In short
- Corporate tax rule: an audit above AED 50 million of revenue and for every Qualifying Free Zone Person.
- Every mainland LLC and joint stock company has its accounts audited each year, at any size.
- DMCC and RAKEZ want audited statements within six months of the year end. RAKEZ fines AED 2,500.
- A free-zone company that skips the audit loses the 0% rate for that tax period and the next four.
In this guide
Is an audit mandatory in the UAE? Who must be audited
No single rule decides who must be audited. Three sets of rules run side by side: the corporate tax law, the Commercial Companies Law for the mainland, and the regulations of each free zone. A company is audited when any one of them says so.
| Company | Audit required | Rule |
|---|---|---|
| Any taxable person with revenue above AED 50 million in the tax period | Yes | Ministerial Decision No. 84 of 2025 |
| Qualifying Free Zone Person, at any revenue | Yes | Ministerial Decision No. 84 of 2025 |
| Tax group | Yes: audited special purpose statements for the group | Ministerial Decision No. 84 of 2025 |
| Mainland LLC, public or private joint stock company | Yes, every year | Commercial Companies Law, Articles 27 and 102 |
| Mainland branch of a foreign company | Yes, and the accounts are filed every year | Commercial Companies Law, Article 338 |
| Free-zone company | Where the zone's regulations ask | Five zones are set out below |
| Sole establishment or freelancer | Only above AED 50 million of revenue | The tax rule alone |
The audit is the last step of a year of bookkeeping. We keep the books and prepare the file the auditor works from: see accounting services in Dubai and the UAE.
The corporate tax rule: AED 50 million of revenue and the free-zone 0% rate
Ministerial Decision No. 84 of 2025 names who prepares and keeps audited financial statements for corporate tax. It applies to tax periods that start on or after 1 January 2025 and replaced Decision No. 82 of 2023.
- Revenue above AED 50 million. The test is the revenue of the tax period itself, so a company can cross the line in one year and drop below it in the next. A foreign company counts only the revenue of its permanent establishment or nexus in the UAE.
- Qualifying Free Zone Person (QFZP). A free-zone company that pays 0% is audited at any revenue: audited statements are a condition of the 0% rate on qualifying income in a free zone.
- Tax group. The group prepares audited special purpose statements, which add the members' accounts together and remove the dealings between them, in the form the Federal Tax Authority sets.
The statements follow IFRS. A company with revenue up to AED 50 million may use IFRS for SMEs. One with revenue up to AED 3 million, the limit of Small Business Relief, may account on a cash basis.
Worked example: two free-zone companies with the same revenue
A trading company in a free zone has revenue of AED 8 million and claims 0% on its sales to other free-zone companies. It needs an audit. Without one it stops being a Qualifying Free Zone Person from the start of that tax period and for the four periods after it. It then pays 9% on taxable income above AED 375,000.
A consultancy in the same zone, with the same revenue, bills clients abroad and pays the standard rates. The tax rule asks no audit of it. Its zone may.
We register the company and prepare its return: corporate tax registration in the UAE.
Mainland companies: the Commercial Companies Law
Federal Decree-Law No. 32 of 2021 asks every limited liability company and every joint stock company to have one or more auditors who audit its accounts each year. Size plays no part: a one-person LLC with no sales is covered. Partnerships may appoint an auditor and are not obliged to.
- The partners appoint the auditor each year at the general assembly.
- The general assembly meets within four months of the end of the financial year, hears the auditor's report and approves the balance sheet and the profit and loss account.
- The first financial year runs from 6 to 18 months from registration, and each later year 12 months.
- A branch of a foreign company keeps its own balance sheet and profit and loss account and has an auditor registered in the UAE. Every year it sends the audited accounts to its licensing authority and the Ministry, with the accounts of its parent.
- The law leaves a free-zone company to the regulations of its zone.
Free zone audit requirements: DMCC, RAKEZ, JAFZA, DIFC and ADGM
Five free zones publish a rule that we checked in their own texts on 9 October 2026.
| Free zone | Who files | Deadline | Auditor |
|---|---|---|---|
| DMCC | Every member company, subsidiaries and branches included | Within six months of the financial year end, on the member portal with the auditor's summary sheet | On DMCC's list of approved auditors |
| RAKEZ | Every company incorporated in RAKEZ | Within six months of the financial year end; AED 2,500 if late | On RAKEZ's list of approved auditors |
| JAFZA | Every FZE and FZCO | Every year, through the Dubai Trade portal | Licensed by Dubai's economic department |
| DIFC | Every company; a small private company is exempt from the audit | Accounts prepared and audited within six months of the year end, then filed within 30 days of going to the shareholders | Registered as an auditor by the DIFC Registrar |
| ADGM | Every company and limited liability partnership | Accounts within nine months of the year end for a private company, six for a public one | An ADGM recognised auditor; a small company may file unaudited accounts |
Small means different things in the two financial centres. DIFC exempts a private company with turnover of no more than $5 million and no more than 20 shareholders, in the current year and the one before. ADGM sets the line at turnover of $13.5 million and 35 employees. RAKEZ adds that it does not ask for the statements at license renewal: the six-month date stands by itself.
A zone that publishes no rule still leaves its companies under the tax rule, and a bank or an investor can ask for audited accounts in any zone. We check the zone's current regulations with you before the first year closes.
Audit deadlines for a financial year that ends on 31 December 2026
| Obligation | Time after the year end | Date |
|---|---|---|
| Mainland LLC: general assembly with the auditor's report | Four months | 30 April 2027 |
| DMCC and RAKEZ: audited statements filed with the zone. DIFC: accounts audited | Six months | 30 June 2027 |
| ADGM public company: accounts filed | Six months | 30 June 2027 |
| Corporate tax return, resting on audited statements where the tax rule applies | Nine months | 30 September 2027 |
| ADGM private company: accounts filed | Nine months | 30 September 2027 |
Decision No. 84 first applied to the year 2025, whose tax return was due by 30 September 2026. Count back from the earliest date on your list. The auditor starts from closed books, so the bookkeeping for the year has to be finished first.
We do this for you Accounting in the UAE from $350 a month
What the auditor asks for
An audit tests the financial statements against the records behind them. Expect a request list on these lines:
- the trial balance and general ledger for the year, with last year's audited statements
- bank statements for every account, and the balances confirmed by the banks
- sales and purchase invoices, with the contracts behind the large ones
- lists of customers and suppliers with the amounts open at the year end
- the fixed asset register and the stock count
- payroll records and the Wage Protection System files
- VAT returns and the corporate tax computation
- dealings with owners and related companies, and the loan agreements
- the trade license, the memorandum of association and the resolutions of the year
The auditor gathers evidence by seven procedures named in the international auditing standard on evidence: inspection, observation, external confirmation, recalculation, reperformance, analytical procedures and inquiry. In practice the auditor reads documents, writes to your bank and your largest customers, recomputes totals and asks your accountant to explain the movements.
Who may sign the audit
The auditor must be on the register of practising auditors kept by the Ministry of Economy and Tourism. Registration runs for three years and requires five years of audit experience. A zone can narrow the choice. DMCC and RAKEZ accept firms on their own approved lists, DIFC and ADGM the auditors they register themselves, and JAFZA an auditor licensed by Dubai's economic department. Check the list before you sign the engagement letter: RAKEZ does not accept statements from a firm outside its list.
Records, fines and the cost of skipping the audit
| Rule | Figure | Source |
|---|---|---|
| Accounting records kept at the head office | Five years from the end of the financial year | Commercial Companies Law, Article 26 |
| Records behind the tax return | Seven years after the tax period | Corporate tax law, Article 56 |
| Records not kept | AED 10,000; AED 20,000 for a repeat within 24 months | Cabinet Decision No. 75 of 2023 |
| Audited statements late at RAKEZ | AED 2,500 | RAKEZ |
| Qualifying Free Zone Person without audited statements | 0% rate lost for the tax period and the next four | Ministerial Decision No. 229 of 2025 |
How to prepare for the first audit, step by step
- Establish which rules apply to you: revenue, tax status, legal form, zone.
- Fix the financial year in the memorandum and note the earliest filing date.
- Appoint an auditor from the right register or list, by a resolution of the owners.
- Close the books: reconcile every bank account, the receivables, the payables and the VAT.
- Prepare IFRS financial statements and hand over the documents on the request list.
- Answer the auditor's questions and sign the representation letter.
- Approve the audited statements, file them where the zone asks and keep them for the tax return.
We keep the books through the year, prepare the statements and answer the auditor for you: accounting for a UAE company.
