Your Guide on ADGM Whistleblower Protection Regulations 2024

Everything You Need to Know to Stay Compliant Before May 31, 2025

What is the ADGM Whistleblower Protection Regulations 2024?

The Abu Dhabi Global Market (ADGM) has rolled out a Whistleblower Protection Regulation and  Supplementary Guidance, setting a new standard for corporate integrity and ethical business conduct. This regulation isn't just another compliance requirement - it’s a game-changer in corporate governance, designed to protect employees who speak up about misconduct while ensuring businesses operate with complete transparency.

By May 31, 2025, every ADGM-registered entity must have a fully compliant whistleblowing system. This isn't just about avoiding penalties - it’s about building a workplace where employees feel safe, valued, and empowered to report wrongdoing without fear of retaliation.

With this regulation, ADGM clarifies that integrity isn’t optional but essential. Businesses that take proactive steps now will stay compliant and foster a culture of trust, accountability, and long-term success. Now is the time to act.

Why Does This Matter?

Implementing an effective whistleblowing system is not just about ticking regulatory boxes - it directly impacts business integrity and operational stability. Here's why staying compliant with the ADGM Whistleblower Protection Regulations is not just a legal requirement but an innovative business move you can’t afford to ignore: 

Penalties & Sanctions

• Fines of up to $50,000 for failing to implement a compliant whistleblowing system.
• Public censure leads to reputational damage.
• Suspension or withdrawal of business licenses, putting company operations at risk.

The Risk of External Whistleblowing

If internal reporting channels are weak or untrusted, employees may report directly to ADGM regulators, bypassing the company entirely.

External whistleblowing can trigger:

• Regulatory investigations
• Legal actions
• Government scrutiny

Legal & Financial Risks

• Employees facing unfair treatment after reporting misconduct may file legal claims against the company. 
• Failing to protect whistleblowers can damage an entity’s reputation, impacting partnerships, investor confidence, and regulatory standing.

How FaceUp Can Help 

Ensuring compliance with the ADGM Whistleblower Protection Regulations requires more than just setting up a generic hotline. FaceUp provides a tailored, all-in-one whistleblowing platform explicitly designed for ADGM businesses.

Unlike global platforms that take a one-size-fits-all approach, in FaceUp, we have this fully covered:

• With our representatives in the UAE, we provide localized solutions and direct support tailored to ADGM regulations.
• Our locally hosted servers ensure compliance with UAE data protection laws, keeping your company’s sensitive data within a jurisdiction.
• We collaborate with leading ADGM-based law firms, including Al Tamimi, to provide businesses with legal guidance on whistleblowing compliance.
• Our partnerships with ADGM regulators and compliance specialists keep our clients ahead of legal updates, ensuring their whistleblowing system remains fully compliant.

In the following sections, we’ll explore the key compliance requirements, how they differ based on your specific company segment, best practices for setting up a practical whistleblowing framework, and why FaceUp is the ideal solution for ADGM businesses navigating these new regulations.
 

Understanding ADGM and Its Whistleblowing Framework

With thousands of registered entities spanning finance, technology, legal services, and other sectors, ADGM is committed to upholding high governance standards, transparency, and compliance. The newly introduced Whistleblower Protection Regulations 2024 further reinforce these principles, ensuring businesses maintain integrity while protecting those who report misconduct.

Core Goals of the Whistleblower Protection Regulations 2024

The ADGM Whistleblower Protection Regulations are designed to create a safer, more transparent business environment by:

• Strengthening trust and accountability within organizations.
• Encouraging employees and stakeholders to report unethical or illegal activities without fear.
• Ensuring whistleblowers are shielded from dismissal, harassment, or other adverse consequences.
• Preventing fraud, corruption, and misconduct from negatively impacting entities and the ADGM financial ecosystem.

By implementing these regulations, ADGM aims to establish a strong framework that protects whistleblowers and helps organizations proactively address and mitigate risks before they escalate into more extensive compliance or reputational issues.

Who Needs to Comply?

A. Mandatory Compliance for All ADGM Entities

Every business registered in ADGM - regardless of industry or size - must adhere to the Whistleblower Protection Regulations by May 31, 2025. This includes implementing the necessary internal processes to handle internal reports effectively.

Key compliance requirements include:

• Setting up a confidential and secure system where employees and stakeholders can report concerns.
• Appointing designated whistleblowing officers to manage and oversee whistleblowing cases. These can be:
  
  
  • Internal compliance, legal, or audit team members
  • Group-level HR or compliance officers (even if based outside ADGM)
  • External third-party whistleblowing service providers
     
• Ensuring whistleblowers can report concerns without fear of losing their jobs or facing discrimination.
• Maintaining whistleblowing records for at least six years.  
• Handling sensitive whistleblower information in line with UAE data protection regulations is a legal requirement.

With the May 31, 2025 deadline approaching, businesses registered in ADGM must act now to ensure full compliance and avoid potential negative consequences.

Stricter Requirements for Certain Businesses

While all ADGM entities must comply with whistleblower protection rules, certain businesses face more stringent requirements due to their size, industry, or regulatory status. These include:

A. Businesses Subject to Higher Standards

• Large Establishments – Entities with:
  • Annual turnover or assets exceeding USD 13.5 million
  • 35+ employees
     
• Authorized Persons & Recognized Bodies – Entities regulated under the Financial Services and Markets Regulations (FSMR)
• Designated Non-Financial Businesses & Professions (DNFBPs) – This includes law, real estate, and accounting firms.
• DLT Foundations – Businesses operating in distributed ledger technology (blockchain) under ADGM regulation.

B. Enhanced Compliance Measures for These Businesses

Entities in these categories must implement comprehensive whistleblowing frameworks beyond essential compliance. These include:

Whistleblower Policies & Procedures

• Develop clear, concise, and accessible whistleblower policies.
• Ensure policies are easy to understand and comply with ADGM regulations.

Internal Reporting Channels

• Establish secure and reliable whistleblowing mechanisms.
• Provide multiple reporting options, such as:
  • Digital reporting platforms
  • Anonymous hotlines
  • In-person reporting systems

Whistleblower Feedback Mechanisms

• Implement a structured process to acknowledge reports and update whistleblowers on case progress.
• Enable two-way communication for follow-ups while maintaining anonymity.

Identity Protection & Confidentiality

• Ensure whistleblower identities remain strictly confidential.
• Use encryption and access controls to protect sensitive information.
• Allow fully anonymous reporting while maintaining investigation integrity.

Protected Disclosure Assessment & Investigation

• Establish clear procedures to assess and investigate reports.
• Determine appropriate next steps, such as:
  • Internal reviews
  • Legal assessments
  • Regulatory escalation

Whistleblower Retaliation Prevention

• Enforce strict anti-retaliation policies to protect whistleblowers.
• Monitor for signs of retaliation, including:
  • Demotions
  • Terminations
  • Workplace harassment

Escalation & Regulatory Compliance

• Implement structured escalation procedures for serious disclosures.
• Ensure timely reporting to ADGM or UAE regulators when required.

Fair Treatment of Accused Persons

• Establish policies to ensure objectivity and fairness during investigations.
• Address potential conflicts of interest in whistleblowing cases.

Ongoing Communication & Awareness

• Regularly educate employees on whistleblower protections.
• Conduct training sessions and provide periodic reminders about reporting channels.
• Reinforce confidentiality commitments to build trust in the system.

What Qualifies as a Protected Disclosure?

To receive protection under the regulations, a whistleblower’s report must meet the following conditions:

• The whistleblower must genuinely believe the information reported is accurate and relevant.
   
• The disclosure must be based on facts or reasonable grounds to suspect wrongdoing.
   
• Reports must involve violations of ADGM regulations, laws, or rules, including:
  • Money laundering
  • Fraud
  • Financial crimes
  • Any other breaches of laws administered by an ADGM authority
     
• Disclosures must be made via:
  • Internal channels – The entity’s designated whistleblowing system
  • External channels – Relevant ADGM or UAE authorities, such as:
    • Financial Services Regulatory Authority (FSRA)
    • Registration Authority (RA)

Protected disclosures can be made anonymously, ensuring whistleblowers can report misconduct without revealing their identity.

Further Recommendations for Strengthening Whistleblower Protections

Beyond the mandatory compliance requirements, businesses registered in ADGM can take additional steps to enhance their whistleblowing frameworks. These best practices help build a culture of trust, improve case management, and ensure regulatory compliance while protecting both whistleblowers and the organization.

Encouraging Internal Reporting (Without Making It Mandatory)

While businesses should promote internal reporting as the first defense against misconduct, employees must always be free to report directly to regulators. The ADGM Whistleblower Protection Regulations explicitly state that:

• Internal reporting should be encouraged but never mandatory – Employees must not be pressured into using internal channels before approaching external authorities.
• Employees retain the right to report to ADGM and UAE regulatory authorities, including the FSRA (Financial Services Regulatory Authority) and RA (Registration Authority).
• Trustworthy internal reporting systems can help businesses address concerns proactively. A well-managed internal whistleblowing system increases the chances of employees reporting internally first, allowing companies to investigate and resolve issues before they escalate to external authorities.

Independent & Skilled Case Management

Effective whistleblowing programs require competent, independent professionals to handle reports fairly and objectively. ADGM entities should:

• Appoint independent whistleblowing officers or external case managers – Professionals responsible for disclosures must remain impartial and free from conflicts of interest.
• Ensure investigations are fair, thorough, and legally sound – Cases should be assessed based on facts and compliance standards, not company politics.
• Consider outsourcing to third-party specialists – Some businesses may benefit from external whistleblowing service providers who offer independent case handling and legal expertise.

Specialized Training for Whistleblowing Program Managers

Handling whistleblowing reports requires expertise in compliance, data security, and anti-retaliation protections. Companies must ensure that designated personnel are appropriately trained to manage whistleblowing cases effectively.

• Training should cover key areas such as:
  • ADGM Whistleblower Protection Regulations and legal frameworks
  • Case assessment procedures to determine credibility and next steps
  • Confidentiality and data protection protocols
  • Anti-retaliation safeguards to protect whistleblowers from harm
  • Escalation pathways for severe cases requiring regulatory intervention

Company-Wide Training & Awareness Initiatives

A strong whistleblowing culture starts with organization-wide awareness. Employees at all levels should understand their rights, protections, and reporting options. Companies should:

• Educate staff about:
  • What qualifies as a protected disclosure
  • How to report concerns confidentially
  • The protections against retaliation provided under ADGM law
     
• Consider:
  • Workshops and seminars on ethical reporting and compliance
  • Internal newsletters with real-life case studies (anonymized)
  • Online learning modules for continuous training and accessibility
     
• Leaders should actively encourage ethical reporting and demonstrate a zero-tolerance approach to misconduct.

Key Compliance Requirements for ADGM Whistleblower Protection Regulations 2024

Internal Whistleblowing Channels

All ADGM entities must:

• Provide clear, simple, and accessible whistleblowing mechanisms.
• Offer anonymous and confidential two-way communication for whistleblowers.
• Assign trained designated personnel to manage and investigate reports.
• Use encrypted, secure platforms to prevent data breaches and leaks.

How FaceUp Helps:

• Whistleblowers can report safely without revealing their identity.
• End-to-end encryption that ensures sensitive information remains fully protected.
• To enhance trust, companies can include designated case managers' bios, names, and photos.
• Employees can report via the web, app, or phone, making the system flexible and accessible.

Whistleblower Protection & Retaliation Prevention

Entities must implement strict safeguards against retaliation, including:

• Ensuring whistleblowers are protected from dismissal, demotion, harassment, or loss of benefits. 
• Educating employees on legal protections and their ability to report misconduct without fear.
• Establishing clear case escalation procedures to handle reports objectively.

How FaceUp Helps:

• Eliminates the risk of retaliation by protecting the whistleblower’s identity via anonymous reporting channels.
• Ensures objective case handling by assigning reports to designated compliance officers via developed workflows. 
• Provides whistleblower protection training & policy guidance, which helps businesses build strong anti-retaliation measures.

Record-keeping & Data Compliance

Entities must adhere to strict data retention and protection laws, including:

• Maintaining whistleblower reports for at least six years to comply with ADGM regulations.
• Ensuring compliance with ADGM Data Protection Regulations 2021 to protect sensitive information from misuse.

How FaceUp Helps:

• Ensures all whistleblower reports are securely stored for compliance.
• Meets global data security and privacy standards, such as ISO-certified security & GDPR-compliant data protection. 

Trusted by Top Companies: FaceUp’s Whistleblowing Solution in Action

With over eight years of experience, FaceUp has been a trusted partner for companies worldwide. We help organizations strengthen internal systems, enhance external credibility, and establish long-term accountability. 

Our commitment to providing high-quality whistleblowing and employee engagement solutions has made us a preferred choice for leading businesses across the Middle East.

We are proud to work with 3,500 global and regional industry leaders, including:

• Emirates
• Etisalat
• Zain
• Mercedes
• Renault
• KFC

These organizations rely on FaceUp to meet compliance requirements and foster transparency, integrity, and a strong corporate culture.

Real-World Applications: Success Stories in Action

Compliance is more than just following regulations - it is about creating systems that work in practice. Our case studies demonstrate how FaceUp has helped companies implement effective whistleblowing solutions, enhance corporate governance, and protect their reputations.

We are pleased to share a real-world success story showcasing how FaceUp transformed a company’s approach to whistleblowing, ensuring full compliance while strengthening employee trust and engagement.

Beyond Compliance: A Powerful Opportunity to Foster a Strong Speak-Up Culture

Implementing a whistleblowing system is not just about regulatory compliance but about creating a workplace where employees feel safe, empowered, and confident in reporting concerns.

A genuinely effective whistleblowing program does more than just offer reporting channels - it builds a Speak-Up Culture that prioritizes:

• Trust, so employees know their reports will be taken seriously and handled confidentially.
• Transparency, where misconduct is addressed openly and fairly.
• Accountability, so leadership sets a strong ethical example, reinforcing a zero-tolerance stance on misconduct.

Why Does This Matter?

Without trust, employees hesitate to report misconduct. If an organization’s culture does not support openness, reports will either never be made - or they will go straight to external regulators, bypassing internal systems altogether. This increases legal risks, reputational damage, and potential financial penalties.

That is why the ADGM Whistleblower Protection Regulations emphasize the importance of a strong “tone from the top.” Leadership must:

• Communicate their commitment to whistleblowing.
• Demonstrate support for ethical reporting by taking reports seriously.
• Ensure employees understand that confidentiality and protections are in place.

When management leads by example, employees are more likely to trust the system, report misconduct, and contribute to a culture of integrity. This proactive approach helps companies identify risks before they escalate, ensuring a more resilient and compliant organization.

How to Build Trust and Encourage Speaking Up

• Provide multiple anonymous reporting options to ensure whistleblowers feel safe and protected. 
• Launch regular awareness campaigns to reinforce the importance of transparency and accountability.
• Recognize and reinforce ethical behavior by encouraging leadership to support and reward integrity actively.

Stay Compliant and Remain Successful with FaceUp

Navigating the ADGM Whistleblower Protection Regulations 2024 requires more than setting up a reporting channel - it demands a comprehensive, secure, and proactive approach to compliance. FaceUp is designed to help businesses meet regulatory requirements and build a culture of trust, transparency, and accountability.

Why FaceUp?

• FaceUp goes beyond whistleblowing. Our platform improves corporate transparency, strengthens governance, and supports employee engagement, all within a single, easy-to-use system.
• With built-in regulatory alignment, FaceUp ensures that ADGM entities remain fully compliant without the complexity of managing multiple tools or external providers. 
• FaceUp is a future-proof solution used by top organizations worldwide that evolves with regulatory updates, keeping businesses ahead of compliance risks.

Take the Next Step

The deadline for May 31, 2025, is fast approaching. Take proactive steps now to ensure compliance, protect your business, and foster a culture of integrity with FaceUp.

Get in touch with our UAE-based representatives by booking a demo and entering your location in the form. We’d love to have you join our growing community! Beyond the initial steps, you can always count on our ongoing support throughout your journey.