Free Zone Audit Requirement 2026: Every QFZP Needs Audited Accounts, at Any Revenue

The free zone audit requirement in 2026 is simpler than most articles make it: if you are claiming Qualifying Free Zone Person status to get 0% corporate tax on qualifying income, you must prepare audited financial statements. There is no revenue threshold. AED 100,000 of revenue, AED 100,000,000 — the obligation is identical.

That is the part that catches people who bought a licence for AED 4,999. The audit is a recurring professional fee attached to a product that was sold on a headline price, and no free zone in our dataset publishes what it costs.

Do free zone companies need audited financial statements?

If you are claiming QFZP status: yes, at every revenue level.

If you are a free zone company not claiming QFZP status, you fall under the general rule instead, and the general rule does have a threshold.

Ministerial Decision No. 84 of 2025 sets both positions. It applies to tax periods commencing on or after 1 January 2025. Ministerial Decision No. 82 of 2023 continues to govern earlier periods, which matters if you are cleaning up a FY2023 or FY2024 filing.

| Who you are | Audited financial statements required? | |---|---| | Qualifying Free Zone Person | Yes, regardless of revenue | | Taxable person not in a tax group, revenue above AED 50,000,000 | Yes | | Taxable person not in a tax group, revenue at or below AED 50,000,000 | Not on this basis | | Non-resident person | Threshold tested on revenue attributable to the UAE permanent establishment or nexus only |

The audited accounts requirement is not a side condition. It is one of the conditions of the QFZP regime itself, alongside adequate substance in the free zone, deriving qualifying income, complying with the arm's length principle, maintaining transfer pricing documentation, satisfying the de minimis test, and not having elected out. Fail one and you are outside the 0% regime. Our checklist of the QFZP conditions walks through all of them.

What did Ministerial Decision No. 84 of 2025 change?

It replaced a general rule with a general rule plus a carve-out that runs in the wrong direction for small free zone companies.

Under MD 84 of 2025, a taxable person that is not a member of a tax group prepares audited financial statements when revenue exceeds AED 50,000,000 in the tax period. That is a threshold most free zone startups will never approach.

Then the decision removes the threshold for Qualifying Free Zone Persons entirely. There is no AED 50 million exemption for a QFZP. The requirement attaches to the claim, not to the size of the company.

There is a further point for goods businesses: a QFZP distributing goods or materials from a Designated Zone must also comply with any additional procedures the Federal Tax Authority prescribes. Designated Zone status is a VAT concept and a separate research problem — our own Designated Zone flags derive from a secondary compilation of Cabinet Decision No. 59 of 2017 and its amendments, because the FTA's own guide was unreachable when we built the dataset. If your model depends on Designated Zone treatment, confirm the zone's status directly with the FTA rather than relying on any comparison site, including this one.

What does an audit obligation do to an AED 4,999 licence?

It changes the shape of the cost. The licence is an annual fee you can see. The audit is an annual professional engagement whose price is set by a firm, not by the zone.

Here are the cheapest licence packages in our dataset with an officially published AED price. Every one of these companies incurs an audit obligation the moment it claims QFZP status.

| Zone | Published starter price (AED) | Package | Provenance | |---|---:|---|---| | Ajman Media City | 4,999 | Business Club, zero visas | Official | | SRTIP | 5,500 | Zero Visa company licence | Official | | SPC Free Zone | 5,750 | E-commerce / trading / media starter | Official | | RAKEZ | 6,000 | Biz Starter | Official | | Shams | 6,500 | Trader Package | Official | | Innovation City (RAK DAO) | 6,600 | Idea package, no visas | Official |

Prices as published by each authority, cost_as_of: 2026-08-19.

Two zones publish a lower figure and are deliberately not in that table. KEZAD and Khalifa Port FTZ charge AED 0 for a new licence and AED 0 for registration; their only published setup fee is a AED 1,000 establishment card, against a mandatory land lease they do not publish. A company on that route still incurs the same audit obligation the moment it claims QFZP status — and the AED 9,350 KEZAD figure that circulates on consultancy sites appears nowhere in KEZAD's own tariff, so do not budget the audit against it.

We are not going to give you an audit fee range. No free zone authority in our dataset publishes one, and inventing an average is exactly the behaviour this site exists to correct. What we can tell you is the structure of the decision: the audit fee is charged annually, it is charged by an independent firm, it is not included in any of the six packages above, and it does not scale down to zero because your revenue is small.

For a company at AED 4,999 a year, the audit is plausibly a material fraction of total annual cost. Get a written quote from an audit firm before you commit to claiming QFZP status, and compare that number against the tax you would actually save. If your profit is below AED 375,000 and you are not claiming QFZP status, the standard regime taxes you at 0% on that band anyway under Cabinet Decision No. 116 of 2022 — in which case the audit is a cost with no corresponding benefit.

Which free zones publish an audit position?

Seven of the 40 zones in our dataset carry a conditional audit position. Thirty-three carry no value at all.

| Zone | Emirate | Basis for the "conditional" flag | |---|---|---| | Dubai Internet City | Dubai | Approved-auditor programme | | Dubai Media City | Dubai | Approved-auditor programme | | ADGM | Abu Dhabi | Published accounts-and-audit guidance for QFZPs, and exemption rules | | SAIF Zone | Sharjah | Approved-auditor programme | | HFZA | Sharjah | Approved-auditor programme | | SPC Free Zone | Sharjah | Approved-auditor programme | | Fujairah Free Zone | Fujairah | Published exemption and application rules |

Read that table with the caveat attached. These values are inferred — from the existence of approved-auditor programmes, and in the case of ADGM and Fujairah Free Zone from published exemption and application rules. They are not quoted from a primary regulation issued by each zone. ADGM is the best-supported of the seven: its own guidance, dated 25 August 2025, states that QFZPs must maintain audited accounts to keep the 0% rate.

The 33 zones with no value are a different statement. A blank means we found no source, not that no audit is required. That distinction is the whole point. Meydan Free Zone is one of the 33: it publishes an AED 12,500 Standard Digital Trade License and add-on visa pricing, and it publishes nothing we could find on audit. Nothing about that blank suggests a Meydan company escapes MD 84 of 2025. The federal rule applies regardless of what the zone's website says.

Which is the practical takeaway. The audit obligation is federal. The zone's approved-auditor list only tells you which firms it will accept, not whether you need one.

What should you do before your first financial year end?

1. Decide whether you are actually claiming QFZP status. Not aspiring to it — claiming it in your corporate tax return. The audit obligation follows the claim.
2. Get an audit quote in writing before the year end, not after. Firms price on scope, and scope is easier to agree while the year is still open.
3. Check whether your zone runs an approved-auditor list. If it is one of the seven above, your choice of firm is constrained.
4. Keep books that can be audited. Bank feeds, invoices, contracts, related-party agreements. Reconstructing a year in March is where the cost blows out.
5. Confirm which decision governs your period. MD 84 of 2025 for periods commencing on or after 1 January 2025; MD 82 of 2023 for earlier ones.
6. Ignore any zone or agent still selling ESR filings as part of a compliance bundle. Those filings were cancelled — we cover what actually changed in our piece on ESR.

Primary sources: Ministerial Decision No. 84 of 2025 on Audited Financial Statements (tax periods from 1 January 2025) · Ministerial Decision No. 82 of 2023 (earlier periods) · Federal Decree-Law No. 47 of 2022.