumstances. Nor does an audit automatically provide a complete view of a blockchain ecosystem's on-chain treasury or every token associated with a protocol.

It does, however, create a regulated financial record of the legal foundation itself.

That distinction could become increasingly important as blockchain foundations manage substantial token holdings, finance ecosystem development and enter partnerships with institutional counterparties.

Registration Was Only the First Stage

ADGM's DLT Foundations framework attracted attention partly because it attempted to give blockchain-native governance structures a recognized legal personality without forcing them entirely into conventional corporate models.

The framework accommodates features including token issuance, tokenholder voting and smart contract-enabled governance, while creating an ownerless legal structure capable of holding assets, entering agreements, and suing or being sued.

But regulatory recognition also comes with obligations.

ADGM's latest guidance makes the accounting side of that bargain more visible. A foundation may operate a decentralized ecosystem, support token-based governance or have no conventional shareholders, but the legal entity established in ADGM must still maintain records, prepare annual accounts, undergo an independent audit and make its accounts available publicly.

The broader framework has also continued to evolve. In April 2026, ADGM introduced amendments affecting the DLT Foundations Regulations 2023 alongside other areas of its commercial legislation.

ADGM's own 2026 assessment of legal persons and arrangements similarly describes DLT Foundations as subject to mandatory disclosure requirements, including annual financial statements, with significant information about these entities subject to public disclosure as a transparency measure.

The direction is therefore becoming clearer: ADGM's DLT regime is not simply a legal home for blockchain foundations. It is also building an accountability framework around them.

For an industry in which foundation treasuries, token allocations and ecosystem funding can play a significant role in governance and development, the next test of the framework may not be how many foundations ADGM attracts, but how much meaningful transparency emerges once their audited financial reporting becomes part of the public record.