Most UAE businesses need an audit, but not all of them. The rules come from three places: the company law for mainland companies, the rules of your free zone, and the corporate tax law. If any one of them applies to you, you need audited accounts. If none of them does, the law does not force an audit, although a bank or an investor may still ask for one.
The four-question test
Answer these in order. A “yes” to any one of them means you need an audit.
- Are you a mainland LLC or a joint stock company? Yes means an audit every year.
- Is your licence from a free zone? Then check what your zone requires. Many ask for audited accounts at renewal or as an annual filing.
- Are you a Qualifying Free Zone Person (QFZP)? Yes means audited financial statements, whatever your revenue.
- Is your revenue above AED 50 million in the tax period, or are you part of a tax group? Yes means audited financial statements.
If all four answers are no, you are not required to have an audit under these rules. You still need to keep proper accounting records.
Mainland companies: the audit is in the company law
Article 27(1) of Federal Decree-Law No. 32 of 2021 says every joint stock company and every limited liability company must have one or more auditors who audit its accounts each year. The article does not mention company size or revenue, so it does not exempt small companies. An LLC with one shareholder and AED 200,000 in sales is covered in the same way as a large one.
The auditor is appointed by the shareholders each year at the annual general assembly (Articles 94 and 102). If your shareholders have never formally appointed an auditor, fix that first.
The same article says other company forms may appoint an auditor, but are not forced to. Sole establishments and freelancers are not LLCs, so this rule does not apply to them. Our guide to corporate tax for freelancers covers what does apply.
Free zones: each zone sets its own rule
A free zone company follows its authority’s rules, and those differ. Several large zones ask for audited accounts when you renew your licence, or as a yearly filing. A few only ask for them from companies that are also QFZPs.
Two examples:
- DMCC: audited financial statements go through the DMCC Member Portal within six months after the end of the financial year, signed off by a DMCC-approved auditor. DMCC can extend the window, so check the date shown in your own portal.
- DIFC: the auditor must be registered with the DIFC Registrar. Published guidance gives different filing deadlines for DFSA-authorised firms and for other DIFC companies, and the sources I checked do not agree. Ask the Registrar for the rule that applies to your entity type.
We found conflicting deadlines for several zones, so do not rely on a blog post, including this one, for your exact date. Get the current rule from your zone in writing.
A missing audit can hold up your licence renewal, which is one more cost on top of the ones we list in our trade license renewal guide.
What the corporate tax law adds
Ministerial Decision No. 84 of 2025 sets out who must prepare and maintain audited financial statements for corporate tax. It applies to tax periods starting on or after 1 January 2025, and it replaced Ministerial Decision No. 82 of 2023, which still applies to earlier periods.
| Who you are | Audited statements required? |
|---|---|
| Taxable person, not in a tax group, with revenue above AED 50 million in the tax period | Yes |
| Qualifying Free Zone Person | Yes, at any revenue |
| Tax group | Yes, audited special purpose statements in the form the FTA sets, whatever the revenue |
| Anyone else | Not under this decision |
Some details that matter:
- The test is revenue, not profit. A trading business with thin margins can pass AED 50 million and still make little profit.
- QFZPs have no size exemption. The audit is tied to the 0% claim itself. Our guide to Qualifying Free Zone Persons explains the other conditions.
- A tax group is audited even when it is small. A QFZP cannot be in a tax group, so these two categories never overlap. See our guide to corporate tax grouping before you combine entities.
- Non-residents: only revenue earned through a UAE permanent establishment or nexus counts toward the AED 50 million.
- The wording is “prepare and maintain”. The decision does not say you must file the audit with your tax return. You must have it ready if the FTA asks.
Audit first, then the tax return
Take a company with a 31 December year-end. A DMCC company has until 30 June for its audited accounts. The corporate tax return is due nine months after year-end, on 30 September. The numbers in the return should come from the audited statements, so in practice the audit has to be finished first. See our corporate tax filing deadline guide for the full date list.
Mix-ups we see in this topic
- “We are small, so we are exempt.” Size only helps under the AED 50 million rule. It does not help a mainland LLC or a QFZP.
- “We had no activity this year.” Free zones commonly still ask for accounts showing nil activity. Check with yours.
- “IFRS for SMEs means no audit.” Which accounting standard you use and whether you need an audit are separate questions. Below AED 50 million you can usually use IFRS for SMEs, and you still need an audit if one of the other rules applies.
- “Financial statements and an audit are the same thing.” Nearly every taxable person must keep records and prepare statements. The audit is the extra step.
- “Any auditor will do.” Some zones keep their own approved lists, such as DMCC-approved auditors and the DIFC register.
If you do not need an audit
You still need proper books. Banks often ask for audited or management accounts when you open or review an account, and investors ask too. If someone wants something lighter than a full audit, a targeted review may do. We explain the options in our guide to special audits.
What to do this month
- Write down your entity type and your free zone, if you have one.
- Check whether you hold, or plan to claim, QFZP status.
- Compare last year’s revenue with AED 50 million.
- Ask your free zone for its current audit rule and deadline.
- Appoint your auditor early and confirm they are on the right approved list.
If you want a second pair of eyes on which rules apply to your company, our audit services team can check it for you. You can also contact us directly.
The primary source for the tax rule is the Ministry of Finance text: Ministerial Decision No. 84 of 2025.
Frequently Asked Questions
Is audit mandatory for all companies in the UAE? No. It is mandatory for mainland LLCs and joint stock companies, for QFZPs, for taxable persons with revenue above AED 50 million, for tax groups, and for free zone companies whose zone requires it.
Does a small mainland LLC need an audit? Yes. Article 27(1) of the Commercial Companies Law requires every LLC to have its accounts audited each year, and the article has no size or revenue exception.
Do all free zone companies need an audit? It depends on the zone. Many large zones require audited accounts at renewal or as an annual filing. Every QFZP needs one for corporate tax, whatever its revenue.
Is the AED 50 million limit based on profit? No. Ministerial Decision No. 84 of 2025 uses revenue in the tax period.
Does a freelancer or sole establishment need an audit? Not under the company law, because these are not LLCs. Under the tax decision, only if revenue goes above AED 50 million.
Do I have to file the audit with my corporate tax return? The decision says audited statements must be prepared and maintained, not filed. Keep them ready in case the FTA asks, and in practice finish the audit before you prepare the return.
