Audited Financial Statements in the UAE: Who Must Have Them

A set of accounts becomes audited financial statements when a licensed auditor has examined them and issued a report on them. The accounts themselves are management's; the report is the auditor's, and it is the report that third parties rely on.

Only a person licensed under Federal Decree-Law No. 41 of 2023 may issue that report. Article 6(1) prohibits practising the profession or rendering its services without the required licences, and Article 27 makes unlicensed practice punishable by not less than three months' imprisonment and/or a fine of AED 100,000 to AED 2,000,000. A report signed by anyone else is not audited financial statements, whatever the covering letter says.

Under Article 247 of the Commercial Companies Law the audit report is read at the general assembly, and Article 27(4) gives any shareholder the right to a free copy of the last audited accounts and the last auditor's report on written request, to be answered within ten days. That right is a useful lever if you are a minority shareholder who cannot get the file from management.

This is where most confusion starts, because the two duties are frequently reported as one.

The company law duty is structural. Article 27(1) of the Commercial Companies Law requires the company to appoint an auditor to audit the accounts each year. There is no revenue threshold, no small-company exemption and no filing size test. A mainland LLC turning over AED 900,000 is inside it.

The corporate tax duty is a threshold test and it was reset by Ministerial Decision No. 84 of 2025, which replaced Ministerial Decision No. 82 of 2023. Article 2(1)(a) requires audited financial statements where a taxable person that is not a tax group derives revenue exceeding AED 50,000,000 in the relevant tax period. Article 2(1)(b) requires them of every qualifying free zone person, with no threshold. Article 2(2) treats tax groups separately: a tax group prepares and maintains audited special purpose financial statements in the form, procedures and rules specified by the Authority. Article 2(4) provides that for a non-resident, only revenue derived through permanent establishments or nexuses in the State counts toward the threshold. Article 4 applies the decision to tax periods commencing on or after 1 January 2025.

For a free zone company chasing the 0% qualifying income rate, the audit is not negotiable. Article 2(1)(b) of Ministerial Decision No. 84 of 2025 requires audited financial statements of every qualifying free zone person at any level of revenue. A newly formed free zone entity with modest revenue is caught in exactly the same way as a large one.

The cost of getting this wrong is disproportionate to the audit fee. Preparing and maintaining audited financial statements is one of the conditions of qualifying free zone person status, and losing that status is not a one-year event: Article 18(2) of the Corporate Tax Law strips it from the beginning of the tax period in which the failure occurs, and the ministerial decision on qualifying and excluded activities extends the consequence across the four subsequent tax periods.

Separately, your free zone authority may require audited statements as a licence renewal condition and may require the auditor to be on its own approved list. That is a zone requirement rather than a federal one, and it sits on top of everything above.

There is no "UAE GAAP". Ministerial Decision No. 114 of 2023 names IFRS, and IFRS for SMEs for taxable persons with revenue up to AED 50,000,000, and nothing else. It also permits the cash basis of accounting at revenue up to AED 3,000,000. The Manual of Federal Government Accrual Accounting Standards published on the Ministry of Finance site is a public-sector document and is not commercial accounting guidance.

Article 27(3) of the Commercial Companies Law points in the same direction, requiring accounts to be prepared in accordance with the International Accounting Standards and Practices.

One consequence surprises people. Ministerial Decision No. 114 of 2023 defines financial statements as including, but not limited to, the income statement, statement of other comprehensive income, balance sheet, statement of changes in equity and cash flow statement. That is a floor set by the standard, not a format set by the State — which is why no authority-issued specimen layout exists.

A large share of the searches reaching this topic are looking for a file — a 2024 PDF, a specimen, or another company's accounts. It is worth being blunt about which of those exist.

There is no public filing register for private UAE company accounts. Unlike jurisdictions with a companies-house model, a mainland LLC's audited statements are filed with its licensing authority and, where relevant, provided to the Federal Tax Authority. They are not published for anyone to download. If you are trying to obtain a UAE private company's accounts, the routes are the shareholder right under Article 27(4) of the Commercial Companies Law, a contractual right such as a lender covenant, or disclosure in litigation.

Listed companies are different in principle, because a public joint stock company's disclosure obligations require publication. We are not summarising those controls here: the Securities and Commodities Authority site serves an application shell whose content could not be read automatically, and the Abu Dhabi Securities Exchange returned 403 to automated requests when checked. Get a listed company's accounts from its own investor relations page or from the exchange, and take the disclosure rule from the regulator rather than from a summary.

A specimen or template does not exist as an official document. Every "UAE financial statement format" PDF circulating in search results is somebody's house style, because Ministerial Decision No. 114 of 2023 sets a minimum content list rather than a layout. Use one if it is helpful, but do not treat it as a compliance requirement.

Ministerial Decision No. 84 of 2025 obliges the taxable person to prepare and maintain audited financial statements. That wording is doing real work and is worth reading precisely.

Maintaining means the statements must exist, be audited and be available if the Federal Tax Authority asks for them. It does not by itself describe a separate lodgement event, and we are not going to describe the mechanics of the corporate tax return submission on this page beyond that, because the tax group's special purpose statements are required in a form the Authority specifies and nobody on this site has read that form. Where a decision defers to a form we have not opened, we say so rather than paraphrasing it.

Your licensing authority is a separate matter with its own conditions and its own dates. Free zone authorities in particular commonly require submission of audited statements as a renewal condition. Take that requirement from your own authority's current portal rather than from a general page, including this one.

Record retention in the UAE is not a single seven-year rule, and quoting the wrong clock is a common and expensive mistake. At least five separate periods can apply to the same business.

The safe approach is to keep to the longest clock that touches your records rather than trying to purge on the earliest. The gap between five years and fifteen is large enough that the discipline is worth the storage.

The realistic failure mode is not refusing to have an audit — it is running out of runway. Two things usually cause it: bookkeeping that is not closed, and a first-year engagement where opening balances have never been verified.

Deal with the sequence rather than the symptom. Close the books and reconcile the balance sheet before fieldwork begins; an auditor cannot audit a moving trial balance and every re-run is re-billed. Appoint the auditor early enough that the general assembly appointment under Article 245 of the Commercial Companies Law is not itself the bottleneck. If a prior year was never audited, tell the incoming auditor at proposal stage, because verifying opening balances is separate work with its own timetable.

If you are already late, the useful move is to get an accurate revised date from the auditor in writing and work backwards from your hardest external deadline — the corporate tax filing date for a qualifying free zone person, the licence renewal date for a zone that requires statements at renewal. Guessing at the recovery date is what turns a late audit into a missed filing.