Audit Requirements for UAE Companies Under Corporate Tax.

Before Corporate Tax, the question "do we need an audit?" was answered by company law or by your free zone. Corporate Tax added a third layer. The three overlap, and a business can be caught by one and not the others.

The rule in force: Ministerial Decision No. 84 of 2025

The Corporate Tax Law lets the Minister decide which taxable persons must prepare and maintain audited financial statements. The current decision is Ministerial Decision No. 84 of 2025, issued on 25 March 2025. It applies to tax periods starting on or after 1 January 2025.

It requires audited financial statements from:

• Any taxable person with revenue above AED 50,000,000 in the relevant tax period, other than a Tax Group.
• Every Qualifying Free Zone Person, whatever its revenue.
• Every Tax Group, which must prepare and maintain audited special purpose financial statements in the form the FTA specifies.

For a non-resident person, only revenue earned through a permanent establishment or nexus in the UAE counts towards the AED 50,000,000 threshold. "Revenue" in the Corporate Tax Law means the gross amount of income derived during a tax period, so the test is on the top line, not profit.

Ministerial Decision No. 82 of 2023, the earlier rule, is repealed but still applies to tax periods that started before 1 January 2025. Under it, the categories were revenue above AED 50,000,000 and Qualifying Free Zone Persons. The FTA's clarification CTP007 confirms that, under the old rule, a Tax Group needed audited statements only where its consolidated revenue exceeded AED 50 million. From 2025 periods, every Tax Group needs them.

Tax Groups

A Tax Group files as one taxable person, so it prepares aggregated financial statements: the standalone statements of the parent and each member, added together, with transactions between members eliminated. The FTA says these follow a special purpose framework, must undergo a special purpose audit under the International Standards on Auditing, and must be submitted with the Tax Return. Members do not need their own audited standalone statements for Corporate Tax, even where a member's revenue exceeds AED 50 million.

Which accounting standards apply

Ministerial Decision No. 114 of 2023 sets the standards for Corporate Tax:

• IFRS is the default.
• IFRS for SMEs may be used where revenue does not exceed AED 50,000,000.
• Cash basis accounting is allowed where revenue does not exceed AED 3,000,000, or in exceptional circumstances on application to the FTA.

A business that needs an audit should agree its accounting framework with its auditor early. Changing it at year end is much harder.

Record keeping

The Corporate Tax Law requires records and documents that support your tax return, and that let the FTA readily work out your taxable income, to be kept for seven years after the end of the tax period they relate to. The Commercial Companies Law separately requires every company to keep its accounting registers at its head office for at least five years from the end of the financial year. For Corporate Tax, the longer period is the one to plan around.

Company law and free zone audits

Corporate Tax is not the only reason to have an audit. Article 27 of the Commercial Companies Law (Federal Decree-Law No. 32 of 2021) says every joint stock company and limited liability company must have one or more auditors to audit its accounts each year, and must prepare annual accounts using international accounting standards. Other company forms may appoint an auditor.

That law does not apply to free zone companies where the free zone's own laws or regulations say so, unless they are permitted to operate outside the free zone. Free zone companies should check the rules of their own free zone authority, which may set separate audit or filing requirements.

The practical point: an audit required by company law or a free zone does not replace the Corporate Tax rule, and a business below the Corporate Tax threshold may still need an audit for other reasons.

A worked example

"We run three companies: a mainland LLC with revenue of AED 12 million, a free zone company with revenue of AED 4 million that is a Qualifying Free Zone Person, and a trading company with revenue of AED 65 million. None are in a Tax Group."

• Mainland LLC, AED 12 million. No Corporate Tax audit requirement, because revenue is under AED 50 million and it is not a Qualifying Free Zone Person. But as an LLC it still needs an annual audit under the Commercial Companies Law. It may use IFRS for SMEs.
• Free zone company, AED 4 million. Audited financial statements are required for Corporate Tax because it is a Qualifying Free Zone Person, regardless of its size. Its free zone may have its own rules too.
• Trading company, AED 65 million. Audited financial statements are required for Corporate Tax because revenue exceeds AED 50 million, and it must use full IFRS.

If the three later formed a Tax Group, the group would need audited special purpose aggregated statements instead.

Getting audit-ready

Audits run faster when the accounts are ready before the auditor arrives:

• monthly bookkeeping with bank, receivable and payable reconciliations;
• a fixed asset register and supporting invoices;
• related party balances agreed between entities; and
• a clear trail from the trial balance to the draft statements.

How we help

We prepare your year-end accounts and the supporting schedules auditors ask for, and we work with partner audit firms. We are not the auditor, and the audit opinion always comes from an independent audit firm. Our year-end accounts and audit support service keeps the process on schedule, and our Corporate Tax filing service uses the final statements to prepare your return.

Frequently asked questions

If my revenue is under AED 50 million, do I need an audit?

Not for Corporate Tax, unless you are a Qualifying Free Zone Person or a Tax Group. But the Commercial Companies Law requires every limited liability company and joint stock company to have its accounts audited each year, so many mainland companies need an audit anyway.

Does every Qualifying Free Zone Person need audited financial statements?

Yes. Ministerial Decision No. 84 of 2025 requires all Qualifying Free Zone Persons to prepare and maintain audited financial statements, whatever their revenue.

Can a small business use IFRS for SMEs?

Yes, where revenue does not exceed AED 50 million. A business with revenue of AED 3 million or less may also prepare financial statements on a cash basis.

Is GoStride our auditor?

No. We prepare the accounts and year-end schedules and work alongside partner audit firms. The audit opinion always comes from an independent audit firm.