TRW & Co · Accounting, audit and bookkeeping
Audit Requirements in Sharjah, RAK and Fujairah Free Zones
Using SAIF Zone approved auditors is only one of the audit tests northern emirates companies face. Hamriyah, the other Sharjah zones, RAKEZ and Fujairah each set their own rules, from RAKEZ's six-month audit deadline to Creative City's package with no zone audit. Corporate tax then requires audited statements from every qualifying free zone person. Here is the comparison.
Key pointRAKEZ treats failure to submit audited financial statements as a listed violation, with a fine and a three-month deadline before all services are suspended, so in RAKEZ a late audit can stop visas as well as renewal.
At a glance
Zone rules first
Each Sharjah, RAK and Fujairah free zone issues its own company regulations, which decide whether an audit is needed, who may sign it and when.
RAKEZ: six months
RAKEZ's Companies Regulations require accounts to be audited and laid before the AGM within six months of the year-end, by a RAKEZ-registered auditor.
RAKEZ violation code
Failure to submit audited financial statements carries AED 2,500 and a three-month deadline, then suspension of all services on a second violation.
Creative City exception
Fujairah's government portal lists no annual audit among Creative City's benefits, but corporate tax rules can still require audited statements.
Tax overlay everywhere
Every qualifying free zone person must prepare and maintain audited financial statements under Ministerial Decision No. 84 of 2025, whatever its zone allows.
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SAIF Zone approved auditors and northern emirates audits: the short answer
Free zone companies in Sharjah, Ras Al Khaimah and Fujairah face audit rules set zone by zone. In SAIF Zone and Hamriyah, the usual expectation is annual accounts audited by one of the SAIF Zone approved auditors or a firm registered with Hamriyah, submitted to the zone and checked around licence renewal. RAKEZ has the most clearly published regime: accounts must be audited within six months of the year-end by an auditor registered with the Authority, and failure to submit them is a listed violation.
Above every zone sits the federal corporate tax rule. Any free zone company claiming the 0% rate as a qualifying free zone person must prepare and maintain audited financial statements, whatever its size and whatever its zone allows. Even a Creative City company in Fujairah, which the emirate's government portal says has no annual audit requirement, needs an audit if it claims that status.
This guide compares the position in SAIF Zone, Hamriyah, the other Sharjah zones, RAKEZ and Fujairah. The accounting and audit work itself is delivered with our group company A&A Consultancy; TRW & Co, as a law firm, covers the legal and regulatory side.
The legal framework: zone rules plus two federal layers
Each free zone in the northern emirates was created by a decree or law of its emirate, and each issues its own company regulations. Article 5 of the federal Commercial Companies Law allows those zone rules to apply instead of the federal company law where the zone's legislation provides for it. So the first question is always which authority issued the licence.
Two federal rules apply everywhere:
- Auditor licensing. Under Federal Decree-Law No. 41 of 2023 on regulating the auditing and accounting professions, every auditor practising in the UAE must be licensed by the Ministry of Economy and Tourism. A zone list adds a second gate; it does not replace the federal one.
- Corporate tax audits. Ministerial Decision No. 84 of 2025 requires every qualifying free zone person to prepare and maintain audited financial statements. It also requires audited statements from other taxpayers with revenue above AED 50 million.
Our guide to registered auditor requirements in the UAE explains how federal licensing and zone approval interact.
Sharjah: SAIF Zone, Hamriyah and the newer zones
SAIF Zone
The Sharjah Airport International Free Zone licenses Free Zone Establishments (single-owner) and Free Zone Companies (multiple owners), many of them traders, logistics operators and light manufacturers with warehouses next to the airport. Industry guidance consistently describes an annual audit by one of the SAIF Zone approved auditors, with the audited statements submitted to the zone and looked for at licence renewal.
We could not verify SAIF Zone's current filing deadline or penalty from a published official source, and secondary summaries disagree. Treat any deadline you are quoted as something to confirm in writing with the zone. What is consistent is the auditor test: check that the firm appears among the SAIF Zone approved auditors when you engage it, and again at each re-engagement.
Hamriyah Free Zone
Hamriyah, on the coast between Sharjah and Ajman, is built around heavy and port-linked industry, energy, maritime and food processing. Its companies also generally need audited accounts from an auditor the zone accepts, and industrial licensees often face lender and customs scrutiny of their inventory and fixed assets as well. The same advice applies: confirm the current list and deadline with the Hamriyah Free Zone Authority rather than relying on a setup package summary.
SHAMS, SPC Free Zone and SRTIP
Sharjah's newer zones, Sharjah Media City (SHAMS), Sharjah Publishing City Free Zone and the Sharjah Research, Technology and Innovation Park, target media, services, e-commerce and technology businesses. Their licence packages and audit expectations vary, and some smaller licences may not be asked for audited accounts at renewal. That does not settle the corporate tax position. Our comparison of Sharjah free zones sets out who each zone suits.
Ask the zone three questions in writing before the year-end: is an audit required for this licence, which auditors does the zone accept, and by when must the audited statements be filed? Keep the reply with the auditor appointment resolution. SAIF Zone approved auditors and the zone's own customer service teams can both help, but the written answer from the zone is what protects the company.
Ras Al Khaimah: the RAKEZ regime in detail
The RAKEZ Companies Regulations apply to FZ-LLCs, public companies and branches registered in the Ras Al Khaimah Economic Zone. Part 11 deals with accounts and audit.
- Accounts. Shareholders or directors must cause accounts to be prepared for each financial year under the accounting standards the Authority approves, showing a true and fair view.
- Six-month rule. Within six months after the year-end, the accounts must be prepared and approved, examined and reported on by an auditor, and laid before the annual general meeting with the auditor's report.
- Filing on direction. As directed by the Registrar, the company must file a copy of the accounts and auditor's report within seven days of the direction.
- Registered auditors. References to an auditor are to one registered under the Regulations; the Registrar keeps a register of auditors and the Authority may refuse or cancel registration. RAKEZ publishes an approved auditors' list, divided into premium and standard firms.
- Appointment. The company appoints its auditor by ordinary resolution.
The RAKEZ violation codes list "failure to submit audited financial statements" as a violation carrying AED 2,500 with a three-month deadline to comply, followed by suspension of all services on a second violation. A suspension stops visa, immigration and amendment services just as effectively as a lapsed licence. RAKEZ's licence renewal checklist also charges a daily late-renewal penalty from the expiry date, so audit delays that push back renewal cost twice. See our guide to company setup in Ras Al Khaimah for the wider regime.
RAK International Corporate Centre companies are not free zone operating companies and follow a different regime; our guide to RAK ICC offshore companies covers them.
Fujairah: the Free Zone and Creative City
Fujairah has two free zone options. The Fujairah Free Zone serves trading, logistics and energy businesses around the port; companies there should confirm the authority's current audit and renewal requirements directly, because we could not verify them from a published official source. Creative City, Fujairah's media free zone, is marketed differently: the emirate's government business portal lists "no paid-up share capital or annual audit" among its benefits.
That zone-level relief is real but narrow. A Creative City company that claims qualifying free zone person status still needs audited statements under Ministerial Decision No. 84 of 2025, and a company with revenue above AED 50 million needs them in any case. Banks, investors and buyers may also insist on audited accounts. Our guide to company setup in Fujairah compares the two zones.
SAIF Zone approved auditors and the other zones compared
The table summarises what we could verify. Where an official source was not available, we say so; confirm the current rule with the zone before relying on it.
| Zone | Auditor requirement | Timing | Consequence of non-filing |
|---|---|---|---|
| SAIF Zone | One of the SAIF Zone approved auditors, plus a Ministry licence | Annual; confirm the current deadline with the zone | Commonly a renewal hold; confirm penalties with the zone |
| Hamriyah Free Zone | Auditor accepted by the Hamriyah authority, plus a Ministry licence | Annual; confirm with the zone | Commonly a renewal hold; confirm with the zone |
| SHAMS, SPC, SRTIP | Depends on licence type; confirm with the zone | Confirm with the zone | Confirm with the zone |
| RAKEZ | Auditor registered with RAKEZ (published approved list) | Audit and AGM within six months of year-end; filing within seven days of a Registrar direction | AED 2,500 and a three-month deadline, then suspension of all services |
| Fujairah Free Zone | Confirm with the authority | Confirm with the authority | Confirm with the authority |
| Creative City (Fujairah) | No annual audit under the zone's package, per the government portal | Not applicable at zone level | None at zone level; corporate tax rules still apply |
| Any qualifying free zone person | Audited statements required for corporate tax | Before the tax return, nine months after the period | Loss of 0% status for that period and the next four |
How corporate tax overlays the zone rules
For most northern emirates companies, the corporate tax requirement is now the binding one. A qualifying free zone person must, among other conditions, maintain adequate substance in the zone, earn qualifying income, stay within the de minimis limit for non-qualifying revenue, comply with transfer pricing rules and prepare audited financial statements. Failing any condition removes the 0% rate from the start of that tax period and for the following four.
Ministerial Decision No. 84 of 2025 also states that a qualifying free zone person distributing goods in or from a designated zone must comply with any additional procedures the Federal Tax Authority prescribes. That matters for traders in the port and airport zones of the northern emirates. Our guides to the qualifying free zone person regime and to VAT in free zones and designated zones explain the conditions.
The practical consequence is a single timetable. The corporate tax return is due nine months after the year-end, RAKEZ expects the audit within six, and SAIF Zone approved auditors are busiest just before renewal season. Plan to the earliest of the three dates.
A working annual cycle
- Identify the authority. Confirm which zone issued the licence, the entity type, the financial year and whether the company claims qualifying free zone person status.
- Get the zone's rules in writing. Ask whether an audit is required, which auditors are accepted and the filing deadline.
- Appoint the auditor. Pass a shareholder resolution, verify the Ministry licence and the zone list (for example SAIF Zone approved auditors or the RAKEZ list) and file any notice the zone requires.
- Close the books. Count inventory at year-end, reconcile bank and intercompany balances, and review revenue against licensed activities.
- Audit, approve and hold the AGM. The auditor reports, directors sign, and shareholders approve within the zone's timetable.
- File and renew. Submit the audited statements through the zone's portal before renewal and keep evidence of acceptance.
- File the tax return. Prepare the corporate tax return from the audited figures within nine months of the year-end.
Illustrative scenario: a SAIF Zone trader selling onshore
Illustrative only; the parties are generic. A SAIF Zone FZE imports spare parts, stores them in a zone warehouse and sells them to customers abroad and, increasingly, to mainland UAE workshops. It claims qualifying free zone person status and has never used anyone other than its original auditor.
Before renewal, the company checks the zone's current list and finds that its auditor's approval needs renewing. It appoints one of the SAIF Zone approved auditors by resolution. The new auditor's stock count reveals slow-moving inventory and the revenue analysis shows that mainland sales have grown. The company's lawyers review its licence, customer contracts and delivery terms, and work with its tax agent on whether mainland revenue remains within the de minimis limit. The audit is filed with the zone, the licence renewed and the tax return prepared from the audited figures.
Risks and common mistakes
Relying on a setup package's "no audit" promise
Some packages are sold as audit-free. Even where the zone does not ask for audited accounts, a qualifying free zone person must prepare them for corporate tax, and banks and buyers may require them. Read the zone's rules and the tax rules separately, and ask the zone for written confirmation of any exemption before relying on it.
Using an auditor the zone does not accept
A Ministry licence does not guarantee a place among SAIF Zone approved auditors or on the RAKEZ list. A report from a firm the zone does not accept may be rejected, forcing a second audit against a renewal deadline. Verify the list at engagement and each year, and keep a copy of the check with the appointment resolution. Approval can lapse between one year-end and the next.
Missing RAKEZ's six-month rule
The RAKEZ Companies Regulations require the audit and AGM within six months of the year-end, earlier than the corporate tax return. A company planning to the tax deadline will already be in breach, and a second violation means suspension of all services. Build the RAKEZ date into the compliance calendar as the real deadline.
Treating inventory as an afterthought
Trading and industrial companies in SAIF Zone, Hamriyah and the Fujairah Free Zone often hold stock in bonded warehouses. Without a year-end count and reconciliation to customs records, the auditor may qualify the opinion, which a zone, bank or the Federal Tax Authority will notice. Plan the count with the auditor and keep the customs documents ready; our customs and trade compliance practice can help where records do not match.
Cross-border groups
Many northern emirates companies are owned from India, Pakistan, Bangladesh, China or the GCC, and use the UAE entity as a trading hub. The zone's audit rules apply to the local entity regardless of how the group reports, and a component audit for group purposes does not replace a UAE statutory audit by a UAE-licensed firm the zone accepts. Align year-ends, plan for local signatures and originals, and keep transfer pricing documentation consistent with the audited figures, since related-party sales are a focus for both auditors and the Federal Tax Authority.
What to do next
List every free zone entity in the group, its authority, its auditor and each relevant date. Check SAIF Zone approved auditors, the RAKEZ list or the relevant zone's requirements before re-engaging, and plan to the earliest deadline.
The accounting and audit engagement is delivered with our group company A&A Consultancy. TRW & Co advises on the legal side: zone regulations and correspondence, auditor appointments and changes, licence amendments, renewal holds and violations, and free zone structuring, working with registered tax agents on Federal Tax Authority matters. We are not auditors or tax agents. To discuss your zone's requirements, contact our Dubai team at info@trw.co or +971 58 942 1012.
Frequently asked questions
01Do SAIF Zone companies need an audit?
In practice, yes. SAIF Zone companies are generally expected to have annual accounts audited by one of the SAIF Zone approved auditors and submitted to the zone, and the submission is commonly checked at licence renewal. We could not verify the zone's current deadline from a published official source, so confirm it in writing with the zone. Any SAIF Zone company claiming qualifying free zone person status must also maintain audited financial statements for corporate tax.
02How do I check whether an auditor is approved by SAIF Zone?
Ask the audit firm for evidence of its current approval by SAIF Zone, its Ministry of Economy and Tourism licence and the signing partner's registration, then confirm the approval with the zone before signing the engagement letter. Approval can lapse, so repeat the check at each re-engagement. Record the checks in the shareholder resolution appointing the auditor, so the company can show it acted properly if the filing is later questioned.
03What is the audit deadline for RAKEZ companies?
Under the RAKEZ Companies Regulations, within six months after the end of the financial year the accounts must be prepared and approved, examined and reported on by a registered auditor and laid before the annual general meeting. The company must file a copy of the accounts and auditor's report within seven days of a direction from the Registrar. The corporate tax return follows nine months after the year-end.
04What is the penalty for not submitting audited accounts in RAKEZ?
The RAKEZ violation codes list failure to submit audited financial statements as a violation carrying AED 2,500 with a three-month deadline to comply. A second violation leads to suspension of all services, which stops visa, immigration and amendment transactions. Late renewal of the licence carries a separate daily penalty, so an audit delay that pushes back renewal can cost twice.
05Do Fujairah Creative City companies need audited accounts?
The Fujairah government's business portal lists no paid-up share capital or annual audit among Creative City's benefits, so the zone itself does not generally ask for one. But a Creative City company claiming qualifying free zone person status must prepare and maintain audited financial statements under Ministerial Decision No. 84 of 2025, and companies with revenue above AED 50 million need them anyway. Banks and investors may also require them.
06Does the corporate tax audit requirement replace the zone rules?
No. The two run in parallel. The zone's rules decide whether the company must file audited accounts with the zone, which auditors are accepted and the deadline. Corporate tax rules decide whether audited statements are needed for tax purposes. A company can meet one and fail the other, for example by using an auditor the zone does not accept, or by relying on a zone exemption while claiming the 0% rate.
Sources and official materials
- RAKEZ Companies Regulations — Part 11 on accounts, the six-month audit rule and registered auditors
- RAKEZ Violation Codes — Fine and service suspension for failure to submit audited financial statements
- RAKEZ Approved Auditors' List — Auditors registered with RAKEZ
- RAKEZ Free Zone Licence Renewal Checklist — Renewal documents and late renewal penalty
- Government of Fujairah: Setting up business in Fujairah — Fujairah Free Zone and Creative City benefits
- Ministerial Decision No. 84 of 2025 on Audited Financial Statements — Corporate tax audit requirement for qualifying free zone persons
- Federal Decree-Law No. 41 of 2023 on Regulating the Auditing and Accounting Professions — Federal licensing of auditors
General information only, current as at 27 October 2026. It is not legal advice and does not create a lawyer–client relationship. UAE law differs between the onshore jurisdiction, the DIFC, ADGM and the free zones, and changes frequently; check current official sources and take advice on the facts of your matter.
