Preparing for a Statutory Audit in the UAE: Who Needs One, Deadlines and Documents

Introduction

Who must have audited financial statements in the UAE, when they are due on the mainland, in free zones and for Corporate Tax, and how to get records ready.

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Last reviewed 3 October 2026 · 9 min read

In short

Mainland limited liability and joint stock companies must have their accounts audited every year under the Commercial Companies Law, and the main free zones set their own annual audit rules. For Corporate Tax, audited statements are also required where revenue exceeds AED 50 million, and from every Qualifying Free Zone Person and Tax Group. Deadlines run from three months after the year end, when a mainland LLC's manager must have the accounts ready, to nine months for the Corporate Tax return. On the mainland only an auditor licensed by the Ministry of Economy and Tourism can sign, and public joint stock companies also need an audit firm accredited by the UAE Capital Market Authority (CMA). Each free zone sets its own approval or registration rules for auditors.

Which companies need audited financial statements?

On the mainland, Federal Decree-Law No. 32 of 2021 on Commercial Companies requires every joint stock company and limited liability company (LLC) to have one or more auditors audit its accounts each year. Other forms, such as partnerships, may appoint an auditor but do not have to. The accounts must follow international accounting standards.

Free zone companies follow their own free zone's rules where those rules cover the point. The Dubai Multi Commodities Centre (DMCC), the Jebel Ali Free Zone (JAFZA), the Dubai International Financial Centre (DIFC) and Abu Dhabi Global Market (ADGM) all start from an annual audit, with limited exceptions. DIFC and ADGM exempt some small companies, DMCC and ADGM exempt dormant companies, and JAFZA's Registrar can approve a one-year waiver if every shareholder agrees, although JAFZA's licence renewal rules and Corporate Tax may still call for audited accounts. Our company set-up guide compares mainland and free zone companies.

Corporate Tax adds a separate test. Under Ministerial Decision No. 84 of 2025, for tax periods starting on or after 1 January 2025, these must prepare and maintain audited financial statements:

  • a taxable person, other than a Tax Group, with revenue above AED 50 million in the tax period
  • every Qualifying Free Zone Person, whatever its revenue
  • every Tax Group, which must prepare audited special purpose aggregated financial statements under Federal Tax Authority (FTA) Decision No. 7 of 2025

When are audited accounts due?

Each set of rules has its own timetable, so plan around the earliest one that applies. For a company with a 31 December year end, the main dates are:

  • Mainland LLC: the manager must prepare the balance sheet, profit and loss account and annual report within three months, by 31 March. The annual general assembly, which considers the auditor's report and approves the accounts, must then meet within four months of the year end, by 30 April. Notice of that meeting must be sent at least 21 days before it, so the audit needs to be finished in good time.
  • DMCC: accounts must be prepared, audited by a DMCC approved auditor and approved by the shareholders within six months, by 30 June, then filed with the Registrar within five business days of that approval. DMCC's filing guidelines ask for the upload through its Member Portal within the same six months.
  • DIFC: accounts must be audited and sent to shareholders within six months, then filed with the Registrar within 30 days. A private company needs no audit and need not file accounts if, in the current year and the year before, its turnover including subsidiaries was USD 5 million or less and it had no more than 20 shareholders. A company in its first year is tested on that year alone. The exemption does not apply if its articles require an audit, or if shareholders holding at least 10% ask for one at least one month before the year end. Firms authorised by the Dubai Financial Services Authority (DFSA) have their own audit rules and usually must send their auditor's reports to it within four months of the year end.
  • ADGM: private companies must file their accounts within nine months, by 30 September, and public companies within six months. Small companies with turnover up to USD 13.5 million and no more than 35 employees can usually claim an audit exemption, unless their shareholders ask for an audit. A company that is part of a group must also check the size of the whole group. Listed companies, public interest entities and most financial institutions regulated by ADGM's Financial Services Regulatory Authority cannot claim the exemption.
  • Corporate Tax: the return is due within nine months of the end of the tax period, by 30 September, unless the FTA sets another date. The return asks for the audit opinion and the auditor's name, and a Tax Group must send its audited statements to the FTA within the same nine months, so any audit that Corporate Tax rules require should be finished before you file.
  • JAFZA: an annual audit is required, and the JAFZA Rules renew a licence only if the company commits to submitting audited accounts each year. Statements are filed through the Dubai Trade portal, but JAFZA publishes no clear filing date, so check it with the free zone.

Who can sign a UAE audit?

Auditing on the mainland is regulated by Federal Decree-Law No. 41 of 2023, in force since 29 March 2024, which replaced the earlier auditing law. Nobody may practise without a professional licence from the Ministry of Economy and Tourism, only licensed individuals may call themselves Chartered Accountants, and they must work through a licensed accounting firm. Public joint stock companies and public investment funds can only be audited by a firm that the UAE Capital Market Authority (CMA) has accredited.

Licensed firms must apply the International Standards on Auditing and the international ethics and independence code adopted by the Ministry in 2024. Reports must carry the signature the Ministry has approved for the auditor, linked to their name and licence number. Signing a report that neither the auditor nor their supervised team prepared is a criminal offence.

Free zones set their own rules on who can audit:

  • DMCC: the audit firm must be approved and registered by DMCC, and its audit partner must hold Ministry accreditation.
  • JAFZA: the auditor must be on the approved list kept by JAFZA's Registrar.
  • DIFC: the auditor must be registered with the DIFC Registrar of Companies.
  • ADGM: any audit, whatever its purpose, must be carried out by an auditor registered with ADGM's Registration Authority.

What documents will the auditor ask for?

Auditors are entitled to see all the company's registers, papers and documents and to ask for explanations. Under the International Standards on Auditing, they must agree the financial statements to the accounting records, examine material journal entries and often confirm balances directly with banks, customers and lenders.

Requests vary by business, but a typical list includes:

  • the trial balance, general ledger and last year's audited accounts
  • bank statements and year-end reconciliations for every account, with authority for the auditor to contact each bank
  • customer and supplier balance listings, with the invoices and contracts behind large items
  • the fixed asset register and purchase documents
  • inventory records and count sheets. Where inventory is material, the auditor must attend the count unless that is impracticable, so agree the date early.
  • loan agreements and lender statements
  • payroll records and staff end-of-service calculations
  • VAT returns, Corporate Tax registration and returns, and FTA correspondence
  • the trade licence, memorandum of association, shareholder resolutions and a list of related parties and transactions with them
  • a signed letter of representation from management, which the auditor asks for near the end

Why do audits run late?

Deadlines leave little room for slippage. ADGM can extend a company's filing deadline by up to three months for a special reason, such as an unforeseen event outside its control. The request must be made through ADGM's online registry before the original deadline, and no extension can run beyond 12 months after the year end. In DIFC and ADGM, late filing can lead to a fine.

Common causes of delay include:

  • books not closed, or bank accounts not reconciled, when the auditor starts
  • bank and other third-party confirmations, which depend on others replying
  • an inventory count the auditor did not attend, which means extra work to support the year-end figure
  • balances with related companies that do not agree on both sides
  • VAT returns that do not reconcile to the revenue in the ledger
  • an auditor appointed late, or one that is not approved by the company's free zone

How do bookkeeping and VAT records feed into the audit?

The audit tests the books, so it moves at the pace of the records. The Commercial Companies Law requires accounting records that show the company's financial position accurately at any time, kept for at least five years. The Corporate Tax Law requires records supporting each tax return to be kept for seven years after the tax period. Free zones set their own periods, such as six years in DIFC and JAFZA and ten years from the date a record is made in ADGM, so keep records for the longest period that applies to you.

Reconciling each VAT return to the ledger as you file it makes the year-end revenue and the VAT balance with the FTA easier to agree. If the audit uncovers a VAT error, a voluntary disclosure may be needed, which our VAT guide explains.

A short monthly routine helps: reconcile every bank account, clear unexplained items, file invoices against each entry, and agree balances with related companies before the year end. Our Corporate Tax guide covers the tax return that the audited figures feed into.

Frequently asked questions

Does a free zone audit exemption mean I do not need an audit?

Not always. Corporate Tax requires audited statements from every Qualifying Free Zone Person, whatever its size, and from other companies with revenue above AED 50 million. ADGM's Registration Authority has said that a small ADGM company that wants the 0% rate as a Qualifying Free Zone Person must keep audited accounts and file them with the Registrar, even though ADGM's own rules would otherwise exempt it.

Do I need an audit if revenue is below AED 50 million?

Often, yes. The AED 50 million test is only one Corporate Tax rule. Mainland LLCs and joint stock companies must be audited every year under the Commercial Companies Law. DMCC, JAFZA, DIFC and ADGM also start from an annual audit, and Qualifying Free Zone Persons and Tax Groups need audited statements at any revenue level.

Can the firm that keeps my books also audit them?

Independence rules limit this. The auditing law bars auditors from taking on work that conflicts with their independence, and licensed auditors must follow the international ethics and independence code adopted by the Ministry of Economy and Tourism. JAFZA and DIFC also bar auditors with a conflict of interest. Ask your auditor before combining the two roles.

What if the auditor cannot get the information it needs?

It has to say so. DMCC's guidance says the audit report must state if the auditor has not received all the information and explanations it needs. For a mainland LLC, an auditor who is not given the facilities to do the work reports this to management and, if nothing changes, to the local authority responsible for companies in that emirate.

How Indigo Group can help

Indigo Group can help you prepare for your audit. Our Accounting and Audit team handles bookkeeping, VAT registration and filing, and audit support, and our Corporate Services team handles Corporate Tax filing, company formation, visas and government liaison. Indigo Group's regulated entity, Indigo Financial Analysis and Consultancy LLC, is licensed by the UAE Capital Market Authority (CMA), licence no. 706042.

Read more about our bookkeeping, accounting and audit support in Dubai.

To talk this through, book a consultation or message us on WhatsApp.

Written by

Alexander Hutton

CEO

Alex Hutton is the CEO of Indigo Group, where he oversees the company's strategic direction and global operations.

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Last reviewed 3 October 2026. This article is for general information only and does not constitute financial, legal or tax advice. Rules change, so please speak to a qualified adviser about your circumstances.

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