Sourced provisions
Every legal rule this system relies on is bound to a specific document, at a
specific version, with a recorded content hash. Nothing is cited from memory,
and the feasibility engine will not return a favourable verdict from a rule
whose source is absent — that is a theorem, eval_unsourced_never_feasible,
not a policy.
This page is the provenance record. It exists so that you can confirm we are reading the same text you are.
The documents
| Document | Version | Date | sha256 (first 16) |
|---|---|---|---|
| FSMR — Financial Services and Markets Regulations 2015 | consolidated v28 | 31 Oct 2025 | 610a8376bd663c69 |
| COBS — Conduct of Business (incl. ch. 19A, Fiat-Referenced Tokens) | v23 | 29 Apr 2026 | 64bc235a121de848 |
| FUNDS | v12 | 29 Apr 2026 | 911df5231be866f7 |
| MKT — Market Rules | v09 | 2 Jan 2025 | b251abff93f0c719 |
| MIR — Market Infrastructure | v11 | 31 Oct 2025 | c96624e21160058b |
| GEN — General Rulebook | v14 | 21 May 2026 | 11c35c9290749b24 |
| GLO — Glossary | v28 | 21 May 2026 | a5cc65902b20ab1f |
| ETR — Electronic Transferable Records Regulations | 2021 | — | 53b2eab87a567575 |
| Guidance — Regulation of Digital Securities Activities | — | — | 78aef16af29a2e39 |
| Guidance — Private Financing Platforms | ver. 20231218 | — | 1c92296059f32bbb |
Where to get them. The rulebooks are published on the ADGM rulebook portal
at en.adgm.thomsonreuters.com/rulebook — FSMR is
here,
and the other rulebooks are reachable from the same portal. The two guidance
documents are direct PDFs on adgm.com: digital
securities
and private financing
platforms.
The FRT framework itself was announced
here.
To check you have our text, run sha256sum on the PDF and compare to the
table. If the hash differs, the version differs, and any compliance conclusion
bound to our hash is provably stale — material_legal_change_stales_compliance_certificate
is exactly this situation as a theorem.
One practical note: the rulebook portal rejects automated fetches, so the documents must be downloaded through a browser rather than scripted.
Fiat-referenced tokens — COBS chapter 19A
This is the chapter that governs the payment leg. Encoded at provision level:
| Provision | Content | Role in the system |
|---|---|---|
| 19A.2.1, 19A.2.3 | white paper submitted 20 days prior; published | a gate on launch |
| 19A.3.1 | issuer restricted from non-incidental Regulated Activities | why the issuer may not also run the venue |
| 19A.3.2 | no AED-denominated FRT | an outright prohibition, not a condition |
| 19A.4.1(1)(b)(i) | redemption at par, no later than T+2 | why the payment leg has no queue at all |
| 19A.4.1(3) | the period may be extended on notification to, or direction from, the Regulator | the only lawful route to a longer period |
| 19A.5.2, 19A.5.3, 19A.5.5 | reserve form (client / non-objected reserve accounts), par-currency denomination, prior notice of composition change | reserves are not protocol capital |
| 19A.6.1 | segregation per token | |
| 19A.7.1 | reserve value ≥ outstanding claims, at all times | the full-backing invariant; isFullyBacked() |
| 19A.7.2 | valuation each day | the operational duty on top of the invariant |
| 19A.7.3 | breach notification | what the issuer owes the FSRA on a failure |
| 19A.8.1–.8.3 | liquidity stress testing, large-scale redemptions | the run scenario is of this class |
| 19A.9.1(b)(iv) | monthly independent attestation, including a random-day reserve test | how you verify |
| 19A.9.2 | publication of that attestation | |
| 19A.10 | annual independent audit of reserve composition and controls | |
| 19A.11.1, .2, .4, .6 | holder claims on liquidation — holders first, capped at par | the waterfall contract |
Sourced but deliberately not encoded: 19A.5.1 (chapter 14/15 cross-application), 19A.5.4 (Regulator-directed divestment), 19A.11.3 (directed liquidation), 19A.11.5 (insolvency and Pooling-Event payment ordering). These are in the text we hold and are not represented in the model; they are listed here so the gap is visible rather than silent.
Classification and permissions — FSMR
| Provision | Content | Role |
|---|---|---|
| s.258 | definition of a Fiat-Referenced Token | the payment leg meets it mechanically — no interpretation left in the definitional question |
| s.106(1)–(3) | definition of a Collective Investment Fund: arrangements, contributions pooled, property managed as a whole | why one SPV per facility, not a pool |
| Schedule 1 | Units in a Collective Investment Fund are Securities; Managing a CIF is a Regulated Activity | the permission that a pooled token would require |
The fund route — FUNDS
Applies only if the pooled structure is used. The qualified-investor route:
| Provision | Content |
|---|---|
| 1.1.1(a) | the Managing a Collective Investment Fund activity gate — the provision the blocker cites |
| 3.3.4 (with 15.1) | the qualified-investor conditions: exempt-offer placement, professional clients, minimum subscription |
| 15.1.2 | ongoing maintenance of those conditions, and the consequence of breach |
| 6.2.2 | notification to the Regulator (a notification route, not the s.107 registration required of Public Funds) |
| 12.2.1 | management per the Fund's Constitution and its most recent prospectus |
| 15.3.1 | legal title to Fund Property with an Eligible Custodian |
Offers and venue
| Provision | Content |
|---|---|
| MKT 4.3.1(1) | the Exempt Offer route — the offer leg of the SPV note structure |
| MIR 2.15.1 | the venue permission gate, with five named ongoing obligations |
What remains open
Three things, stated plainly because they bound every legal claim on this site:
- The fund-side (pooled) route is resolved, and it is closed. FUNDS v12 is
sourced, hashed and parsed to provision level, and the route evaluates to
provedInfeasiblewith the blocker named: the fund-manager permission (FSMR Schedule 1; FUNDS 1.1.1(a)). That is a resolved status under this framework — the system knows the answer, and the answer is no. The closure path is proved: it opens if the permission is held. - Documentary-credit wrappers rest on ICC texts (UCP, URC, URDG, URF) that we have not fetched. The corresponding rows in the coverage matrix stay failed rather than being upgraded on assumption.
- Islamic instruments are source-gated. Six archetypes have records; none is instanced, because shariah rulings are interpretation-class premises and no AAOIFI source has been supplied.
See the ADGM position for which routes currently resolve, and why one SPV per claim for the structural consequence.