The Restricted Scope Company (RSC) is a private company form under the ADGM Companies Regulations 2020 that allows a degree of confidentiality around shareholding disclosure on the public register. The RSC is not anonymous — full UBO disclosure to the Registration Authority remains mandatory — but the publicly searchable register shows limited information, with detail held confidentially by the regulator.
Eligibility.
The RSC has restricted eligibility:
- Family vehicle — holds the wealth of a single family.
- Subsidiary of a group holding company — where a wider group structure requires a UAE intermediate entity.
Generic confidentiality interest is not a sufficient basis.
What is and is not confidential.
| Information | Public register | Registration Authority |
|---|---|---|
| Company name, registered office | Public | Disclosed |
| Shareholders | Restricted | Full disclosure |
| Ultimate beneficial owners | Not public | Mandatory UBO filing |
| Annual filings | Restricted | Full filing |
CSP requirement.
RSCs must appoint a Company Service Provider. The CSP handles AML/CFT screening, UBO disclosure to the Registration Authority, annual filings and day-to-day liaison.
Use cases.
Single-family wealth vehicle. An UHNW family establishing a UAE holding structure with succession, security or business-confidentiality considerations uses an RSC at the family-holding layer. Operating subsidiaries and asset-specific SPVs sit under the RSC as standard ADGM SPVs.
Group intermediate holding. A multinational group placing a UAE-based intermediate holding company uses an RSC to limit publicly searchable disclosure about the UAE entity's ownership chain. Group-level corporate transparency commitments under home-state law continue to apply.
RSC versus standard Private Company.
| Feature | RSC | Private Company |
|---|---|---|
| Public shareholder disclosure | Restricted | Public |
| UBO filing | Mandatory (confidential to RA) | Mandatory (confidential to RA) |
| Eligibility | Family vehicle or group subsidiary | General |
| CSP requirement | Mandatory | Not generally |
| Commercial activity | Permitted | Permitted |
Conclusion.
The ADGM RSC is the right structure for family or group holdings with a legitimate confidentiality interest. The confidentiality is real but bounded — UBO disclosure to regulators continues. Neo Legal supports families and groups across RSC structuring.
