ADX INVESTOR RELATIONS GUIDANCE

The Abu Dhabi Securities Exchange has published a new Investor Relations Guide (the “2026 Guide“), which updates and consolidates the guidance previously set out in the 2022 Investor Relations Guidebook (the “2022 Guidebook“). The 2026 Guide sets out, for the first time, a consolidated set of six minimum requirements supported by a structured assessment and enforcement regime. It also provides materially expanded guidance across all areas of investor relations practice. The underlying disclosure obligations are contained in the ADX Rules Book, the AD CSD Rule Book and applicable CMA guidelines; the 2026 Guide does not replicate that regulatory framework but provides practical guidance on compliance. This alert summarises the principal changes and identifies some of the practical steps that listed companies should consider in response.

Six Formal Minimum Requirements

The 2026 Guide introduces six minimum requirements applicable to all listed companies, covering:

• the appointment of a designated IR officer and submission of a signed ADX IR Commitment Form;
• maintenance of a dedicated IR webpage with contact details and at least three years of archived financial reports;
• an investor presentation updated every six months and filed with ADX when updated;
• timely disclosure in accordance with ADX Disclosure Rules, submitted as OCR-compatible searchable PDFs and published bilingually in Arabic and English;
• periodic financial reporting within 45 days of period end (quarterly for Main Market companies and semi-annually for Growth Market companies), accompanied by a Management Discussion and Analysis; and
• annual reporting obligations, including a combined annual report and, for Main Market companies, preliminary unaudited annual KPIs within 45 days of fiscal year end.

Assessment and Enforcement

The 2026 Guide introduces a two-stage assessment process.

• The first stage is a pass/fail compliance check against the minimum requirements. Failure at this stage disqualifies the company from eligibility for recognition or awards in the relevant assessment year, regardless of performance in other areas.
• The second stage is a best-practice score covering matters such as earnings call quality, availability of recordings and transcripts, the analyst data pack, and the currency of the investor presentation.

The Guide states expressly that failure to meet the minimum requirements results in warnings and/or monetary penalties. Penalties are specified in warning letters issued to the non-compliant company and are applied to annual listing renewal fees at ADX management’s discretion, calibrated to the severity of non-compliance.

Disclosure and Compliance

The 2026 Guide devotes a dedicated chapter to disclosure and compliance, going considerably further than the 2022 Guidebook’s brief regulatory overview. It introduces a materiality test, a prescribed material disclosure sequence, and a formal quiet period regime. Document standards require OCR-compatible searchable PDFs, and the Guide recommends that companies adopt electronic signature processes in place of wet-ink signatures. On insider trading controls, the Guide requires companies to maintain an insider list and sets out detailed protocols for handling rumours. Separately, ADX encourages insiders to register for a National Investor Number. Once registered, insiders are subject to automatic broker-level trading blocks during quiet periods. Practical tools new to this guidance include an Ad Hoc Disclosure Checklist and an Insiders’ Register Disclosure Template.

Reporting Deadlines and the IR Calendar

• The 2026 Guide sets out an indicative table of ADX deadlines covering quarterly and annual financials, dividend disclosure, material news, and board meeting notices. It also specifies AGM procedure in considerably greater detail:
• the board meeting that considers the AGM invitation must take place at least 30 days before the AGM;
• audited annual financial statements must be disclosed before the CMA approves the invitation;
• the AGM invitation must be published at least 21 days before the meeting; and
• the AGM must ordinarily be held within four months of financial year-end.

Combined Annual Report

• The 2026 Guide formalises the combined annual report as a single mandatory consolidated document. For Main Market companies, it must comprise six components:
• the Board of Directors’ Report;
• the external auditor’s report;
• audited annual financial statements and notes;
• a corporate governance report;
• a sustainability report; and
• where applicable, an Internal Shari’ah Supervisory Committee report.
• Growth Market companies are not required to include the corporate governance or sustainability reports.
• The bilingual combined annual report must be filed as an ADX disclosure by the earlier of 90 days after financial year-end or at least 10 days before the AGM, and must be filed before being published on the issuer’s own website.

Updated IR Obligations and Best Practices

The 2026 Guide introduces substantial new guidance not present in the 2022 Guidebook. On digital presence, for example, it sets more specific standards than the 2022 Guidebook’s sixteen-point best-practice list, including minimum content requirements and a mandatory bilingual equivalence standard. Material disclosures must be published in both Arabic and English. Beyond these minimum requirements, the Guide identifies a number of best practices for companies aspiring to a “world-class” standard. These include a navigation standard under which key information should be accessible within two clicks of the homepage, professional financial translation, and simultaneous publication of Arabic and English versions of material disclosures.

Practical Implications for Listed Companies

Listed companies should treat the 2026 Guide as materially raising the compliance bar. Companies should conduct a gap assessment of their current arrangements against the six minimum requirements. Disclosure workflows should be reviewed to ensure compliance with the prescribed sequence, format, and approval trail. Quiet period policies and insider list discipline should be formalised where they are not already. Companies should also confirm that their combined annual report process produces a single consolidated document incorporating all required components, correctly sequenced ahead of the AGM. Companies may also wish to benchmark their broader IR practice against the frameworks set out in the 2026 Guide.

How Can We Help

The 2026 Guide consolidates and raises the practical compliance expectations applicable to ADX-listed companies, complementing the binding obligations set out in the ADX Rules Book, the AD CSD Rule Book and applicable CMA guidelines. Early engagement with the new framework will be important not only for companies seeking to avoid penalties but also for those looking to enhance their standing in ADX’s recognition process.

Our equity capital markets team regularly advises listed companies, IPO candidates, and investors on UAE capital markets matters across onshore markets and financial free zones. We assist clients with both transactional and ongoing regulatory matters. This includes assessing the impact of the 2026 Guide on existing IR programmes, preparing gap analyses against the new minimum requirements, updating disclosure and governance frameworks, and advising on practical implementation.

If you would like to discuss how these changes may affect your business or IR programme, please get in touch with our equity capital markets team.