If your free zone company was already doing business in mainland Dubai without a mainland license, you had until March 3, 2026, to regularize that status under Executive Council Resolution No. 11 of 2025. That date is now more than five months behind us. If you missed it and have not applied for an extension, you are currently operating outside the rules, and the fix is more urgent than most of the guidance still circulating online suggests.
Most articles on this topic were written last year, when the deadline was still ahead. They tell you to act “before March 2026.” That advice is stale. This one picks up from where those left off: what the deadline meant, why the date passing changes your risk position rather than removing it, and what a business with real assets in the UAE, particularly in real estate, should do this month.
What Resolution 11 of 2025 changed
Before this resolution, a company licensed in a Dubai free zone could not legally trade in mainland Dubai. To reach mainland customers, it needed a separate mainland entity, a local service agent, or a distributor. Most of that workaround infrastructure existed because there was no direct legal path, not because businesses wanted the extra layer.
The resolution, effective March 3, 2025, opened three direct paths from free zone to mainland. A standard branch license lets a free zone company open a full branch onshore. A dual license lets the branch trade in the mainland while the compny itself stays registered and headquartered in the free zone, at a cost of AED 10,000 a year, renewable annually. A temporary permit covers short, defined mainland activity for up to six months, at AED 5,000.
All three routes fall under the Department of Economy and Tourism, which was also tasked with publishing a full list of mainland activities eligible under this framework. Multiple advisory firms report that list as still evolving rather than finalized, with DET adding sector approvals over time rather than issuing one closed document. If your activity is not clearly on record with DET yet, that is worth resolving before you assume you are covered.
One boundary matters for anyone weighing this against other Emirates: none of these licenses let you trade outside Dubai. Abu Dhabi has a separate dual licensing framework introduced in February 2025. The two are not interchangeable, and content or advice that blends them together is a sign the writer has not read the actual text.
The deadline was March 3, 2026. Here is where things stands
Companies that were already conducting mainland business informally, before the resolution existed, were given one year to regularize. That gave a deadline of March 3, 2026. The resolution allows DET to grant a one-time extension, but the application for that extension had to go in before the original deadline, not after.
That means there are now three categories of business, and they are in very different positions. If you regularized before March 3, 2026, you are compliant and this article is background reading. If you applied for an extension before the deadline, you should have a defined new date from DET and a live application on file. If neither happened, and you are still trading in the mainland on a free zone license, you are currently unauthorized, and the resolution states that non-compliance can lead to fines, penalties, or revocation of your authorization to operate outside the free zone.
We have not found confirmed public reporting of a blanket, sector wide extension issued after the deadline. Treat any claim that “everyone automatically got more time” with caution unless it points to an actual DET notices and check directly with DET or your free zone authority rather than relying on secondhand blog posts, this one included, for your specific standing.
The practical takeaway is simple. If you are unsure which of the three categories your business falls into, that uncertainty is itself the risk. Five months past a compliance deadline is long enough that “we were going to get to it” stops being a reasonable answer if DET asks.
This is not only a problem for companies planning a mainland move
A common mistake is assuming this resolution only concerns businesses that are deliberately expanding into the mainland. In practice, the trigger is any mainland activity, not intent. A free zone company that invoices mainland clients directly, sends staff to work from a mainland office, signs mainland contracts, or holds meetings that count as conducting business outside the zone can already meet the bar for needing a license under this framework, even if nobody at the company thought of it as “expanding.”
If your operations are genuinely contained within your free zone, with no mainland clients, contracts, or presence, this resolution does not require anything from you. But that is a factual question about how the business actually operates day to day, not an assumption to make from the office. It is worth a short internal review rather than a guess, especially for groups that have grown through several free zone entities over the years and may not have a single clear picture of where each one is actually trading.
The tax line you cannot afford to get wrong
Free zone income keeps its 0% corporate tax rate under this framework. Income earned through mainland operations is taxed at the UAE’s standard 9% rate. That split sounds simple until you have to prove it, and proving it is exactly what the resolution requires: separate, auditable financial records for mainland activity versus free zone activity, ready to be reviewed by the Department of Economy and Tourism.
This is where a lot of otherwise compliant businesses get exposed, not because they ignored the resolution, but because their finance function was never built to split income cleanly between two tax treatments. If your general ledger, invoicing, and reporting were not restructured when you started mainland activity, the tax exposure is not theoretical, it is sitting in your books right now waiting to be found in an audit.
Picture a services company with AED 8 million in free zone revenue and AED 2 million now coming through a new mainland branch. Handled correctly, only that AED 2 million sits at 9%, and the tax bill is straightforward to defend. Handled with one shared ledger and no clear split, DET has grounds to question the whole AED 10 million, and the business is negotiating from a position of doubt rather than proof. The difference between those two outcomes is not the resolution itself, it is whether the finance function was rebuilt before the mainland activity started, not after DET asks for the records.
This is precisely the kind of structural work our Financial Planning and Analysis and Virtual CFO teams do for clients in Dubai, building the reporting structure that keeps 0% and 9% income visibly, defensibly separate, before an audit forces the question.
What this means if you hold real estate assets
Real estate groups are a special case worth naming directly, since so much of this market runs through free zone holding structures. A group that holds property through a free zone entity but manages leasing, development, or facilities activity that touches the mainland, directly with tenants, contractors, or buyers, can fall inside this resolution without having restructured anything on paper.
The stakes are higher here than for a services business, because real estate income tends to be large, concentrated, and easy for a regulator to trace back to a specific asset. A holding structure that made sense in 2022 may now need a second look, not to be dismantled, but to make sure the parts of the operation that genuinely touch the mainland are licensed to do so, and the parts that do not are documented as staying inside the free zone. Our Real Estate Investment Advisory team works through exactly this kind of structural review with asset owners.
Three questions to answer before you do anything else
Before engaging a lawyer, a free zone authority, or an accountant, a business owner or CFO should be able to answer three questions with certainty, not with a best guess.
First, does any part of the business actually operate in the mainland today, through clients, staff, contracts, or premises, regardless of what the original free zone license says. Second, if the answer to the first question is yes, has the business applied for a license, a permit, or an extension, and is there a paper trail proving it. Third, are the financial records for mainland and free zone income currently separated well enough to survive a DET audit without weeks of reconstruction work.
If you cannot answer all three cleanly, that is the actual starting point, not a market comparison of free zone against mainland. Our Corporate Structuring and Business Set-Up and Tax Compliance teams handle this assessment directly and can tell you within a short engagement exactly where you stand against the resolution.
How Unison Direct helps
We work with mid-market and asset heavy businesses across the UAE on the finance side of exactly this kind of regulatory shift, from structuring the entity to building the reporting that keeps you compliant afterward. That covers Financial Planning and Analysis, Virtual CFO support, Finance and Accounts Outsourcing, and the tax and business setup work this resolution now touches directly.
If you are unsure where your business stands against Resolution 11 of 2025, or you know you are past the deadline and need a clear plan, talk to our UAE team. A short conversation is usually enough to tell you whether this is a paperwork fix or a structural one.
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