ADGM FSRA Introduces Mandatory Cyber Security Risk Management (CSRM) Framework

ADGM FSRA Introduces Mandatory Cyber Security Risk Management (CSRM) Framework

Effective January 2026

8/18/2025
ADGM FSRA Introduces Mandatory Cyber Security Risk Management (CSRM) Framework

The Abu Dhabi Global Market (ADGM) Financial Services Regulatory Authority (FSRA) has introduced legally binding Cyber Security Risk Management (CSRM) rules, effective 31 January 2026. These new requirements mark a significant step toward strengthening the cyber resilience of financial institutions operating in ADGM.

  • Why FSRA Introduced the CSRM Framework?
    Cyber threats are increasing in frequency and sophistication. Financial firms face:
  • Financial loss from fraud, ransomware, and operational disruption
  • Reputational damage from data breaches that erode customer trust
  • Regulatory penalties for non-compliance

The CSRM framework ensures firms manage cyber risks consistently, protect sensitive data, and strengthen market integrity.

Benefits of CSRM for Your Organization

  • Protect finances: Reduces risk of direct and indirect losses from cyber attacks
  • Build customer trust: Demonstrates commitment to safeguarding data
  • Operational resilience: Structured frameworks allow faster detection, reporting, and mitigation of incidents
  • Regulatory readiness: Ensures audit-ready compliance and avoids costly fines

What’s changing?


Area

Before July 2025

From July 2025 (Effective Jan 2026)

Legal Status

Mostly guidance, compliance was voluntary

Now legally required and all firms must comply

Cyber Risk Framework

Cyber risks were expected to be managed, but no formal framework

Must have a formal, documented cyber risk management framework integrated into overall business risk management

Incident Notification

Quick reporting expected, within 72 hrs.

Must report significant incidents within 24 hours

Third-Party / IT Risk

General advice for managing supplier or IT risks

Clear rules for managing risks from IT suppliers and subcontractors, including contracts and monitoring

Governance

Board accountability was general

Board must approve the framework, set risk limits, and review regularly

Transition Period

N/A

Six-month window to comply by 31 Jan 2026


Real-World Impact of Cyber Attacks in ADGM

While specific organizations are not named, recent incidents within the ADGM financial sector have demonstrated the critical need for robust cyber risk management

Case Study 1: A financial institution experienced a ransomware attack that disrupted operations for several days, leading to significant financial losses and a decline in customer trust. The estimated financial impact was approximately $3 million, highlighting the importance of having a formal cyber risk management framework in place to prevent such occurrences.

Case Study 2: An unauthorized access breach compromised sensitive customer data, resulting in reputational damage and regulatory scrutiny. The event underscored the necessity for strict governance and incident notification protocols as mandated by the FSRA.

Case Study 3: A third-party service provider was found to have inadequate cybersecurity measures, which exposed the institution to potential threats. This case emphasized the need for comprehensive third-party risk management and compliance with FSRA's requirements.

How We Can Help:
Our services are designed to build robust cyber resilience and safeguard your organization. We can provide

  • 24/7 SOC monitoring to meet the ≤24h incident reporting rule.
  • Threat intelligence aligned with FSRA’s risk-based approach.
  • ICT vendor risk monitoring and contract compliance checks.
  • Incident playbook updates and FSRA-ready notification templates.
  • Compliance evidence packs for audit-readiness.

Deadline: Six months to comply.

Act now to safeguard your organization against cyber threats and ensure operational resilience. The deadline to comply with FSRA’s CSRM rules is 31 January 2026. Organizations have a six-month window to prepare – delaying action could expose firms to operational, financial, and regulatory risks.

Secure Today. Protect Tomorrow.

Our Cyber Security & Cyber Threat Management Consulting, Assessments, And Tailored Solutions help you stay ahead of evolving threats and safeguard your business-critical assets. Partner with us to ensure resilience, compliance, and peace of mind and contact us today to start your CSRM compliance journey.

Crowe UAE | Email: [email protected] | Mobile: +971 55 343 8693


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Dawn Thomas
Dawn Thomas
Partner - Governance Risk & Compliance