- Federal Decree-Law No. 20 of 2025, effective 15 October 2025, is the broadest revision to UAE company law since 2021, introducing a formal re-domiciliation framework, multiple LLC share classes, and recognition of non-profit companies.
- Companies can now move their registration between emirates, between free zones, or between free zone and mainland while keeping their legal personality, instead of dissolving and re-incorporating.
- Businesses with revenue of AED 50 million or more must appoint an Accredited Service Provider for e-invoicing by 30 October 2026, with mandatory go-live on 1 January 2027.
- Smaller businesses (under AED 50 million revenue) have until 1 July 2027 for mandatory e-invoicing, and government entities until 1 October 2027.
- The Central Bank of the UAE's SME Customer Protection Regulation (Circular 2/2026) took effect 13 September 2026, giving small business banking customers more formal standing.
- Separately, the Federal Tax Authority has reminded businesses with a 31 December 2025 financial year end that Corporate Tax returns and payment are due by 30 September 2026.
Three real changes have landed in UAE company formation since October 2025: a full overhaul of the Commercial Companies Law that lets companies relocate between free zones and mainland without dissolving, an e-invoicing mandate with a hard October 2026 deadline for larger businesses, and a new central bank protection regulation for SME banking customers. None of these are rumors or proposals. All three are law, and two of them carry real penalties for businesses that miss the dates.
This is a roundup of what has actually changed since the last major reform wave, not the 2021 ownership liberalization most guides still lead with. If you want that earlier context first, see our guide on what changed in UAE company formation covering ownership, tax, and visas.
The Commercial Companies Law overhaul (October 2025)
See e.zone’s coverage of why the UAE is connecting its business records in 2026, a related data-sharing shift worth understanding alongside this overhaul.
Federal Decree-Law No. 20 of 2025 took effect on 15 October 2025 and is the most substantial revision to UAE company law in years. Four changes matter most for founders and existing company owners:
- Re-domiciliation is now a formal legal process. Article 15 of the amendment lets a company move its registration between emirates, between free zones, or between a free zone and the mainland, while keeping its legal personality intact. Previously this effectively meant dissolving and re-incorporating.
- Free zone companies are now formally recognised as UAE companies under the law, reducing ambiguity for structures that operate across both free zone and mainland jurisdictions.
- Multiple share classes are now permitted in LLCs, along with a statutory basis for drag-along and tag-along rights, which matters for any company bringing on investors with different terms than the founders.
- Non-profit companies are formally recognised for the first time, for entities pursuing social, cultural, or developmental purposes with surplus reinvested rather than distributed.
Why re-domiciliation is the change worth paying attention to
Before this amendment, a company that outgrew its original free zone, or that started mainland and later wanted free zone benefits, generally had to close the original entity and incorporate a new one. That meant new bank accounts, new contracts, and a break in trading history.
A formal re-domiciliation framework means a company can now change jurisdiction while keeping the same legal identity. This is genuinely useful for a business that picked a free zone early for speed and cost, and later needs mainland trading rights, or one that needs to consolidate operations into a single emirate for banking or licensing reasons.
E-invoicing is one line item in a longer list; our the broader compliance calendar this feeds into covers the rest.
The e-invoicing mandate, and the deadline that is already close
The UAE’s e-invoicing system moved from proposal to law under Ministerial Decisions No. 243 and No. 244 of 2025, with the pilot and voluntary phase live since 1 July 2026. The dates that matter now:
| Business size | Milestone | Date |
|---|---|---|
| Revenue ≥ AED 50 million | Must appoint an Accredited Service Provider (ASP) | 30 October 2026 |
| Revenue ≥ AED 50 million | Mandatory e-invoicing go-live | 1 January 2027 |
| Revenue below AED 50 million | Mandatory e-invoicing go-live | 1 July 2027 |
| Government entities | Mandatory e-invoicing go-live | 1 October 2027 |
The ASP appointment deadline was itself extended once already, under Ministerial Decision No. 66 of 2026, which moved it from an earlier date to 30 October 2026. Non-compliance carries an administrative penalty of AED 5,000 per month. If your business is approaching AED 50 million in revenue, appointing an ASP is not a 2027 problem. It is a task for the coming weeks.
“Smaller businesses have until mid-2027, but the ASP appointment deadline for larger companies is now weeks away, not years.”
This sits alongside broader documentation banks already ask for; see what banks now require from new company accounts.
A new banking protection rule for SMEs (September 2026)
The Central Bank of the UAE issued Circular 2/2026, the SME Customer Protection Regulation, effective 13 September 2026. This is a newer, narrower development than the two changes above, but relevant for any small or growing company that has dealt with slow account opening, unclear fee structures, or account closures without adequate notice from a UAE bank. The regulation is aimed specifically at strengthening how banks treat SME customers, an area where founders have historically had little formal recourse.
The deadline that applies right now, not just to new changes
Separate from anything new, the Federal Tax Authority has reminded businesses with a financial year ending 31 December 2025 that their Corporate Tax return and any tax due is payable by 30 September 2026. This is not a new rule, but it is the nearest concrete deadline on the calendar for most existing companies, and worth checking against your own filing status regardless of which of the changes above apply to you. For the full breakdown of Corporate Tax and VAT registration and deadlines, see our the deadlines and thresholds that changed too.
While you’re checking dates, it’s worth confirming your next renewal deadline too.
What to actually check, based on company age
- Companies incorporated in the last 12 months: confirm your Corporate Tax registration was completed within three months of incorporation, and check whether the September 2026 filing deadline applies to your financial year.
- Companies considering a jurisdiction change: the re-domiciliation framework may now make a move between free zone and mainland, or between emirates, viable without dissolving your existing entity.
- Businesses approaching AED 50 million in revenue: the ASP appointment deadline of 30 October 2026 is close. Waiting until 2027 is not an option for this tier.
- Multi-shareholder LLCs: the new multiple share class and drag-along/tag-along provisions may be worth revisiting with a lawyer if your shareholder agreement predates October 2025.
When professional help is worth it
Re-domiciliation and multi-class share structures both involve genuine legal complexity that a template shareholder agreement will not cover correctly. E-invoicing ASP selection also has real cost and integration implications that are worth getting right the first time rather than switching providers mid-rollout. For a company navigating any of these changes, e.zone’s formation advisors can confirm which of these actually apply to your structure and what the practical next step looks like.
Frequently asked questions
What is Federal Decree-Law No. 20 of 2025?
A major amendment to the UAE Commercial Companies Law, effective 15 October 2025, introducing a formal re-domiciliation framework, multiple LLC share classes, drag-along and tag-along rights, and formal recognition of non-profit companies.
Can a UAE company move from a free zone to the mainland without closing down?
Yes. The re-domiciliation framework introduced under Article 15 of Federal Decree-Law No. 20 of 2025 allows a company to transfer its registration while retaining its legal personality.
When does e-invoicing become mandatory in the UAE?
Businesses with revenue of AED 50 million or more must go live by 1 January 2027, after appointing an Accredited Service Provider by 30 October 2026. Smaller businesses have until 1 July 2027.
What is the penalty for non-compliance with UAE e-invoicing requirements?
An administrative penalty of AED 5,000 per month applies for non-compliance once the relevant mandatory deadline has passed.
What is the SME Customer Protection Regulation?
Central Bank of the UAE Circular 2/2026, effective 13 September 2026, which strengthens protections for small and medium business customers in their dealings with UAE banks.
Is my Corporate Tax return due in September 2026?
If your company's financial year ended 31 December 2025, your Corporate Tax return and any tax due is payable by 30 September 2026.
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