Imagine a Dubai-based tech startup celebrating a record year—only to be blindsided at license renewal when the team scrambles for an “audited special purpose financial statement” they’ve never needed before. In 2025, stories like this are set to multiply across the UAE as Ministerial Decision No. 84 shakes up corporate tax and audit compliance for both new and established businesses.
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Ministerial Decision 84 transforms UAE audit requirements in 2025—explore new mandates for tax groups, QFZPs, and IFZA companies. Stay compliant and save.

What Has Changed? Unpacking Ministerial Decision 84 of 2025

Ministerial Decision No. 84, issued in April 2025, marks a watershed in UAE’s financial reporting landscape. The new rules leave few large or multi-entity businesses untouched, extending mandatory audited financial statements UAE requirements and redefining risk for those caught unprepared.
Key takeaways:

• All tax groups must now prepare audited special purpose financial statements—no revenue threshold applies.
• Single entities (non-groups) must prepare audited financials if their UAE revenue exceeds AED 50 million for the period.
• All Qualifying Free Zone Persons (QFZPs) are subject to audit requirements, regardless of revenue.
• IFZA (International Free Zone Authority) companies face their own transparency revolution: from September 30, 2025, audited (or simplified, if qualifying) financials are mandatory for every trade license renewal—no industry exemptions.

UAE Audit and Reporting: The New 2025 Compliance Map

Ministerial Decision 84’s scope is broad, imposing a tiered approach that demands new levels of readiness. Here’s how it breaks down:
Who Must Prepare Audited Financial Statements?

Tax Groups:

• All tax groups—regardless of size—must prepare and maintain audited special purpose financial statements for tax years starting January 1, 2025 onward.
• Group members don’t need separate audited reports; aggregation is allowed, provided intra-group transactions are eliminated.

Non-Group Entities:

• Revenue over AED 50 million for the relevant period triggers audit—applies to non-resident persons only for UAE-sourced revenue.

Qualifying Free Zone Persons:

• Audit remains mandatory, ensuring substance and 0% corporate tax eligibility (regardless of turnover).

IFZA Licensees:

• From September 30, 2025, all IFZA-registered companies and branches need to submit financial statements for renewal—audited for larger/funded firms, simplified for those under AED 3M turnover and <10 staff.

Common Pain Points and Real-World Scenarios
Why does this matter—and what can go wrong? Here are some real-world issues businesses will now face:

• Administrative Overload: Many tax groups and Free Zone entities have never prepared “special purpose” audited statements. Compliance teams face a steep learning curve.
• Surprise Audit Triggers: Fast-growing SMEs can unexpectedly cross the AED 50M revenue threshold midway through the year, with little time to prepare.
• IFZA’s Catch-All Rule: Even micro-entities in IFZA must submit financial statements; larger firms need a full audit or risk license non-renewal.
• Audit-Readiness for Multi-Nationals: For tax groups or QFZPs, failing to align report formats and timelines may lead to rejected returns or loss of tax benefits.
• Penalties: Failure to comply can result in return rejection, loss of Free Zone status, administrative penalties, and risk during M&A or restructuring.

Case in Point:
A UAE property group (tax group status, AED 120M turnover) failed to aggregate inter-entity accounts—result: late audit, delayed corporate tax filing, and a threatened tax benefit loss.

Special Spotlight: IFZA Financial Reporting Revolution
From September 30, 2025, all IFZA licensees are required to submit financial statements with every renewal, making reporting mandatory for thousands of UAE Free Zone SMEs.

Threshold for Audit vs. Simplified Statement:

• Annual turnover over AED 3M or ≥10 staff: audited financials by an IFZA-approved auditor.
• Turnover ≤ AED 3M and <10 staff: may submit a simplified (unaudited) statement if requirements are met.

No Renewal Without Submission:

• Failing to comply bans license renewal—no exceptions.

Who Prepares the Audit:

• Must be by an auditor registered and approved by IFZA.

Timeline:

• Enforcement begins for renewals on/after September 30, 2025.

Preparing for Compliance: Strategies and Roadmap
Staying ahead in this new era of corporate tax compliance takes more than superficial paperwork—a systematic approach is vital:

Assess Your Status:

• Are you part of a tax group, QFZP, or IFZA-registered? Cross-check revenue and activities NOW.

Select Qualified Auditors Early:

• High demand for accredited audit firms is likely—secure your slot months ahead.

Prepare IFRS-Compliant Records:

• All financials must align with International Financial Reporting Standards (IFRS).

Implement Internal Controls:

• Ensure reliable books, retention policies (7 years), and clear aggregation for all group entities.

Stay Alert to Further Guidance:

• The FTA and Ministry of Finance are expected to issue more clarifications—subscribe to updates and seek professional advice.

Integrate Audit with Corporate Tax Filing:

• Plan timelines so audits conclude well before the filing deadline, avoiding last-minute risks.

Review IFZA & Free Zone Rules:

• Check if you qualify for simplified statements, but prepare for a full audit if you grow.

Conclusion
Ministerial Decision 84 closes loopholes and sets a new bar for audited financial statements UAE and corporate tax transparency. For businesses, audit compliance in 2025 isn’t just about ticking a box—it is the key to maintaining tax advantages, investor confidence, and regulatory peace of mind.
Are you prepared? Audit readiness is no longer optional. Start now: review your structure, book your auditor, and future-proof your reporting processes before the 2025 deadlines arrive.
Take action:
Download our 2025 UAE Audit Compliance Checklist or contact ASC Group for end-to-end tax advisory and audit support.
Engagement:
How is your company coping with the new audit rules? Share experience, tips, or ask a question below—and pass this resource to others navigating Ministerial Decision 84.

FAQs
Q: What if my entity joins a tax group mid-year?
Audited special purpose consolidated statements will be required for the whole group, not individual members.
Q: I run an IFZA company with AED 2M turnover—what happens after Sept 30?
You might qualify for a simplified statement, but confirm with IFZA and prepare for future audit obligations if the business grows.
Q: What’s the risk of NOT complying?
Return rejection, license suspension, administrative penalties, and lost Free Zone/tax group tax breaks.
Q: Are special rules expected for QFZPs in distribution activities?
Further procedural detail is expected—monitor Ministry of Finance circulars.
Q: How do I aggregate inter-company financials for a tax group?
Follow FTA Public Clarification CTP007—eliminate intra-group balances, consolidate revenues, and prepare a standalone statement.