How to complain about an auditor in the UAE

The sanctioned party can file a grievance within 10 business days and then appeal to the Court of Appeal within 20 business days.

Federal Decree-Law No. 41 of 2023, which replaced Federal Law No. 12 of 2014 on the auditors' profession, makes the Ministry of Economy the regulator of the accounting and auditing profession. Article 5 gives the Ministry oversight and inspection of practitioners and firms, and the job of referring offences found in inspections, together with complaints, whistleblowing reports and court judgments it receives, to the Professional Compliance Committee.

So the complaint itself goes to the Ministry, not directly to the Committee. Use the Ministry's current complaints channel on its website and keep a copy of what you file. Under Article 35, cases that were pending before the old disciplinary board of auditors when the new law came into force passed to the Committee.

Two other regulators can be involved. Under Article 21(5), the Securities and Commodities Authority investigates the firms it has accredited if they breach the law while serving companies and funds it supervises, and its board may impose the same disciplinary sanctions. And if the auditor is on a free zone's approved list, the zone may have its own process for removing it from that list; check the zone rules alongside our guide to approved auditors by free zone.

Article 20 lets the Committee discipline a firm or chartered accountant that violates the duties, standards, code of conduct or principles of the profession, breaches any obligation or restriction in the law, its Executive Regulation or decisions issued under them, or acts in a manner that degrades the profession. Common grounds drawn from the law's own obligations include:

• Lack of due diligence in the work, or reports not prepared by the signer or staff under the signer's supervision (Article 16(1)).
• Independence breaches: being a creditor or debtor of the client other than for fees, holding a prohibited interest, or being a partner or agent of a founder, partner or director (Article 17).
• Disclosing client secrets outside the permitted exceptions (Article 18).
• Failing to keep engagement records for at least 10 years (Article 19).
• Practising or advertising in breach of the code of conduct (Article 17(3)).

A fee dispute on its own is usually a contract matter for the courts rather than a disciplinary one. Our page on auditor independence rules explains the conflicts that most often lead to complaints.

The Committee is formed by ministerial decision and includes experienced professionals and specialists in the profession and in professional compliance (Article 22). The Ministry lists Ministerial Resolution No. 139 of 2024 as the decision forming it. Its powers are to:

• consider breaches referred by the Ministry;
• impose the disciplinary sanctions in the law on anyone against whom the offence is proven;
• recommend that the Ministry report criminal offences to the public prosecution;
• give its opinion on offences by SCA-accredited firms before SCA refers them to the prosecution.

The sanctions in Article 20 are a written notice, a fine of AED 10,000 to AED 1,000,000, suspension of the professional licence for one month to three years, or cancellation of the licence, and they may be combined. Under Article 21, retirement does not protect a chartered accountant from discipline for work done in the five years before retiring, but no disciplinary action is taken while a final court judgment on the same offence is pending. The Ministry may publish inspection findings, committee decisions and final judgments (Article 29).

The process gives the sanctioned firm two levels of challenge, with tight deadlines:

1. Grievance to the Ministry: a reasoned written grievance within 10 business days of being notified of the sanction (Article 23(1)).
2. Grievance committee: chaired by a specialised judge chosen by the Minister of Justice, with four experienced members chosen by the Minister (Article 23(2)). The Ministry lists Ministerial Resolution No. 227 of 2024 as the decision on its formation and working system.
3. Court of Appeal: the grievance committee's decision can be challenged before the competent Court of Appeal within 20 business days of notification (Article 23(3)).

A firm whose licence is cancelled by a Committee decision may only apply for a new licence after five years, and the Minister may refuse it based on the grounds of the cancellation (Article 12(2)). A licence cancelled by a court judgment cannot be reissued at all (Article 12(3)).

As the complainant you are not a party to the grievance stage as the law describes it, so keep your evidence complete when you first file.

Some complaints turn out to involve someone who was never entitled to sign. Article 6 bars anyone from practising the profession without the licences the law requires, and Article 8(2) protects the title chartered accountant. Every report must carry the chartered accountant's Ministry-approved signature, name and professional licence number together with the firm's name and licence number (Article 16(2)(a)(8)), so a report without them is a warning sign.

Practising without a licence, or while suspended, is a crime under Article 27, punishable by at least three months in prison and/or a fine of AED 100,000 to AED 2,000,000. Article 24 says anyone aware of a crime under the law must report it to the Ministry or the public prosecution.

If your financial statements were signed by an unlicensed person, a free zone, bank or the Federal Tax Authority may reject them, and you will need a fresh audit by a properly licensed firm. Separately from discipline, you may also have a civil claim for compensation under Article 25. These provisions were read from the Ministry's published English text; check uaelegislation.gov.ae for later amendments.