Category: TAX & COMPLIANCE

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UAE E-Invoicing Progress Report, October 2026. What Changed This Month and What It Means for Your Group

A year ago, the UAE’s e-invoicing system was mostly legislation and test environments. When the Ministry of Finance published its first list of pre-approved service providers on September 29, 2025, it carried five names. The Ministry’s register of fully accredited providers now lists 69. The pilot has been running since July 1, 2026, and businesses with revenue of AED 50 million or more have until October 30, 2026 to appoint one of those providers ahead of mandatory go-live on January 1, 2027

 

October has been the busiest month for the programme since the pilot opened. In the space of three weeks the Ministry announced two decisions that change how providers are approved, how companies in the same group invoice each other, where invoice data can be kept and how quickly certain invoices must go out. Neither decision moves a go-live date. Both change what a careful finance team should be checking between now and January.

Where the programme stands today01

The infrastructure has moved faster than most businesses. Here is the path from first provider list to go-live, with the dates that still lie ahead.

Date Milestone
Sep 29, 2025 Ministry of Finance publishes its first list of pre-approved service providers, with five names on it.
May 2026 Ministerial Decision No. 66 of 2026 moves the large-business provider deadline from July 31 to October 30, after a market readiness assessment. Go-live stays at January 1, 2027.
Jul 1, 2026 Pilot and voluntary adoption open on the five-corner model.
Sep 29, 2026 Federal Tax Authority confirms the October 30 and January 1 dates at a session attended by more than 700 participants.
Oct 1, 2026 Ministerial Decisions No. 168 and No. 197 of 2026 take effect.
Oct 9 and 19, 2026 The Ministry announces the two decisions.
Oct 30, 2026 Businesses with revenue of AED 50 million or more must appoint an accredited provider.
Jan 1, 2027 Mandatory e-invoicing starts for that group. The tax group exclusion begins the same day.
Mar 31, 2027 Provider deadline for businesses below AED 50 million and for in-scope government entities.
Jul 1, 2027 Mandatory e-invoicing starts for businesses below AED 50 million.
Oct 1, 2027 Mandatory e-invoicing starts for in-scope government entities.
Dec 31, 2028 The tax group exclusion ends.

Business readiness has moved more slowly than the system around it. A ClearTax survey of more than 500 UAE finance leaders, run in April and May 2026, put overall readiness at 57.5 percent and classed the market as still developing. ClearTax is an accredited provider itself, so that figure is best read as a direction of travel rather than an independent census. Its central finding matches what advisers across the market describe, which is that the problem has moved from awareness to execution.

Change one. Providers must now be fully accredited, with no halfway status02

Ministerial Decision No. 168 of 2026 replaced Ministerial Decision No. 64 of 2025 and every amendment made to it since. Its biggest effect is that the pre-approval stage is gone. A provider can now operate only once it has passed eligibility checks, interoperability testing, end-user verification, tax data reporting tests and production readiness, all before accreditation is granted. The Ministry tied this to the programme moving from development into live operation.

 

Providers that held pre-approval under the old framework were given 30 days from October 1 to complete the new requirements. If they do not, the Ministry has said their preliminary approval will be terminated. As of October 21, three firms were still listed on the Ministry’s register as under final assessment.

 

For a business, the practical consequence is simple. A sales deck that says “pre-approved” no longer means anything. Before signing, check the provider’s name and accreditation number against the Ministry of Finance register. And keep the two October deadlines separate in your head. The provider’s 30-day window and your own October 30 appointment deadline are different obligations, and a provider meeting its deadline does nothing to meet yours.

 

One more question is worth asking. The new decision still lets providers build on third-party Peppol technology and outsource parts of their service, while keeping full responsibility for compliance. That is a sensible rule, but it means two providers on the same register can look very different underneath. Ask yours which parts of the service it runs itself and who you call when an invoice fails validation at 6pm on a filing day.

Change two. Four amendments that lighten the load, each with a
condition attached 03

Ministerial Decision No. 197 of 2026 amends the core e-invoicing regulation, Ministerial Decision No. 243 of 2025. The Ministry announced it on October 19 and framed it as reducing the operational burden on businesses. That is fair, but every one of the four changes comes with a condition that is easy to miss.

01 01. Tax group transactions are excluded for two years

Transactions between members of the same Tax Group are treated as excluded transactions for 24 months from January 1, 2027, which takes the relief to December 31, 2028. This puts into law a grace period the Ministry had already signalled in its guidelines. The exclusion covers members of the same formal VAT Tax Group only. It does not cover every related-party or intercompany transaction, and once it expires the normal e-invoicing rules apply to those transactions in full.

02 02. Invoice data can now be stored outside the UAE

The earlier rule referred to storing e-invoices and credit notes within the State. That wording is gone. Businesses must still keep the records for the period set by the Tax Procedures Law and produce them for the Federal Tax Authority on request, so the test has moved from where the data sits to whether it can be retrieved. Sector rules have not moved with it. Central Bank rules still require banks to keep their master system of record in the UAE, and some government data carries its own hosting requirements.

03 03. The two-day system failure notice is gone

Businesses no longer have to notify the Federal Tax Authority within two business days when their e-invoicing system fails, because the Ministry has repealed the article that required it. The obligation to issue and transmit invoices correctly has not been repealed, so incident logs, provider escalation and recovery of stuck invoices still belong in your process.

04 04. A 14-day deadline moved to business days, but not for VAT invoices

The general issuance window under Article 6(5) changed from 14 calendar days to 14 business days. This is the amendment most likely to be misread. For VAT-registered issuers, the tax invoice timelines in the VAT Law still apply, which generally means 14 calendar days from the date of supply. A finance team that resets its system to 14 business days across the board could end up issuing tax invoices later than VAT law allows. The two timelines need to sit side by side in your invoicing rules, not replace each other.

What none of this, changes 04

The rollout dates are exactly where they were. Businesses at or above AED 50 million still go live on January 1, 2027, and the tax group relief is not a general two-year postponement. A PDF emailed to a customer is still not an e-invoice, because the Ministry defines an e-invoice as structured data exchanged between the two parties’ providers and reported to the tax authority. If you want the format side of that in detail, our PINT-AE explainer covers it, and our full mandate guide sets out the penalty framework.

The question every multi-entity group now must answer 05

For holding structures, the tax group exclusion is the most valuable change of the month and the easiest one to get wrong. It applies only to companies registered with the FTA as one VAT Tax Group under Article 14 of the VAT Decree-Law. Sharing an owner, a board or a building does not qualify. To form a group, every member must be a legal person with a place of establishment in the UAE, and the members must be related parties with control running between them. Individuals cannot be members, which matters for families that hold some property personally and some through companies.

 

That leaves a decision on the table for any group that bills heavily between its own companies. If you are not already a VAT group, two years of relief from e-invoicing your management fees and cost recharges is a genuine argument for forming one. It should not be the deciding argument, for two reasons.

 

The first is liability. VAT group members are jointly and severally liable for each other’s VAT, so a weaker entity’s exposure becomes everyone’s, and that liability can follow a company for the periods it was a member even after it leaves.

 

The second matters most for real estate. The lease of residential property is generally an exempt supply in the UAE once its first supply has passed, and exempt supplies cannot recover the input VAT linked to them. Bring a residential leasing SPV into a VAT group with commercial or service entities and the input tax recovery position of the whole group can shift. That cost would continue long after the e-invoicing relief has expired at the end of 2028.

 

So, the right order is to model the VAT position of the group first and treat the e-invoicing relief as a bonus on top, not as the reason. And whichever way you go, read December 31, 2028, as a deadline rather than a horizon. On January 1, 2029, every management fee, recharge and cost allocation between group companies will need to carry clean, structured, line-level data. Groups that use the next two years to fix their intercompany process will treat that date as a non-event. Groups that use the time to wait will meet it with two more years of habits to unpick.

What to check before October 30, and before January 1 06

For businesses in the first phase, the next nine days matter most. For everyone else, this is the same checklist on a longer runway.

  1. Confirm the phase for each entity, not just the group. The threshold is revenue, meaning gross income in the most recent accounting period, not profit.
  2. Verify your provider on the Ministry register by name and accreditation number and get its accreditation date in writing.
  3. Map every intra-group flow and mark which ones sit inside a formal VAT group, and which do not. Only the first set gets the 2027 to 2028 relief.
  4. Set two invoice timing rules, not one. VAT tax invoices follow VAT law. The 14-business day window applies to the rest.
  5. Check your storage arrangement against your sector rules, not only against the amended e-invoicing regulation.
  6. Test exchange and reporting end to end before routine invoices depend on it. Signing a provider contract is one step, and the Ministry’s own guidance expects integration and testing to follow it.

Where Unison Direct fits 07

An accredited provider moves the invoice. It does not decide which entity should raise it, what VAT treatment each line carries, or whether your group should be one VAT registration or six. That work sits with the finance function, and it is where most of the delays we see in e-invoicing projects begin.

 

Our Tax Compliance and Finance and Accounts Outsourcing teams prepare the data and the process your provider depends on. For groups running several entities, a Virtual CFO gives one person ownership of getting every company ready on the same timeline, and our Real Estate Investment Advisory team works through the VAT group question for property structures specifically.

 

If you would like a clear view before October 30, we will prepare a one-page e-invoicing entity map for your group. It shows which phase each company falls into, which intra-group flows the tax group exclusion covers and where your invoice data has gaps. Ask our UAE team for yours.

Frequently Asked Questions

No. Businesses with revenue of AED 50 million or more must still appoint an accredited provider by October 30, 2026 and go live on January 1, 2027. Businesses below that threshold go live on July 1, 2027.

It amends the UAE’s core e-invoicing regulation, Ministerial Decision No. 243 of 2025. It excludes transactions between members of the same Tax Group from January 1, 2027 to December 31, 2028, allows e-invoice data to be stored outside the UAE, repeals the two-business-day system failure notice, and moves one issuance window from 14 calendar days to 14 business days. It took effect on October 1, 2026.

It replaces the earlier accreditation rules for e-invoicing service providers and removes the pre-approval stage. Providers must now pass all assessment and testing before they are accredited, and previously pre-approved providers had 30 days from October 1, 2026 to complete the new requirements.

Only between members of the same formal VAT Tax Group, and only from January 1, 2027 to December 31, 2028. Related companies that share an owner but are registered for VAT separately do not qualify.

Yes, under the amended regulation, as long as records are kept for the period set by the Tax Procedures Law and can be produced to the Federal Tax Authority on request. Separate sector rules, such as Central Bank requirements for banks, still apply.

The Ministry of Finance register listed 69 fully accredited providers on October 21, 2026, with three more under final assessment. The list is updated regularly, so check it directly before appointing one.

Sources

  • Ministry of Finance, Ministerial Decision No. 197 of 2026 announcement, Oct 19, 2026
  • Ministry of Finance, register of e-invoicing Accredited Service Providers, checked Oct 21, 2026
  • Gulf News, UAE scraps e-invoicing pre-approval ahead of October deadline, Oct 13, 2026
  • Gulf News, UAE eases e-invoicing rules, Oct 19, 2026
  • GCC Business News, UAE updates e-invoicing accreditation rules, Oct 9, 2026
  • RTC Suite, key regulatory updates and revised accreditation rules, Oct 20, 2026
  • Thomson Reuters, Pagero listed as pre-approved provider (first list of five), Oct 2025
  • Gulf News, UAE launches e-invoicing pilot phase
  • Gulf Business, ClearTax UAE E-Invoicing Readiness Index 2026, Jun 23, 2026
  • Kayrouz and Associates, UAE VAT group registration eligibility
  • Crowe UAE, Tax Group registration in the UAE (joint liability, exempt member apportionment)
  • Tally Solutions, partial exemption and input VAT recovery in the UAE (residential lease exemption)
Categories
TAX & COMPLIANCE UAE Business Setup

Real Estate Funding Advisory in the UAE: How It Actually Works, and Why the Capital Stack Matters More Than the Bank Right Now

Dubai’s property market moved AED 291.7 billion across 87,800 transactions in the first half of 2026 alone, and 71 percent of that volume was off plan. Numbers like that make it easy to assume capital is everywhere, that any developer with a good plot and a strong concept can walk into a bank and walk out with a construction loan. The reality inside the deal is narrower than the headline. A bank will lend against a project once presales and completion have de-risked it. Before that point, most of the capital must come from somewhere else, and that somewhere else is exactly what real estate funding advisory in the UAE is built to solve.

 

Here is the mechanic that catches a lot of developers off guard, especially first-time ones. Off-plan buyers in the UAE are currently capped at a maximum loan to value of 50 percent regardless of who they are, and most banks will not release that mortgage money until the buyer has paid in half the unit price and the building itself has reached somewhere between 30 and 40 percent physical completion. That means the earliest, most capital hungry phase of a project, buying the land, mobilising the contractor, pouring the foundations, has almost no mortgage money behind it yet. Presale deposits help, and strong sales velocity genuinely does fund a project over time, but the timing rarely lines up cleanly with when the cash is needed on site. That mismatch, between when money is owed to the contractor and when money arrives from buyers and their banks, is the single most common reason a well-conceived project runs into a cash crunch it never needed to have.

What real estate funding advisory is

Real estate funding advisory is the discipline of closing that gap deliberately, before it becomes an emergency, rather than reacting to it once a contractor invoice is already overdue. In practice it covers a specific set of tasks, not a vague promise to “help with financing.”

 

It starts with the financial model, built to run the numbers under a few different scenarios, so a developer knows what happens to return if construction runs six months late or sales slow for a quarter, rather than finding out the hard way mid project. It includes putting together the investment memorandum and pitch materials a lender or equity partner needs to say yes, in the format they expect, not a generic deck reused from the last deal. It means sourcing the capital itself, debt and equity both, from a network of banks, private credit funds, and equity investors active in the UAE right now, rather than approaching whichever bank happens to have an existing relationship with the business. It means reviewing and negotiating the term sheet line by line, because the difference between a workable facility and a punishing one is rarely the headline interest rate, it is usually buried in the covenants, the drawdown conditions, and the exit fees. It means coordinating the lenders, valuers, lawyers, and tax advisors so they are working off the same numbers and the same timeline instead of five separate conversations moving at five different speeds. It means planning how funds flow at financial close, so the money lands where it needs to when it needs to. And it means staying on for the ongoing reporting and covenant monitoring once the facility is live, because a covenant breaches a lender finds before you have flagged it yourself is a very different conversation than one you bring to them first.

The capital stack, in plain terms

Most people outside real estate finance have heard the term capital stack without really knowing what sits inside it, so it is worth laying it out plainly, because each of the four common pieces solves a different problem.

 

Senior debt is the core layer, typically a bank loan secured directly against the project’s land and asset value, and it is the cheapest capital available because the lender’s risk is lowest, it gets paid back first if anything goes wrong. The trade-off is that banks are conservative about how much of total project cost they will cover, and they usually want meaningful presales already achieved and a clean, de-risked land position before they commit real money.

 

Bridge finance is short term, usually six to eighteen months, used to cover a specific gap rather than fund the whole build. A developer might use it to complete a land acquisition quickly, ahead of longer-term financing being arranged, or to cover a cash gap between one financial event and the next. It costs more than senior debt because it is faster to arrange and carries more risk, but it is priced for speed, not for the life of the project.

 

Mezzanine finance sits between senior debt and equity, and it is the layer that usually closes the gap described above, the money needed before presale and mortgage cash starts arriving in meaningful volume. It carries higher leverage than a bank will offer and more flexible repayment terms, in exchange for a higher cost of capital and sometimes a share of the project’s upside. For a developer who does not want to give up equity or bring in a full partner, mezzanine finance is often the more attractive route, provided the numbers still work once its higher cost is properly factored into the model.

 

Preferred equity behaves more like equity in how it is structured, there is no fixed repayment schedule the way debt has, but it sits ahead of ordinary equity in getting paid out, and it gives the investor stronger protection and a defined return target rather than open ended upside. It suits a developer who wants to keep control of the project and share less of the eventual profit than a full joint venture partner would take, while still bringing in capital that a bank’s own criteria will not stretch to cover.

 

None of these four exist to replace the others. A well-structured deal usually blends two or three of them, senior debt covering the base, mezzanine finance or preferred equity covering the gap, sometimes a short bridge facility solving one specific timing problem at the start. Getting that blend wrong, too much expensive capital, or too little flexible capital at the point it is needed, is what turns a fundable project into one that stalls halfway through construction.

 

To make this concrete, take an illustrative mid-size residential development in Dubai. This is not a real project, it is built here purely to show how the numbers typically sit together. Say total project cost is AED 120 million, split roughly between AED 30 million for the land and AED 90 million for construction and soft costs. A developer bringing 25 percent of that in as their own equity puts in AED 30 million. A bank, once satisfied with presales and the land position, might cover senior debt at around 55 percent of total cost, AED 66 million. That leaves a gap of roughly AED 24 million, 20 percent of the total, which is exactly where mezzanine finance or preferred equity typically sits, priced higher than the senior debt but still considerably cheaper than the developer giving up an equivalent slice of the project to a full equity partner instead. Structured well, that AED 24 million is the difference between a project that breaks ground on schedule and one that sits waiting for presales to catch up with the construction bill.

Why this matters more this year, not less

The backdrop makes structured funding advisory more relevant in 2026 specifically, not less. The UAE’s real estate, hospitality, and infrastructure sectors are among the areas driving the country’s projected 5.4 percent economic growth this year, and international private credit providers have become a genuinely active part of the local lending landscape, offering structures banks generally will not, construction finance without the same presale thresholds, for instance, though usually at a higher cost. Two pieces of legislation sit underneath that growing confidence and are worth knowing even without reading the text directly. The UAE’s Bankruptcy Law, in force since May 2024, created a dedicated Bankruptcy Court and a clearer insolvency process, and the Movables Security Law strengthened a lender’s ability to enforce a claim over receivables and other assets rather than land alone. Both make international lenders and funds meaningfully more comfortable extending real estate credit here than they might have been a decade ago, which is part of why the funding options open to a Dubai developer today are broader than a straightforward bank construction loan.

 

At the same time, the market has become more selective, not less, and that cuts in favour of developers who arrive with a properly structured funding plan already in hand. New project launches fell roughly 68.5 percent year on year in the first five months of 2026, and off-plan transaction volumes were down a smaller but still real 7.1 percent over the same period, even as overall transaction value for the year stayed strong. Buyers are reading the market more carefully too, weighing pricing, a developer’s actual delivery track record, and financing certainty before they commit, rather than buying on momentum alone the way an earlier cycle rewarded. A developer who can show a lender, or a buyer, a properly structured, fully funded capital plan is simply a more credible counterparty in a market like this than one who is still assembling the money as the project goes along.

Who this is for

This is not only a tool for large developers running several towers at once. Joint venture sponsors and landowners bringing a site into a partnership need the same discipline around term sheet negotiation and funds flow planning that a listed developer’s finance team already has in house. Asset managers and institutional funds evaluating a UAE real estate allocation need financial models and scenario analysis built to the standard their investment committee expects, not a back of envelope projection put together the week before a board meeting.

 

Family offices are a particularly active part of this market right now. The UAE is home to roughly 73 documented single family offices, 55 of them based in Dubai, and around 80 percent of them hold real estate as part of their portfolio, often across Dubai residential and hospitality assets alongside international holdings in London, wider Europe, and the US Sunbelt. A family office deploying its own capital into a development, or co-investing alongside a developer, needs the same rigour around deal structuring and covenant monitoring that an institutional fund would insist on, and a growing number are structuring those investments through ADGM or DIFC holding vehicles specifically because of the common law framework and investor protections that come with it.

 

Property companies scaling from one project to a genuine portfolio hit a point where raising capital project by project, on an ad hoc basis, simply stops working. What they need instead is a repeatable process, one relationship managing multiple lenders and multiple deals, rather than starting from a blank page every single time a new site comes up.

Why Unison Direct

Where this tends to go wrong with a purely transactional advisor is that the relationship ends at financial close. The term sheet gets signed, the funds are drawn, and the advisor moves on to the next deal, leaving the developer to manage covenant compliance, lender reporting, and cash flow forecasting alone from that point forward, often the exact area where a facility gets breached months later.

 

Unison Direct’s funding advisory work sits inside a broader finance function built for asset heavy businesses, so the financial model built to raise the capital is the same one used afterward to track covenant headroom and report to the lender, rather than two disconnected processes handled by two different teams that stop talking to each other after signing. That connects naturally into our Financial Planning and Analysis work, which keeps the numbers current once the facility is live, our Virtual CFO engagements for developers and family offices who want one person accountable for the whole finance function rather than assembling it piece by piece themselves, and our Real Estate Investment Advisory team for the underlying asset and structuring questions that usually sit alongside a funding decision, including whether the entity holding the project is even structured correctly for UAE corporate tax before the capital goes in. For businesses setting up the underlying vehicle for the first time, our Corporate Structuring and Business Set-Up and Tax Compliance teams handle that groundwork directly, before the funding conversation even starts.

 

If you are raising capital for a UAE real estate project, whether that is a first development, a portfolio scaling past what ad hoc financing can support, or a family office building out a direct real estate allocation, the honest first conversation is usually about the capital stack itself, not the pitch deck. Getting that structure right before approaching a lender or an investor is what makes the rest of the process move quickly, instead of stalling on questions that should have been answered earlier.

 

 Talk to our UAE team about your project or explore our Funding Advisory service in full. A short conversation is usually enough to tell you what your capital stack needs, and just as importantly, what it does not.

Frequently Asked Questions

Real estate funding advisory is the process of structuring, sourcing, and managing the capital a development project needs. It combines debt and equity from banks, private credit funds, and investors, then covers negotiating terms and coordinating everyone involved, from financial modelling through to financial close and the ongoing reporting that follows.

Bridge finance is short term funding, typically six to eighteen months, used to cover a specific timing gap such as completing a land purchase quickly. Mezzanine finance sits between senior debt and equity for the life of the project, offering higher leverage and more flexible terms than a bank loan, usually to fund the phase of construction before presale and mortgage cash starts arriving in volume.

It depends heavily on presales achieved, the land position, and the developer’s track record, but banks typically will not fund the full project cost on their own, especially in the earliest phase of construction. Off-plan buyer mortgages are currently capped at 50 percent loan to value regardless of buyer profile, and mortgage funds are usually not released until the buyer has paid in half the price and the building has reached 30 to 40 percent completion, which is why most projects blend senior debt with mezzanine finance or preferred equity rather than relying on one source.

Family offices deploying capital into UAE real estate, directly or alongside a developer, benefit from the same rigour around deal structuring, financial modelling, and term sheet review that an institutional investor would insist on, particularly as more UAE family offices structure these investments through ADGM or DIFC holding vehicles.

Timelines vary by deal size and complexity, but a properly prepared financial model and investment memorandum meaningfully shortens the process, because most delays come from lenders requesting information that was not ready rather than from the lending decision itself. Starting the funding conversation before construction is due to begin, rather than once cash is already needed on site, is what keeps the timeline realistic.

Deal structuring and capital strategy, financial modelling and scenario analysis, preparing the investment memorandum and pitch materials, sourcing debt and equity capital, reviewing and negotiating term sheets, coordinating lenders, valuers, legal, and tax advisors, planning funds flow at financial close, and ongoing reporting and covenant monitoring once the facility is in place.

Because the earliest and most capital intensive phase of a project, land acquisition and the start of construction, happens before most of the funding sources a developer expects to rely on are actually available. Presale deposits build gradually, and buyer mortgages are capped and do not release until the project is already 30 to 40 percent complete, which leaves a funding gap in the exact period when the contractor still needs to be paid.

sources

  • Funding Advisory Services, UAE
  • Financial Planning and Analysis, UAE
  • Virtual CFO Services, UAE
  • Real Estate Investment Advisory, UAE
  • Corporate Structuring and Business Set-Up, UAE
  • Tax Compliance Services, UAE
  • Contact, UAE
Categories
TAX & COMPLIANCE UAE Business Setup

The Dubai Free Zone to Mainland Deadline Has Passed. Here Is What Happens Now

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.

Frequently Asked Questions

It is the Dubai law that allows free zone companies to legally operate in mainland Dubai, through a branch license, a dual license, or a temporary permit, instead of requiring a separate mainland entity or local agent. It took effect March 3, 2025.
March 3, 2026, one year after the resolution took effect. This applied to free zone companies that were already conducting mainland business before the resolution existed.
The resolution allows for fines, penalties, or revocation of authorization to operate outside the free zone. A one time extension was available, but only for businesses that applied before the original deadline, not after it passed.
Yes. The three license pathways, branch license, dual license, and temporary permit, remain open on an ongoing basis. What changed is that businesses already trading informally in the mainland before March 2025 no longer have the one year grace period, they now need to regularize as a matter of urgency rather than routine planning.
Free zone income keeps the 0% corporate tax rate. Income from mainland operations is taxed at the standard 9% rate, and the business must keep separate financial records to prove which income falls where.
No. None of the licenses or permits under Resolution 11 of 2025 authorize trading in any other Emirate. Abu Dhabi has its own, separate dual licensing framework, introduced in February 2025.
No. Dubai International Financial Centre entities and other financial free zone institutions are excluded from Resolution 11 of 2025 entirely. If your business is licensed through DIFC, this framework does not apply to you, and any mainland activity would need to be assessed under separate DIFC and federal rules.

sources

  • Financial Planning and Analysis, UAE
  • Virtual CFO Services, UAE
  • Real Estate Investment Advisory, UAE
  • Corporate Structuring and Business Set-Up, UAE
  • Tax Compliance Services, UAE
  • Contact, UAE