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ADGM DPR vs EU GDPR
ADGM Data Protection Regulations 2021 (Abu Dhabi Global Market (UAE free zone)) compared with Regulation (EU) 2016/679 (General Data Protection Regulation) (European Union (EEA)) on the same topics. Every value comes from the law pages, which link to the official sources.
| Topic | ADGM DPR Abu Dhabi Global Market (UAE free zone) 13/14 facts confirmed by two sources | EU GDPR European Union (EEA) ✓ Confirmed by two sources |
|---|---|---|
| Status | In force since 14 February 2021 (transition periods have ended).✓ | In force since 25 May 2018. Digital Omnibus amendments proposed Nov 2025, not adopted as of Oct 2026.✓ |
| Who it applies to | Processing by controllers/processors established in or operating out of ADGM, wherever the processing takes place, including outside ADGM.✓ | Any organisation processing personal data in the context of an EU establishment, plus non-EU organisations that offer goods/services to people in the EU or monitor their behaviour there.✓ |
| Size thresholds | Applies to all ADGM entities. Firms with fewer than 5 employees are exempt from DPO appointment unless they do high-risk processing.✓ | None — applies regardless of size. Limited record-keeping relief for organisations under 250 staff (Art 30(5)), lost if processing is risky, not occasional, or includes special-category or criminal data.✓ |
| Regulator | Commissioner of Data Protection, ADGM Office of Data Protection✓ | National data protection authorities (DPAs), coordinated by the European Data Protection Board (EDPB)✓ |
| Breach or incident reporting | Notify the Commissioner within 72 hours of becoming aware, unless unlikely to risk individuals' rights; explain any delay. Tell affected people without undue delay if the breach is high risk.✓ | Notify the competent supervisory authority without undue delay and within 72 hours of becoming aware, unless the breach is unlikely to result in a risk to individuals (Art 33). If you have an EU main establishment, that is your lead authority; if you have no EU establishment (even with an EU representative), notify the authority of every member state where affected people live (EDPB Guidelines 9/2022, para 73). Tell affected individuals without undue delay if the risk is high (Art 34).✓ |
| Deadline to answer personal data requests | Two months from receipt, extendable by one further month (three months in total) for complex or numerous requests; the person must be told of the extension within the first two months.✓ | 1 month from receipt; extendable by 2 further months for complex requests if the person is told within the first month. Free of charge unless manifestly unfounded or excessive.✓ |
| Data protection officer | Required in certain cases (e.g., high-risk processing). Need not be ADGM-based or an employee, but must have expert data protection knowledge.✓ | DPO mandatory for public bodies, and where core activities involve large-scale regular and systematic monitoring, or large-scale processing of special-category or criminal-offence data.✓ |
| Local representative | No separate representative requirement found; entities are ADGM-registered.✓ | Non-EU controllers/processors caught by Art 3(2) must appoint an EU representative in writing, unless processing is occasional, low-risk and excludes large-scale sensitive data, or they are a public body.✓ |
| Sending data abroad | Allowed to jurisdictions the Commissioner deems adequate (e.g., EU, UK), or with safeguards such as ADGM Standard Contractual Clauses or approved Binding Corporate Rules, or under derogations such as explicit informed consent or contract necessity.✓ | Transfers outside the EEA need an adequacy decision (e.g. UK, Switzerland, EU-US Data Privacy Framework), or safeguards such as Standard Contractual Clauses or Binding Corporate Rules, or a narrow Art 49 derogation.✓ |
| Cookies and consent | Being verified | Cookie/tracker consent is governed by the ePrivacy Directive Art 5(3); where consent is the GDPR legal basis it must be freely given, specific, informed, unambiguous and as easy to withdraw as to give.✓ |
| Maximum penalty | Administrative fines of up to USD 28 million; failing to pay the data protection fee can attract fines of up to 150% of the fee. Individuals can also claim compensation.✓ | Up to EUR 20 million or 4% of total worldwide annual turnover, whichever is higher (lower tier: EUR 10 million or 2%).✓ |
= confirmed by two independent sources, at least one official.
Facts marked “Being verified” are still being confirmed and are not given as answers.
Who each law applies to
- ADGM DPR
- Processing by controllers/processors established in or operating out of ADGM, wherever the processing takes place, including outside ADGM.
- EU GDPR
- Any organisation processing personal data in the context of an EU establishment, plus non-EU organisations that offer goods/services to people in the EU or monitor their behaviour there.
What you must do under ADGM DPR
- Register with the Office of Data Protection and pay the annual data protection fee.
- Report qualifying breaches to the Commissioner without undue delay, within 72 hours where feasible.
- Answer data subject requests within two months (extendable by one month).
- Appoint a DPO where required, e.g., for high-risk processing.
What you must do under EU GDPR
- Identify a lawful basis for every processing purpose and record it.
- Publish a clear privacy notice covering purposes, recipients, retention and rights.
- Keep a record of processing activities and sign Art 28 contracts with processors.
- Run a DPIA before high-risk processing such as large-scale profiling or sensitive data.
- Report qualifying breaches within 72 hours (lead authority, or every relevant DPA if you have no EU establishment) and log all breaches.
- Answer access, erasure and other rights requests within one month.
Information only, not legal advice. Laws change; confirm with the regulator or a qualified lawyer before relying on this page. Spotted an error? Email contact@