ADGM or DIFC Foundation?

ADGM: Foundations Regulations 2017, with English common law applying directly.
DIFC: DIFC Foundations Law 2018.

ADGM: initial assets of USD 100.
DIFC: no minimum.

ADGM: a licensed company service provider is required unless the foundation is exempt.
DIFC: no registered agent required; the foundation needs a registered address in the DIFC.

Both jurisdictions protect foundation assets against foreign forced heirship claims. The DIFC’s firewall provisions are often described as broader.

ADGM’s government fees are generally lower than the DIFC’s, and registration is fully digital.

For families who value low set-up costs, digital registration and a licensed partner on the ground, ADGM is usually the more practical choice. Where a structure already sits in Dubai, the DIFC can make sense; through our sister firm in Dubai, we know both jurisdictions.