- Executive Council Resolution No. 11 of 2025, issued March 2025, gives Dubai free zone companies three mainland access routes: a branch license, a renewable one-year dual license, or a temporary project-based permit.
- Only activities on DET's published eligible-activities list qualify; DIFC entities sit outside the resolution entirely.
- Mainland income earned under a dual license is taxed at the standard 9% corporate tax rate and must be tracked in separate accounts from qualifying free zone income to protect Qualifying Free Zone Person status.
- A dual license does not automatically expand visa quotas or waive physical-presence requirements — both depend on the specific activity authorized.
Executive Council Resolution No. 11 of 2025 lets most Dubai free zone companies legally operate inside mainland Dubai without setting up a separate onshore subsidiary.
Businesses that previously had to duplicate their entire structure just to serve mainland clients can now apply for a branch license, a renewable one-year dual license, or a temporary permit instead.
Issued in March 2025, the resolution reshapes one of the most persistent frustrations in UAE company formation: the wall between free zone and mainland operations. This guide covers who qualifies, which of the three routes fits which business, and what the Department of Economy and Tourism expects in return.
| Detail | What applies |
|---|---|
| Legal basis | Executive Council Resolution No. 11 of 2025 |
| Issued | March 2025 |
| Regulator | Dubai Department of Economy and Tourism (DET) |
| Excluded free zone | DIFC (financial free zone with its own separate regime) |
| Options available | Branch license, renewable one-year dual license, or temporary permit |
| Eligible activities | Published by DET as a defined activities list, not open to all free zone activities |
“A Dubai free zone company no longer needs a second company just to shake hands with a mainland client.”
Why Dubai created the dual license framework
For years, the standard advice to a free zone company wanting mainland business was blunt: incorporate a second entity onshore, or work through a local distributor and lose margin on every transaction. That advice made sense under the old rules, since free zone licenses were territorially restricted to the zone itself, with narrow exceptions for specific activities. It also meant duplicated visa quotas, duplicated office costs, and duplicated compliance obligations for what was often the same underlying business.
Executive Council Resolution No. 11 of 2025 responds to years of feedback from free zone operators who wanted access to mainland Dubai’s market without the overhead of running two parallel companies. Instead of forcing a full mainland subsidiary, the resolution creates lighter-weight pathways calibrated to how much mainland presence a business actually needs.
The reform also reflects Dubai’s broader push to make the free zone and mainland economies feel like a single, connected market rather than two separate jurisdictions that happen to share a border. DET’s role in publishing and maintaining the eligible-activities list keeps this flexible rather than a blanket policy, letting the emirate adjust which sectors qualify as market conditions change.
The three pathways: branch license, dual license, and temporary permit
The branch license option suits free zone companies that want a genuine, ongoing mainland presence, effectively opening a Dubai mainland branch of the free zone entity. It carries more setup work than the other two routes but gives the most durable footprint, useful for a business planning to bid on long-term mainland contracts or lease commercial premises outside the zone.
The dual license is the option most free zone companies are actually choosing. It is renewable annually, ties directly to the parent free zone license, and lets the company operate under both licenses concurrently without incorporating a separate legal entity. The temporary permit sits below both, intended for short, project-based mainland work, such as a specific contract or an event, where the company does not need standing mainland authorization at all.
A Dubai Internet City-registered software consultancy wins a six-month implementation project with a mainland Dubai retail chain. Under the old rules, the consultancy would either need a mainland branch, a local service agent arrangement, or would have to decline the work outright due to licensing restrictions.
Under the new framework, assuming software consultancy sits on DET’s eligible-activities list, the company applies for a dual license tied to its existing free zone registration. It keeps its Dubai Internet City office and staff visas exactly as they are, adds mainland authorization for the specific activity, and renews that authorization annually as long as the mainland relationship continues.
Which activities actually qualify
Not every free zone activity is eligible under the resolution. DET publishes and periodically updates a specific list of activities that can be conducted through a branch license, dual license, or temporary permit, and free zone companies whose activity does not appear on that list still need the traditional mainland subsidiary route if they want onshore presence.
In practice, the eligible list leans toward professional services, consultancy, technology, trading-adjacent activities, and other sectors where Dubai wants to reduce friction for scaling companies. Highly regulated sectors, and activities that intersect with specific mainland licensing regimes such as construction or healthcare, are more likely to sit outside the eligible list or require additional sector-specific approval layered on top of the dual license.
See our guide on e-commerce licensing across mainland and free zone for a sector where the old dual-structure requirement was especially punishing, and where this resolution now offers real relief.
How the application actually works
Applications route through DET, and in most cases through the Invest in Dubai platform that also handles other mainland licensing workflows. The free zone company submits its existing trade license, confirms the specific mainland activity it wants authorized, and DET checks that activity against the published eligible list before issuing the branch license, dual license, or permit.
Processing timelines vary by activity and by how much additional approval a given sector requires, but the intent of the resolution is to keep this materially faster than establishing a full mainland entity from scratch. Companies should still budget a few weeks for the review, particularly where the mainland activity touches a regulated sector needing sign-off from a separate authority beyond DET itself.
See our guide on what a UAE business actually needs to stay compliant, checklist by checklist for the baseline documentation any application of this kind tends to require, on top of the free zone-specific paperwork.
Tax and accounting implications of operating under two licenses
Running mainland activity alongside a free zone license raises a question every finance team should ask early: does mainland income under a dual license jeopardize the company’s Qualifying Free Zone Person status for corporate tax purposes. The short answer is that mainland-sourced revenue is generally taxed at the standard 9 percent corporate tax rate, and needs to be accounted for separately from qualifying free zone income to avoid contaminating the lower-tax treatment on the free zone side.
This means companies taking advantage of the dual license need genuinely separate management accounts for mainland versus free zone revenue streams, not just a mental note that the two are different. Sloppy bookkeeping here is the most likely way a company loses free zone tax benefits it would otherwise be entitled to keep.
See our guide on why mainland revenue still gets taxed at 9% for free zone entities for the mechanics of maintaining Qualifying Free Zone Person status while running parallel mainland activity.
How this interacts with the qualifying activities list
This resolution does not exist in a vacuum. It was issued around the same period as Ministerial Decision No. 229 of 2025, which separately revised the list of qualifying and excluded activities for corporate tax purposes. The two reforms address different questions, licensing scope versus tax classification, but companies using the dual license route need to check both at once: is the mainland activity eligible under DET’s list, and does earning that mainland income affect the company’s qualifying income calculation under MD 229.
Getting this wrong in either direction creates real exposure, either a licensing breach for operating mainland activity without proper authorization, or a tax exposure for miscalculating qualifying income. Finance and legal advisors should review both frameworks together rather than treating the dual license as a purely operational decision.
See our guide on what MD 229 of 2025 changed for the free zone qualifying activities list for the tax-side rules that run alongside this licensing reform.
Visa and staffing considerations under a dual license
A dual license does not automatically expand a free zone company’s visa quota for mainland-based staff. Employees working primarily on mainland activity may need visa sponsorship structured differently than staff working purely within the free zone, and companies should check with both their free zone authority and DET before assuming existing visa allocations stretch across both operations without adjustment.
See our guide on what a founder should budget for their first UAE hire for how visa and staffing costs are typically calculated, since dual license operations often add a layer of complexity here that a single-license company would not face.
Office and physical presence questions under a dual license
A dual license does not require a free zone company to lease a second, separate mainland office in every case, but the exact physical presence expectation depends heavily on the specific activity being authorized and how DET treats that activity category. Some activities can be conducted under a dual license with the company’s existing free zone office serving as the operational base, while others, particularly those involving walk-in customers or physical inventory, may still expect some form of mainland physical footprint.
Companies should not assume a single, uniform answer applies across every activity type. A consultancy providing services remotely to mainland clients faces a very different physical presence question than a trading company that needs to store and deliver goods within mainland Dubai, and DET’s application review is likely to reflect that distinction rather than applying one blanket physical presence rule to every dual license applicant. Companies unsure which category their own activity falls into should raise the question directly with DET before submitting a full application, since a wrong assumption here can delay approval significantly and force a costly resubmission later in the process.
See our guide on virtual versus physical office requirements in the UAE for how this question is assessed more generally across UAE licensing, a useful reference point for gauging what a specific dual license application is likely to require.
Common mistakes when approaching the dual license framework
- Assuming every free zone activity is eligible without first checking DET’s published eligible-activities list.
- Mixing mainland and free zone revenue in a single set of accounts, risking Qualifying Free Zone Person status.
- Choosing a temporary permit for what is actually an ongoing mainland relationship, then having to reapply repeatedly instead of moving to the renewable dual license.
- Forgetting that DIFC entities sit outside this resolution and need to use DIFC’s own separate mechanisms for mainland access.
- Overlooking sector-specific approvals that still apply on top of DET’s authorization for regulated activities.
When professional help is worth it
A straightforward consultancy adding a single mainland client can often navigate the dual license application directly through the Invest in Dubai platform without extensive advisory support. Once a company is layering mainland revenue on top of free zone tax status, or operating in a sector where sign-off from more than one authority is required, the risk of an avoidable compliance misstep rises sharply.
The e.zone team that handles free zone and mainland structuring day to day can map a company’s specific activity against DET’s eligible list before an application goes in, saving a rejected submission and a lost few weeks. See e.zone’s guide on how the Dubai mainland permit works for free zone companies for a closer walkthrough of how the three pathways compare in practice.
Expect DET’s eligible-activities list to keep evolving through 2026 as more sectors test the framework, so a company that gets an initial rejection should not assume the door is permanently closed, since a later update to the list may open the same activity for licensing within a matter of months.
Frequently asked questions
What's the difference between a dual license and a branch license?
A dual license is renewable annually and lets a company operate under both its free zone and mainland authorization concurrently without a separate legal entity; a branch license opens a more durable, standalone mainland branch of the free zone entity, suited to longer-term mainland contracts.
Does a dual license affect my free zone corporate tax status?
Yes, if not managed carefully. Mainland income is taxed at the standard 9% rate and must be accounted for separately; commingling mainland and free zone revenue risks losing Qualifying Free Zone Person status on the free zone side.
Can DIFC companies use this resolution to access mainland Dubai?
No. DIFC is excluded from Executive Council Resolution No. 11 of 2025 and continues to use its own separate mechanisms for mainland access.
Does every free zone activity qualify for a dual license?
No. DET publishes and periodically updates a specific eligible-activities list; activities outside that list still require the traditional mainland subsidiary route.
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