Audited Financial Statements Decision (2023)

Required taxable persons with revenue above AED 50 million and all Qualifying Free Zone Persons to prepare and maintain audited financial statements; repealed by Ministerial Decision No. 84 of 2025 but still applies to tax periods that began before 1 January 2025.

Official title
Ministerial Decision No. 82 of 2023 on the Determination of Categories of Taxable Persons Required to Prepare and Maintain Audited Financial Statements for the Purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses
Instrument
Ministerial Decision No. 82 of 2023
Issued by
Minister of Finance
Jurisdiction
UAE Federal
Dates
issued 10 April 2023
Status
superseded
Repealed by
Ministerial Decision No. 84 of 2025
Topics
Corporate tax · Accounting & audit
Official source
mof.gov.ae
Verified
25 October 2026

Summary

Ministerial Decision No. 82 of 2023 was the first decision to say which Taxable Persons must have their financial statements audited for Corporate Tax. It was issued on 10 April 2023 under Article 54(2) of the Corporate Tax Law (Federal Decree-Law No. 47 of 2022), came into effect fifteen days after publication, and has been superseded: Ministerial Decision No. 84 of 2025 repealed it with effect for Tax Periods commencing on or after 1 January 2025, while providing that it continues to apply to Tax Periods that commenced before that date.

The decision has three articles. Article 1 adopts the definitions of the Corporate Tax Law. Article 2 lists the categories required to prepare and maintain audited financial statements: a Taxable Person deriving Revenue exceeding AED 50,000,000 during the relevant Tax Period, and a Qualifying Free Zone Person. There is no revenue floor for the second category, so a free zone company claiming the 0% rate on Qualifying Income needs audited accounts whatever its size. Article 3 provides for publication and commencement fifteen days after publication.

For a Taxable Person below AED 50,000,000 that is not a Qualifying Free Zone Person, the decision imposes no audit requirement; such a person still has to prepare financial statements under Article 54(1) of the law and the accounting standards set in Ministerial Decision No. 114 of 2023, and keep records for the retention period, but need not have them audited for Corporate Tax purposes.

The 2025 replacement keeps both categories but refines them: the AED 50,000,000 test now applies to a Taxable Person that is not a Tax Group, Tax Groups must prepare audited special purpose financial statements in the form the FTA specifies, a Non-Resident Person counts only Revenue of its UAE Permanent Establishments and nexuses, and Qualifying Free Zone Persons distributing goods from a Designated Zone must follow any additional FTA procedures. Those refinements do not apply retrospectively; for the first Tax Periods under Corporate Tax (those starting between 1 June 2023 and 31 December 2024) the simpler 2023 wording governs.

The decision does not itself prescribe who may audit or in what form; the audit requirement attaches to the financial statements the Taxable Person must prepare under Article 54 of the law.

Who it applies to

For Tax Periods that commenced before 1 January 2025: Taxable Persons with Revenue above AED 50,000,000 in the Tax Period, and every Qualifying Free Zone Person regardless of Revenue. Other Taxable Persons were not required to have audited financial statements for Corporate Tax under this decision.

Key provisions

Article 1Words and expressions take the meanings given in Federal Decree-Law No. 47 of 2022, the Corporate Tax Law.
Article 2(1)A Taxable Person deriving Revenue exceeding AED 50,000,000 during the relevant Tax Period must prepare and maintain audited financial statements for the purposes of Article 54(2) of the Corporate Tax Law.
Article 2(2)A Qualifying Free Zone Person must prepare and maintain audited financial statements, with no Revenue threshold.
Article 3The decision was published and came into effect fifteen days after the date of its publication; it was issued on 10 April 2023 (19 Ramadan 1444H).
Article 3 of Ministerial Decision No. 84 of 2025Repeals this decision but provides that it continues to apply to Tax Periods that commenced before 1 January 2025.

Obligations and deadlines

  • Taxable Persons with Revenue above AED 50,000,000 in a Tax Period starting before 1 January 2025: maintain audited financial statements for that period.
  • Qualifying Free Zone Persons: maintain audited financial statements for every Tax Period starting before 1 January 2025, whatever the Revenue.
  • Keep the audited statements with the Corporate Tax records for the statutory retention period.

Penalties

The decision contains no penalty provision. Failure to keep the records and financial statements required under the Corporate Tax Law is penalised under Cabinet Decision No. 75 of 2023, and a Qualifying Free Zone Person without audited financial statements fails a condition of the 0% regime and is taxed at 9% on its Taxable Income.

In practice — how Polaris handles it

We keep this decision in the library because the first Corporate Tax returns of most of our clients fall under it: a company with a financial year starting 1 January 2024 or 1 June 2023 is judged on the 2023 wording, not the 2025 replacement. Its practical bite was on free zone clients. When a DMCC, RAKEZ or IFZA company elected to be a Qualifying Free Zone Person for its first Tax Period, we built an audit into the compliance calendar regardless of turnover, because without audited financial statements the 0% claim fails. Mainland and offshore holding companies below AED 50,000,000 were told that audited accounts were not required for Corporate Tax, though their free zone or bank may require them anyway. For any FTA review of a 2023 or 2024 period we check the audit position against this decision, and for periods from 2025 we apply Ministerial Decision No. 84 of 2025.

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Source and verification. This page was written from the official text published at mof.gov.ae, read on 25 October 2026. Quoted from that text: “A Taxable Person deriving Revenue exceeding AED 50,000,000 (fifty million United Arab Emirates dirhams) during the relevant Tax Period.”
This summary is published for general information by Polaris Corporate Services FZ-LLC, a licensed Trust and Corporate Service Provider. It is not legal advice and does not replace the official text, which prevails in case of difference. Arabic is the authoritative language of UAE federal and emirate legislation; English translations are provided by the issuing authorities. Instruments change: check the status and the official source before relying on this page.

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