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Internal Audit in the UAE

Internal audit in the UAE: what the Commercial Companies Law actually requires, the licensing question nobody has answered, and how to check a provider.

internal audit

Internal audit is a management assurance function that reports to the board or an audit committee, and it is not the statutory audit required by Article 27(1) of the Commercial Companies Law. No general federal rule makes it compulsory for private UAE companies. Where it is required, the duty comes from sector regulation, a listing rule, or the company's own governance framework.

Basis: UAE Ministry of Economy and Tourism

Occurrences of the phrase internal audit in the English Commercial Companies Law
Zero, in the 70-page Ministry text searched on 17 August 2026

Federal Decree-Law No. 32 of 2021, full-text search of the Ministry's published English PDF

How the profession law defines Other Assurances' Services
Expressly includes the services of internal audit

Article 1, Federal Decree-Law No. 41 of 2023

Who may render services of the profession
No natural or juristic person, except after obtaining the licences in the Decree-Law

Article 6(1), Federal Decree-Law No. 41 of 2023

Penalty for practising the profession without a professional licence
Prison of not less than 3 months and/or a fine of AED 100,000 to AED 2,000,000

Article 27, Federal Decree-Law No. 41 of 2023

Statutory auditor may not hold an executive role in the company
No board seat and no technical, administrative or executive office

Article 246(3), Federal Decree-Law No. 32 of 2021

Ceiling on fines for breaching corporate governance rules
AED 10,000,000

Article 7, Federal Decree-Law No. 32 of 2021

How long an accounting firm must keep engagement working papers
At least 10 years from the date the report was issued to the client

Article 19(1), Federal Decree-Law No. 41 of 2023

What this site publishes about its own credentials
Nothing — no professional licence number, no fee, no address, and no claim to sign an audit

Editorial standards, this site

#What the function is, and what it is not

Internal audit is an ongoing examination of a company's own risks, controls and governance, performed for the people running the company and reported to the board or an audit committee. It can be staffed in house, co-sourced, or bought in as an outsourced engagement.

That is a different product from the audit most UAE businesses buy once a year. The statutory audit is an independent opinion on financial statements, owed to shareholders: Article 27(1) of Federal Decree-Law No. 32 of 2021 requires every joint stock company and limited liability company to have one or more auditors auditing its accounts on a yearly basis, and the auditor's report goes to the general assembly under Article 248(1), with a copy to the Authority and the competent authority.

The two are structurally different rather than merely different in emphasis, and company law makes that explicit. Article 246(3) says the auditor shall not combine the profession of auditor with the capacity of a shareholder, nor occupy the office of board member or any technical, administrative, or executive office in the company. An internal auditor holds exactly such an office. The firm signing your statutory audit therefore cannot also be your internal audit function, and a proposal that offers both to the same entity in the same year should be questioned before it is priced.

#Is it mandatory? What UAE company law actually says

It says nothing. We searched the full English text of the Commercial Companies Law published by the Ministry of Economy and Tourism — 70 pages, read on 17 August 2026 — for the phrases internal audit, audit committee and internal control. There are no occurrences. The Decree-Law regulates the external auditor at length, in Articles 245 to 249, and does not create an internal audit function at all.

So the honest answer to is internal audit mandatory in the UAE is that there is no general federal duty on a private company, and any provider telling you otherwise should be asked to name the article. What does exist is a set of narrower routes by which the obligation reaches a particular business, and they are the ones worth checking against your own facts.

The most important of those sits in Article 6 of the Commercial Companies Law. Governance is defined in the Decree-Law as a set of controls, standards and procedures achieving corporate governance at management level, and Article 6(1) hands the making of governance decisions to the Minister for companies other than public joint stock companies, and to the Board of the Securities and Commodities Authority for public joint stock companies — while expressly preserving the Central Bank's requirements for the financial institutions under its supervision. Article 7 then says those governance decisions carry fines of up to AED 10,000,000. That is where a UAE internal audit requirement usually comes from: a governance instrument, not the company law itself.

Where a UAE internal audit obligation can actually come from
Source of the dutyWho sets itWhat to read
Commercial Companies LawFederal legislatorNothing — the Decree-Law creates no internal audit function
Corporate governance decisionThe Minister, or the SCA Board for public joint stock companiesArticle 6(1) of Federal Decree-Law No. 32 of 2021 and the decision issued under it
Prudential regulation of financial institutionsCentral Bank of the UAEThe Central Bank's own requirements, preserved by Article 6(1)
Financial free zone rulebooksDFSA in the DIFC; the equivalent regulator in ADGMThe regulator's own rulebook, in the free zone where you are licensed
Listing and market rulesThe market on which the securities are listedThe listing rules that apply to your class of securities
The company's own frameworkBoard or shareholdersYour internal audit charter, shareholder agreement or group policy

#The licensing question the Ministry has not answered

This is the part of the topic that matters most when you are buying the service, and it is unresolved. We are setting out both halves of it rather than picking one.

Article 1 of Federal Decree-Law No. 41 of 2023, which regulates the accounting and auditing profession, defines Other Assurances' Services as services the chartered accountant and the accounting firms are licensed to provide, related to the financial statements, that provide assurances to external parties about financial information or verify compliance with accounting standards, financial rules and the internal controls of economic facilities — including, in the article's own words, the services of internal audit. Article 4 puts auditing, review, other assurances and related services inside the scope of the profession. And Article 6(1) provides that no natural or juristic person shall practise the profession in the State, or render any of the services of the profession or the related services, except after obtaining the licences stipulated in the Decree-Law and its Executive Regulation.

Read in sequence, those three articles raise a real question: does an outsourced internal audit engagement fall inside the licensed activities, so that only a firm holding the Ministry's professional licence may sell it?

We found no Ministry guidance resolving it, and we are not going to resolve it for you. There is a serious argument each way. The definition opens by describing services that licensees are licensed to provide and ties them to the financial statements, which can be read as scoping the term to work done by the profession rather than capturing every internal audit engagement in the country — and internal audit is in fact performed daily by employees and by consultancies that hold no professional licence. Against that, the words including … the services of internal audit are in the definition, and Article 6(1) is drafted broadly enough to reach any of the services of the profession.

The practical response is not to form a view. It is to ask.

What to ask a prospective provider

Ask for the firm's professional licence number issued by the Ministry of Economy and Tourism, and the name and licence number of the chartered accountant who will sign anything issued to you. A firm that holds one has removed the question entirely. A firm that does not should be able to explain, in writing, why it considers the engagement to sit outside Article 6(1) — and if it cannot, that is your answer about how carefully it has read the law it works under.

Note what this is not. Article 14 requires an accounting firm to hold an economic licence as well, and makes the emirate's licensing authority verify the Ministry's approval before issuing it. A trade licence listing audit as an activity is not the professional licence, and a certification held by an individual is not a licence at all.

Why the answer is not academic

Article 27 of Federal Decree-Law No. 41 of 2023 makes practising the profession without a professional licence a criminal offence: imprisonment of not less than three months and/or a fine of AED 100,000 to AED 2,000,000, with the court able to order cancellation of the licence or closure of the firm on conviction.

That penalty attaches to practising the profession. Whether an outsourced internal audit engagement is practising the profession is precisely the open point. Which is why the sensible position for a buyer is to prefer the provider for whom the question cannot arise.

#What a competent engagement looks like, step by step

Internal audit is sold under a dozen names — controls review, risk assurance, governance health check, SOX-style testing. The engagement underneath should look roughly the same regardless of the label, and if a proposal skips two of these steps you are buying a report rather than assurance.

  1. Fix the reporting line before the scope

    Internal audit that reports to the finance function it is testing is not assurance. Settle in writing who the function reports to — the board, an audit committee, or the owners — who may change its scope, and who sees the findings before management does. This is the single decision that determines whether anything else on the list is worth paying for.

  2. Build a risk assessment you can argue with

    The plan should start from the risks that would actually hurt this business, ranked, with the reasoning visible. A plan that mirrors last year's, or that mirrors a template, has not been made for you. For a UAE company the register should reach beyond finance: licensing conditions, WPS and labour obligations, sanctions and anti-money-laundering exposure, and the tax deadlines that carry fixed penalties.

  3. Write the scope down, including what is excluded

    An engagement letter that lists processes in scope, the period covered, the standard being applied and — explicitly — what is not being looked at, prevents the two arguments that end most internal audit relationships: a finding the business says was out of scope, and a failure the business assumed was covered.

  4. Test transactions, do not just walk through processes

    A walkthrough tells you what the control is meant to be. Sampling tells you whether it happened. Ask how many items will be tested, how the sample is selected, and what happens when an exception is found: whether the sample is extended, and whether the exception is reported or resolved quietly with the process owner.

  5. Cover the related-party picture deliberately

    Article 248(1) of the Commercial Companies Law makes reviewing transactions with related parties a duty of the statutory auditor, and Article 34 of the Corporate Tax Law requires those same transactions to be priced at arm's length. Internal audit is the natural place to find out whether the controls around intercompany pricing, approvals and documentation actually work — before either the auditor or the Federal Tax Authority asks.

  6. Report with owners and dates, then follow up

    A finding without a named owner and an agreed date is an observation. The value of internal audit is almost entirely in the follow-up cycle: re-testing what was supposed to be fixed, and reporting to the board what was not. Agree the follow-up in the engagement, not afterwards.

  7. Agree who keeps the working papers, and for how long

    If your provider is a licensed accounting firm, Article 19(1) of Federal Decree-Law No. 41 of 2023 requires it to keep the data and documents of contracted work for at least ten years from the date the report was issued, running instead from final judgment where the matter is litigated, and Article 19(2) puts that duty on the partners personally if the licence is cancelled. If your provider is not a licensed firm, that statutory floor does not apply to it — so put the retention period in the contract.

#Checking the provider, and why we will not rank firms

Searches for internal audit companies in the UAE return ranked lists, and none of the ones we looked at publish a methodology. We are not going to add another. A ranking that cannot tell you how it was ordered is an advertisement with numbers on it, and the firms that pay to appear on those lists are not necessarily the firms that would staff your engagement.

The checks that separate providers are duller and far more useful. Ask for the professional licence number, as above. Ask who personally will do the work and how many days each of them is allocated — internal audit is sold by partners and delivered by juniors more often than any other assurance product. Ask for the independence position: Article 17 of Federal Decree-Law No. 41 of 2023 restricts a practitioner from contracting for services that contravene independence where independence is required, from being a partner or agent of a founder, partner or director of the entity engaged, from being its creditor or debtor beyond the fees, and from taking part in the incorporation or management of an establishment it served in the previous two years.

Two further conditions are worth asking about because they are in the same law. Article 16(2)(b) requires an accounting firm to hold professional liability insurance covering the firm and its chartered accountants, with the firm bearing the premiums. Article 18 limits confidentiality to a defined list of exceptions — the client's own request or consent, a judicial or investigating authority, a request from the Ministry, the prevention or reporting of a crime, and self-defence before an investigating or judicial body. If a provider's engagement letter gives itself wider disclosure rights than that, ask why.

#Standards, the association, and the conference and training searches

The standards used by internal auditors in the UAE are not issued by a UAE authority. They are the Global Internal Audit Standards published by the Institute of Internal Auditors, a mandatory component of its International Professional Practices Framework, organised into five domains: the purpose of internal auditing, ethics and professionalism, governing the internal audit function, managing the internal audit function, and performing internal audit services. The IIA states that all internal audit functions are expected to conform.

Read that expectation correctly. It is a professional expectation set by a private body, not UAE law. It becomes binding on your company only where a regulator, a listing rule or your own internal audit charter adopts it — which is a good reason to have the charter say which version of the standards applies.

The association people are searching for is the UAE Internal Auditors Association, which describes itself as the premier professional body for internal auditors in the UAE and as part of the IIA global network, and which publishes membership, training, conference and quality-assurance services along with an events calendar. Conference and training-calendar dates change, and a date copied onto a third-party page rots quietly, so we do not reproduce them: read the association's own calendar on the day you need it.

Searches that specify an emirate — internal audit in Abu Dhabi, a conference in Abu Dhabi, internal audit in Dubai — are almost always looking for a provider or an event rather than a different rule. The federal instruments on this page apply across all seven emirates. What changes with location is the economic licence, issued by the emirate's own licensing authority under Article 14 of Federal Decree-Law No. 41 of 2023, and whether the entity sits inside a financial free zone: Article 5(1) of the Commercial Companies Law disapplies the Decree-Law to companies incorporated in a free zone where that zone's own laws so provide, and pulls them back inside it if those laws let them operate outside the zone in the State.

#Head of internal audit, director, manager: the role queries

A large share of the searches on this topic are about roles rather than engagements — head of internal audit, internal audit director, internal audit manager, internal audit roles in Abu Dhabi and Dubai. The role taxonomy is worth stating because it also tells a buyer how an outsourced team should be structured.

The chief audit executive — commonly titled head of internal audit — is the person the standards make responsible for managing the function in accordance with the internal audit charter, and is the role that owns the reporting line into the board or audit committee. A director typically owns a portfolio of audits and the relationship with senior management. A manager runs individual engagements, supervises fieldwork and drafts findings. Where the function is outsourced, the same three layers should be visible in the fee proposal, with days attached to each; where they are not, the work is likely to be performed a level or two below what was sold.

We do not publish salary figures for internal audit roles, and the reason is specific rather than cautious. The bands circulating on UAE advisory blogs trace back to recruitment surveys that we cannot open to verify: on 17 August 2026, Cooper Fitch's salary guide sits behind a lead-capture form demanding a company email address, Michael Page's is behind a full user-registration form, and Bayt's UAE salary pages returned HTTP 403. Reproducing a number from a source we could not read would be inventing it at one remove. A recruiter who actually places internal audit roles will give you a better answer than any range we could responsibly print.

#What this page does not claim about us

This is a reference page, and the same standard we ask you to apply to a provider applies here.

We publish no fee, day rate, package price or turnaround commitment for internal audit or for anything else — not because they are secret, but because a price quoted before anyone has seen your entity structure, systems, transaction volume and regulatory perimeter is a price for a form rather than for the work. We publish no professional licence number, no audit licence, no tax agent registration and no certification claim, because none has been verified for publication here; when one exists it will appear with its number so you can check it against the register rather than take our word for it. We publish no office address, no location claim and no telephone number. We make no claim to be able to perform or sign a statutory audit — that is a licensed activity under Federal Decree-Law No. 41 of 2023, and the auditor whose name goes on the report should be findable in the Ministry of Economy and Tourism's practising auditors register before you engage them.

And every page on this site carries a review status of draft until a person holding a UAE credential has read it and signed it off. Ask us for the same number we have told you to ask others for; the absence of an answer is itself information.

Sources and legal basis

This page relies on

  • Federal Decree-Law No. 41 of 2023 Concerning the Regulation of the Accounting and Auditing Profession
  • Article 1 of Federal Decree-Law No. 41 of 2023 (definition of Other Assurances' Services, including internal audit)
  • Article 3 of Federal Decree-Law No. 41 of 2023 (scope, including free zone firms practising outside the zone)
  • Article 4 of Federal Decree-Law No. 41 of 2023 (scope of services of the profession)
  • Article 6(1) of Federal Decree-Law No. 41 of 2023 (prohibition on unlicensed practice)
  • Article 14 of Federal Decree-Law No. 41 of 2023 (economic licence of accounting firms)
  • Article 16 of Federal Decree-Law No. 41 of 2023 (obligations, internal control system, professional liability insurance)
  • Article 17 of Federal Decree-Law No. 41 of 2023 (restrictions and independence)
  • Article 18 of Federal Decree-Law No. 41 of 2023 (confidentiality and its exceptions)
  • Article 19 of Federal Decree-Law No. 41 of 2023 (working papers kept 10 years)
  • Article 27 of Federal Decree-Law No. 41 of 2023 (criminal penalty for unlicensed practice)
  • Federal Decree-Law No. 32 of 2021 (Commercial Companies Law)
  • Article 5(1) of the Commercial Companies Law (companies in free zones)
  • Article 6 of the Commercial Companies Law (corporate governance decisions)
  • Article 7 of the Commercial Companies Law (fines up to AED 10,000,000 for breach of governance rules)
  • Article 27(1) of the Commercial Companies Law (yearly audit of the accounts)
  • Article 246 of the Commercial Companies Law (conditions and independence of the auditor)
  • Article 248 of the Commercial Companies Law (duties of the auditor, including related-party transactions)
  • Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses
  • Article 34 of the Corporate Tax Law (arm's length principle)
  • Federal Decree-Law No. 28 of 2022 on Tax Procedures
  • Article 46 of the Tax Procedures Law (limitation period, renumbered by Federal Decree-Law No. 17 of 2025)
  • Ministerial Decision No. 84 of 2025 on Audited Financial Statements
  • UAE Ministry of Economy and Tourism
  • Practising auditors register
  • Securities and Commodities Authority
  • Central Bank of the UAE
  • Dubai Financial Services Authority (DFSA)
  • Dubai International Financial Centre (DIFC)
  • Federal Tax Authority (FTA)
  • Institute of Internal Auditors (IIA)
  • Global Internal Audit Standards
  • International Professional Practices Framework (IPPF)
  • UAE Internal Auditors Association
  • Chief audit executive
  • Audit committee
  • Other Assurances' Services
  • Qualifying Free Zone Person
  1. Federal Decree-Law No. 41 of 2023 Concerning the Regulation of the Accounting and Auditing ProfessionUAE Ministry of Economy and Tourism
  2. Auditing and accounts legislations — the Ministry's index of instruments governing the professionUAE Ministry of Economy and Tourism
  3. Federal Decree-Law No. 32 of 2021 on Commercial CompaniesUAE Ministry of Economy and Tourism
  4. Request to register natural persons in the practising auditors registerUAE Ministry of Economy and Tourism
  5. Global Internal Audit Standards and the five domains of the IPPFThe Institute of Internal Auditors
  6. UAE Internal Auditors Association — membership, training, conferences and quality assuranceUAE Internal Auditors Association
  7. UAE Internal Auditors Association events calendar — check dates here rather than on a third-party pageUAE Internal Auditors Association
  8. DFSA Rulebook — returned HTTP 403 to us on 17 August 2026; open it in a browserDubai Financial Services Authority
  9. Ministerial Decision No. 84 of 2025 on Audited Financial StatementsUAE Ministry of Finance

Rates, thresholds and deadlines change. Every figure above is linked to the authority that publishes it — if the two ever disagree, the authority is right and this page is out of date. Tell us and we will fix it.

FAQ Answers to the questions people actually ask

Frequently asked questions

Is internal audit mandatory in the UAE?

Not as a general rule. The Commercial Companies Law creates no internal audit function at all, and a full-text search of the Ministry's published English text on 17 August 2026 returned no occurrence of the phrase. Where an internal audit duty exists it comes from a corporate governance decision issued under Article 6 of that law, from sector regulation such as the Central Bank's, from a financial free zone rulebook, from listing rules, or from the company's own governance framework.

How much does an internal auditor earn in Dubai?

We do not publish a figure, and we would rather say so than reproduce one. The salary bands repeated across UAE advisory sites trace back to recruitment surveys we could not open to verify: on 17 August 2026 two of the major guides were behind lead-capture and registration forms and a third returned an access error. A specialist recruiter will give you a current answer for the specific role, sector and seniority.

Is audit mandatory in the UAE free zone?

For corporate tax purposes every qualifying free zone person must prepare and maintain audited financial statements at any level of revenue, under Ministerial Decision No. 84 of 2025. Free zone authorities also set their own filing conditions for licence renewal. Both of those concern the statutory audit, not internal audit — no free zone rule turns a statutory audit into an internal audit function, and the two cannot be provided by the same firm to the same entity.

Who is eligible for internal audit?

Any company can commission it, and companies with a board, external investors, multiple locations or regulated activity get the most from it. On who may perform it, the position is unsettled. Article 1 of Federal Decree-Law No. 41 of 2023 places internal audit inside Other Assurances' Services and Article 6(1) bars unlicensed practice, but no Ministry guidance we could find says whether outsourced internal audit needs the professional licence. Ask the provider for its licence number.

What internal audit standards apply in the UAE?

The Global Internal Audit Standards published by the Institute of Internal Auditors are what practitioners work to. They are a mandatory component of the International Professional Practices Framework and are organised into five domains covering purpose, ethics and professionalism, governing the function, managing the function, and performing internal audit services. They are professional standards issued by a private body, so they bind your company only where a regulator, a listing rule or your own charter adopts them.

Is there an internal audit association in the UAE?

Yes. The UAE Internal Auditors Association describes itself as the premier professional body for internal auditors in the country and as part of the Institute of Internal Auditors global network, and publishes membership, training, conference and quality-assurance services along with an events calendar. Its site is uaeiaa.org. Confirm the domain before entering any personal or payment details, because a similar-looking domain served unrelated gambling content when we checked it.

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