Hamriyah Free Zone Audit Requirement

Hamriyah Free Zone Authority (HFZA) publishes two rulebooks on its forms and procedures page: the Implementing Rules and Regulations for Free Zone Establishments (FZE) and for Free Zone Companies (FZC), both issued under Sharjah Emiri Decree No. 6 of 1995. The accounts provisions are the same in substance.

• The directors must prepare a balance sheet and a profit and loss account for each financial year, giving a true and fair view (FZE Article 17(F)-(G)).
• HFZA may require the accounts to follow provisions it sets from time to time (Article 17(H)).
• A parent that owns or controls another entity must also prepare consolidated group accounts (Article 17(I)).
• At least one director signs the balance sheet and profit and loss account (Article 17(J)).
• A copy of the annual accounts goes to the FZE Unit within three months of year end, or such longer period as HFZA determines (Article 17(K); FZC Article 19(J)).
• The entity must appoint an auditor approved by HFZA and deliver the signed auditor's report with the accounts (Article 17(L)-(M); FZC Article 19(K)-(L)).

There is no turnover threshold or small-company exemption in these articles. The duty applies to every FZE and FZC.

The core deadline is three months after the financial year end: 31 March for a 31 December year end. HFZA can extend it, but only the Authority can grant the extension, so ask before the date passes.

The first financial year starts on incorporation and must be at least six and no more than 18 months, fixed by shareholders' resolution filed within 15 days. A later change of year end cannot create a year longer than 15 months or shorter than six (FZE Article 17(D)-(E)).

Renewal is linked through HFZA's own forms. Its Audit Submission Undertaking states that the company undertakes to submit audited financials for a stated period by a stated date, and that the licence is being renewed on the basis of that undertaking. Failure to submit, the form says, will result in penalties and other penal measures. So a renewal can proceed before the audit is ready, but only against a written promise with a date.

Compare this with the nine-month corporate tax deadline: in Hamriyah the zone date comes first.

The Implementing Rules are explicit: the auditor must be chosen 'from among those approved by the HFZ Authority'. An audit by a firm outside HFZA's approved auditors does not meet Article 17(L) or Article 19(K), even if the firm is licensed elsewhere in the UAE.

The auditor reports to the shareholders on whether the annual accounts have been properly prepared under the Implementing Rules and give a true and fair view of the financial position at year end, the profit or loss for the year and, where relevant, the consolidated position.

We did not find the list of approved auditors on the HFZA website, so ask HFZA's Finance and Accounts department for the current list before you sign an engagement letter. Check the firm against the Ministry of Economy register as well, because the profession is regulated federally under Federal Decree-Law No. 41 of 2023. Our approved auditors by free zone page compares lists across authorities.

HFZA also publishes an Audit Waiver Undertaking. Under it, the owner or director undertakes to submit the audited financial statements at any time in future and to follow HFZA's instructions. The form says HFZA is giving a temporary waiver from submission for the stated year or years based on the undertaking, and that any waiver fee paid is not refunded if HFZA revokes the conditional waiver. The form does not state the fee amount or who qualifies. The waiver is temporary and conditional, not an exemption.

On penalties, Article 25(B) of the FZE Rules and Article 27 of the FZC Rules allow HFZA to impose a daily fine for non-compliance with the Rules, circulars or licence terms. The published text leaves the daily amount blank, so we do not state one; ask HFZA. Missing the three-month deadline without an extension or undertaking is a breach that falls within this power.

Take a Hamriyah FZE with a 31 December 2025 year end that claims QFZP status and whose tax period matches its financial year.

1. January to February 2026: close the books, confirm the auditor is on HFZA's current approved list, and give the auditor access to records.
2. By 31 March 2026: deliver the signed annual accounts and the auditor's report to the FZE Unit under Article 17(K)-(M), unless HFZA has granted a longer period.
3. If renewal falls before the audit is signed: sign HFZA's Audit Submission Undertaking with a realistic date, then meet it.
4. By 30 September 2026: file the corporate tax return, using the same audited statements to support the QFZP claim.

The zone date is six months earlier than the tax date, so the audit timetable should be built around HFZA, not the FTA.

The federal rule runs in parallel. For tax periods starting on or after 1 January 2025, Ministerial Decision No. 84 of 2025 requires audited financial statements for every Qualifying Free Zone Person at any revenue, any taxable person with revenue above AED 50 million, and every tax group. Ministerial Decision No. 82 of 2023 covered earlier periods.

An audit waiver from HFZA does not waive the tax requirement. A company claiming the 0% rate needs audited statements for the FTA in the same year, so a waiver rarely saves anything for a QFZP. Plan one audit that meets HFZA's three-month date and supports the tax return.

A QFZP that distributes goods in or from a Designated Zone should check whether it needs an agreed-upon procedures report under FTA Decision No. 6 of 2026, and should not assume Hamriyah's Designated Zone status without checking the official list. If you are closing the company, see Hamriyah licence cancellation.