DAFZA Audit Requirement: Who Must Audit and When

Yes, for every company. The DAFZ Download Centre, under the heading Official Auditors of DAFZ, states that as per the regulations all companies (FZE and FZCO) registered in DAFZ have to conduct their annual audit of financial statements from auditors approved by the Authority. There is no turnover or size exemption in that statement, unlike the simplified route some other zones now offer.

The legal framework is Dubai Law No. 25 of 2009 concerning the Dubai International Airport Free Zone, with the detail in the DAFZA Rules and Regulations 2021. In the part on records, accounts and auditor, Regulation 65.1 requires an FZCO to maintain accounting records, prepare accounts and have them audited. Regulation 67.2 requires the accounts to follow the standards prescribed or approved by the Registrar and to give a true and fair view, and Regulation 67.3 requires them to be approved and signed by at least one director.

The one published exception is for individuals rather than companies. DAFZ's Talent Pass page says freelancers are not required to do an annual audit, although they are advised to keep accurate accounts. If you hold a Talent Pass and later convert to a company, the audit obligation starts with the company's first financial year.

DAFZA publishes no single headline deadline, so the Regulations are the starting point, and they need careful reading.

• Regulation 67.5 (FZCO), as published: "within thirty (30) days after the end of the Financial Year, the accounts for that year shall be (a) prepared and approved by the Directors; and (b) examined and reported upon by an auditor."
• Regulation 65.3(b): the FZCO appoints its auditor within six months after the financial year end (or earlier, if before accounts are sent to shareholders), by directors' resolution unless the shareholders appoint by ordinary resolution.
• Regulation 67.6(b): the FZCO files its accounts with the Registrar within 30 days after they have been examined and reported upon by an auditor.
• Regulation 67.4 (PLC): accounts prepared, audited, laid before the general meeting and sent to shareholders within six months of the year end, then filed within 30 days after circulation.

The 30-day audit wording in Regulation 67.5 sits oddly with a rule that allows the auditor to be appointed up to six months after year end. We present it exactly as published. Before you plan your close, confirm the working deadline in writing with DAFZA, and then file within 30 days of the audit report.

Your audit cycle runs from the financial year set under Regulation 66. The first financial year may run for up to 18 months (Regulation 66.1), and later financial years are 12 months, with a tolerance of seven days either way (Regulation 66.3). A company formed in mid-2025 could therefore have a first year ending 31 December 2026, with its first audit after that date.

The Regulations then set out the people involved:

• the auditor must give written consent to act and meet the independence and conflict rules (Regulations 65.7 and 65.8);
• shareholders can remove the auditor by ordinary resolution (Regulation 65.9), and the Court may remove an auditor on the Registrar's application (Regulation 65.10);
• each shareholder is entitled to a copy of the accounts within seven days (Regulation 68);
• the auditor's report must state whether the accounts give a true and fair view (Regulation 69), and Regulation 70 sets the auditor's duties.

Keep the board or shareholder resolution appointing the auditor, the signed consent and the director-approved accounts together. These are the documents you will need if DAFZA asks how the timetable was met.

Only an auditor approved by DAFZA can sign. The Download Centre links the approved auditors list ("Click to view approved auditors list"), published as dated PDFs; the latest version seen in search results was dated 17 September 2025. Check the firm against the current list before fieldwork starts, and again if you change auditors mid-year. Our approved auditors by free zone page explains how each zone publishes its list.

Records matter as much as the report. Regulation 65.1 requires records to be kept for at least six years. That is longer than the five years in some other free zone rulebooks, so a group with companies in several zones should apply the longer period to its DAFZA entity.

On penalties, Regulation 67.7 makes a company that fails to comply with Regulation 67 liable to a fine. The Regulations do not state the amount, and we could not find a published figure from DAFZA, so ask the Authority rather than relying on figures quoted by third parties. For how DAFZA compares with other zones, see free zone audit deadlines 2026 and the authority-by-authority guide.

The DAFZA rule is a free zone requirement. Corporate tax adds a separate test under Ministerial Decision No. 84 of 2025, which applies to tax periods starting on or after 1 January 2025 and repealed Ministerial Decision No. 82 of 2023. Audited financial statements are required for any taxable person with revenue above AED 50 million, for every Qualifying Free Zone Person whatever its revenue, and for tax groups.

Many DAFZA companies claim the 0% rate as a Qualifying Free Zone Person. For them the two rules overlap: one audited set, signed by a DAFZA-approved auditor, can serve both DAFZA and the corporate tax return, which is due nine months after the end of the tax period (see the filing deadline guide).

A practical sequence for a 31 December year end:

1. Confirm the financial year in your DAFZA records.
2. Appoint a firm from the current DAFZA list by resolution.
3. Confirm the working audit deadline with DAFZA, given the Regulation 67.5 wording.
4. File the audited accounts with the Registrar within 30 days of the audit report.
5. Use the same statements for the corporate tax return by 30 September.