ADGM’s New Cyber Risk Management Framework: Why It Demands a GRC Overhaul

The New ADGM Cyber Risk Management Framework

The Abu Dhabi Global Market's (ADGM) Financial Services Regulatory Authority (FSRA) has implemented a new Cyber Risk Management Framework, effective January 31, 2026. This framework marks a significant shift from high-level guidance to legally binding requirements for all Authorized Persons and Recognized Bodies within the financial free zone.

The ADGM Cyber Risk Management Framework is designed to establish a consistent, market-wide standard for cyber resilience, safeguarding the integrity of the ADGM’s financial ecosystem against increasingly sophisticated threats. This initiative builds upon prior guidelines to establish a more structured and enforceable rule set that aligns with global best practices in cybersecurity regulation.

How It Affects ADGM-Licensed Firms

The new FSRA cyber framework elevates cybersecurity from a back-office IT concern to a core business imperative, with direct accountability at the board and senior management level.

A formally documented and board-approved cyber risk framework is now a legal obligation. This is not merely a policy statement but a comprehensive set of strategies, policies, and procedures that must guide daily operations. The aim is to embed security into the firm’s DNA, ensuring that cyber risk is proactively managed rather than addressed reactively.

The framework also introduces enhanced obligations for oversight of third parties. The FSRA recognizes that many cyber vulnerabilities originate within the supply chain. As a result, firms must conduct rigorous due diligence on IT service providers, including cloud and software vendors. Contracts must include clear provisions for security standards, incident notification, and audit rights. Importantly, non-compliance may stem not only from a firm’s own shortcomings but also from weaknesses in its suppliers’ security practices, making firms responsible for the resilience of their entire digital ecosystem.

Another critical element is the principle of proportionality and integration. While requirements will scale according to a firm’s size, complexity, and risk profile, all firms are expected to integrate cyber risk management into their broader Enterprise Risk Management (ERM) and governance structures. This shift requires cyber risk to be treated with the same seriousness as financial, credit, or market risk, ensuring it is managed holistically across the enterprise.

Finally, the framework mandates swift incident reporting. Any material cyber incident must now be reported to the FSRA within 24 hours of discovery. Meeting this demanding timeline requires robust internal detection and notification protocols, often supported by automated systems for logging and classification, along with predefined communication plans. The objective is to enable the FSRA to act quickly and contain potential systemic risks before they can spread across the Abu Dhabi Global Market.

Why a Strategic GRC Overhaul Is Needed

A piecemeal or reactive approach to compliance is no longer sufficient. Much like the EU’s DORA regulation, the ADGM Cyber Risk Management Framework requires a strategic overhaul of Governance, Risk, and Compliance (GRC) functions.

The traditional “checkbox” mindset of meeting minimum standards is misaligned with the FSRA’s outcome-focused framework. Firms must adopt an enterprise-wide strategy that unifies IT security, operational resilience, and corporate governance. This shift ensures that compliance is not treated as a siloed obligation but as an integrated driver of resilience and trust.

The new framework also places board-level accountability front and centre. Directors and senior management must set the firm’s cyber risk appetite, actively oversee resilience measures, and be prepared for scrutiny during audits or thematic reviews. Failure to do so can result in penalties, reputational damage, and questions around leadership responsibility. This heightened oversight compels boards to take a more proactive role in cyber governance, moving beyond delegation to IT teams.

At the same time, firms must carefully navigate the proportionality challenge. Each organisation must assess its specific threat landscape, digital footprint, and third-party dependencies to calibrate the right level of controls. Without careful alignment, a firm risks creating inefficiencies, leaving unaddressed vulnerabilities, or undermining confidence with international partners who increasingly demand proof of operational resilience in Abu Dhabi Global Market firms.

In short, this framework is not just about compliance. It is about embedding resilience into the very fabric of the business.

How AwareFox Can Help with the 

At AwareFox, we understand that navigating this evolving regulatory landscape requires a strategic partner. Our GRC and business advisory services are designed to help firms turn regulatory obligations into a competitive advantage.

• Strategic Advisory & Gap Analysis: We conduct a full-scale review of your current GRC framework against ADGM’s requirements, identifying weaknesses and developing a tailored roadmap for compliance and operational resilience.

• Custom Framework Development: We help you design and implement a robust Cyber Risk Management Framework fully integrated into your governance and risk structures, with practical policies, procedures, and controls for asset management, incident response, and third-party oversight.

• Third-Party Risk Management: We support you in reviewing, negotiating, and updating contracts with critical vendors while establishing monitoring programs to continuously assess their cyber resilience.

• Training & Implementation: We deliver targeted training for boards, senior management, and operational teams, ensuring everyone understands their responsibilities. We also provide hands-on support during implementation to ensure a smooth and effective transition.

By partnering with AwareFox, you can transform regulatory compliance into a foundation for resilience, protecting your firm’s assets, reputation, and long-term success.

Conclusion

The ADGM Cyber Risk Management Framework signals a decisive shift in how firms must approach digital resilience. Compliance will no longer be about ticking boxes. It will be about building lasting structures of trust, accountability, and adaptability. Those who act early will not only meet regulatory obligations but also gain a strategic edge in a market where clients, partners, and regulators demand proof of resilience. With the right guidance, this transition can strengthen both compliance and competitiveness, and AwareFox is here to help you achieve exactly that.