Introduction

Dubai Executive Council recently issued Resolution No. 11 of 2025 regulating the Free Zone Establishments' Conduct of their Business within the Emirate of Dubai (Resolution), and it is a new regulation that allows free zone establishments (FZEs) to expand their operations to onshore Dubai.

Pursuant to the Resolution, FZEs in Dubai, with the exception of financial institutions licensed within the Dubai International Financial Centre, can apply to the Dubai Department of Economy and Tourism (DET) for one of the following new types of licence/activity permit:

• Branch Licence (to establish a branch of an FZE in onshore Dubai) – this type of licensing arrangement is already permitted under the existing licensing regime;
• Branch Licence with Headquarters in a Free Zone (to establish a branch of an FZE in onshore Dubai while keeping its headquarters within the free zone); and
• Activity Permit for Specific Operations (to hold a temporary permit to conduct specific activities in onshore Dubai without the requirement to open a branch).

Implementation

FZEs may only carry out approved economic activities in onshore Dubai. The list of permitted activities that an FZE may undertake is expected to be published by the DET within six months of the Resolution's issuance. It is anticipated that the permitted activities will differ depending on the type of licence and activity permit held.

In order to comply with the Resolution, FZEs that are licensed or permitted to operate in onshore Dubai must maintain separate financial records for their onshore and free zone operations. This is consistent with the requirements under the existing licensing regime for branch offices.

In addition, FZEs must ensure that they are operating in compliance with all applicable federal and local laws and, in particular, the conditions for employing the establishment's workforce (the DET is expected to issue guidelines on these specific conditions in due course).

All FZEs wishing to avail of the new licences and permits must adhere to the Resolution's provisions within one year of its publication in the Official Gazette. A one-year extension may be granted at the discretion of the Director General of the DET.

Impact on Dubai's business environment

This is a significant development which improves the ease of doing business in Dubai. The Resolution aims to make Dubai an even more attractive destination for entrepreneurs and multinational corporations and is one of the recent legislative developments introduced with Dubai's D33 Economic Agenda in mind – one of the key goals of which is to double the size of Dubai's economy over the next decade and consolidate its position among the top three global cities.

By facilitating FZEs' greater access to the onshore Dubai market, the Resolution promotes business expansion, operational flexibility and increased competitiveness.

To speak to us in relation to how we can support you or your business in the UAE, please contact one of our lawyers who would be delighted to assist.