Setting Up a Fund Manager in ADGM? Here's the Office You'll Need

Most founders who call us about a fund manager start the conversation in the same place: how many offices do I need to lease, and how big do they have to be? It is a fair question, but it usually has a surprising answer. A typical fund manager structure has several legal entities stacked on top of one another, and only one of them needs premises at all. Get that mapping right and you avoid paying for floor space you will never use. Get it wrong and you either overspend or, worse, fall short of what the regulator expects of the one entity that genuinely matters.

So before you sign anything, it helps to separate the layers of your structure and ask, for each one, a single question: does the FSRA expect this entity to have substance? Because office requirements in ADGM do not attach to a structure in the abstract. They attach to specific entities, based on what each one does.

The regulated manager is the entity that needs an office

The fund manager itself — the operating company that holds the FSRA permission to manage assets — is a regulated entity. It is supervised, it carries regulatory capital, and it is expected to demonstrate genuine substance in ADGM. For premises, that means a real, dedicated private office. Not a hot desk you share with whoever wanders in, and not a name on a registered-address service. The regulator wants somewhere your investment team can actually sit, where decisions get taken, and where client and investor records can be stored securely.

This is the entity where the cost and the scrutiny live. When we talk through space with a manager, we are really talking about the manager company, full stop. The rest of the structure tends to need nothing. If you want the broader picture of what the regulator looks for, our note on office requirements for FSRA-regulated firms walks through how premises sit alongside people, governance and capital.

SPVs and the funds you manage generally need no premises

Underneath the manager you will usually find special purpose vehicles and the funds themselves. These are holding and pooling structures. They do not employ people, they do not take investment decisions independently, and they do not store records the way an operating business does — the manager does all of that on their behalf. As a result, an SPV in ADGM generally needs no office of its own; it satisfies its address requirement through a registered office arrangement, not a leased room. Our explainer on how ADGM SPVs work goes into why these vehicles are deliberately light.

The same logic flows up to the funds. A fund is a pool of capital under management; it is the manager that carries the obligations. This is the single most useful thing to internalise: the office requirement lives on the regulated operating layer, not on the holding layer. Map your structure that way and the premises question almost answers itself.

What a fund manager's office should actually include

Once you know the manager needs a private office, the next question is what that office should contain. The regulator is not handing out a checklist of square metres, but the expectation is plainly that the space matches the activity. In practice that means a room your team can genuinely occupy, sized to your headcount with a little room to grow, plus the ability to store sensitive material securely — investor onboarding files, subscription documents, board minutes, compliance records.

• Dedicated, lockable space — not shared, so confidential conversations and documents stay private.
• Secure record storage — physical and digital, with controlled access to investor and client data.
• Seating for your ADGM-based people — the substance test assumes real staff are based there, not just a brass plate.
• A professional setting for governance — somewhere board and investment-committee meetings can credibly take place.

None of this needs to be lavish. It needs to be real and appropriate. A small manager with three people does not need a trading floor; it needs a tidy, secure private office that an examiner could walk into and recognise as a working business.

A worked example: a small manager and its vehicles

Picture a boutique manager launching with a founder, a portfolio manager and a part-time compliance officer — three people in ADGM. They establish a single regulated fund management company. Beneath it they set up one fund and two SPVs to hold the underlying assets. So the legal diagram has four entities: the manager, the fund, and two SPVs.

How many offices? One. The manager takes a private office sized for three to four desks, with secure storage for investor files. The fund and the two SPVs take registered-office arrangements and lease no space at all. If this team had assumed each entity needed its own room, they would have been pricing four offices — and three of them would have sat empty. Instead they pay for the one space that does real work, and the holding layer costs them next to nothing in premises terms.

As the manager grows — say to eight people and a second fund — only the manager's office needs to expand. The new fund and any new SPVs slot in underneath without adding floor space. That is the efficiency of mapping requirements to entities rather than to the org chart as a whole.

Mapping your structure before you commit to space

The practical move is to draw your structure first and label each entity by what it does, then attach a premises decision to each label. Regulated operating company? Private office. Holding or pooling vehicle? Registered office, no lease. Do this on paper before you talk to anyone about square footage and you will walk into the space conversation knowing exactly what you are buying. For a wider sense of why managers are choosing this jurisdiction in the first place, our piece on asset managers choosing ADGM sets the scene.

One Al Reem footnote, because it does change the maths: housing the manager in a private office here, in the same ADGM regime as Al Maryah, costs meaningfully less per desk — which matters most for exactly the entity that has to carry real premises.

Frequently asked questions

Does every entity in my fund structure need its own office?

No. In a typical structure only the regulated fund management company needs a dedicated private office. The funds and SPVs it manages generally satisfy their requirements through a registered office and need no leased space of their own.

Can my fund manager operate from a shared desk?

Generally not. Because the manager is FSRA-supervised and must demonstrate substance, the regulator expects a dedicated, private and secure office appropriate to the activity — a shared hot desk usually falls short for an authorised manager.

Where do my investor and client records have to be kept?

With the manager, securely. The manager carries the record-keeping obligations on behalf of the funds and SPVs, so its office needs controlled, secure storage for investor onboarding files, subscription documents and compliance records.

How big should the manager's office be?

Sized to your ADGM-based headcount with modest room to grow. A small manager with three or four people needs a private office that genuinely seats that team and stores records securely — appropriate to scale, not oversized.

Talk to MY Coworking

Setting up a manager and unsure which entity needs what? We will map your structure with you and quote a private office sized to the regulated company alone — so you pay for substance, not for empty rooms.

We're on Al Reem Island — 2312 Addax Tower, City of Lights, Abu Dhabi. Email contact@mycoworking.ae to book a tour or get a same-day quote.