Key takeaways
- Foreign investors can now own 100% of most UAE mainland companies, including LLCs, without a UAE national holding 51% of the shares.
- This follows Federal Decree-Law No. 32 of 2021 on Commercial Companies, in force since 2 January 2022, which scrapped the old 51% local shareholding default.
- A short list of activities the UAE Cabinet treats as having "strategic impact," such as security, banking, insurance and oil and gas exploration, can still require UAE national ownership or extra approvals.
- Dubai's DET, Abu Dhabi's ADDED and the other emirates' economic departments decide activity by activity whether an LLC can be 100% foreign owned, so the same activity can be treated differently in different emirates.
- Professional licences run as civil companies usually still need a Local Service Agent, a UAE national paid a fee who holds no shares and has no say in the business.
- An existing 49/51 company doesn't convert automatically; the shareholders have to amend the Memorandum of Association and re-register with the licensing authority.
What law allows 100% foreign ownership of a UAE mainland company?
Federal Decree-Law No. 32 of 2021 on Commercial Companies removed the general requirement that UAE or GCC nationals hold at least 51% of a mainland limited liability company. The law was issued on 20 September 2021 and took effect on 2 January 2022, replacing the earlier Federal Law No. 2 of 2015 and building on interim amendments made by Federal Decree-Law No. 26 of 2020. Under the current law, 100% foreign ownership of a mainland LLC is the default position for most commercial and industrial activities, subject to the licensing authority's own rules and any activity the UAE Cabinet restricts.
Which activities are excluded from 100% foreign ownership?
Activities the UAE Cabinet designates as having "strategic impact" can still require UAE national participation, additional security clearance or a specific ownership structure. Based on the activities published by the Ministry of Economy and reported by UAE law firms, this group typically covers security and defence-related work, banking and other financial services, insurance, telecommunications, commercial agencies, and activities such as Hajj and Umrah services and fishing of pearls. Because the Cabinet can add or amend this list, a company whose activity sits close to one of these categories should check with the Ministry of Economy or its licensing authority before assuming full ownership is available.
| Sector treated as strategic | Typical extra requirement |
|---|---|
| Security, defence and military-related activities | UAE national ownership or specific government approval |
| Banking, insurance and financial services | Sector regulator approval, often alongside Central Bank licensing |
| Telecommunications | Federal licensing and Cabinet-level approval |
| Commercial agencies | Registration under the Commercial Agencies Law, UAE national agent |
| Hajj and Umrah services, printing and distribution of the Quran | Specific ministerial approval |
Accurate as of October 2026. Confirm the current list for your exact activity with the Ministry of Economy or your licensing authority before you apply.
Do I still need a local Emirati partner or service agent?
For most mainland LLC activities outside the strategic list, no: you don't need a UAE national shareholder or a service agent to hold shares on your behalf. The position is different for professional licences structured as civil companies, which commonly still require a Local Service Agent, a UAE national (or a company wholly owned by UAE nationals) who is paid a fixed or annual fee to liaise with government departments on the licence holder's behalf. An LSA has no equity, no profit share and no management role; the arrangement is contractual, not an ownership stake, and it sits outside the Commercial Companies Law because civil companies are licensed under separate rules.
How do I find out if my specific activity qualifies for full ownership?
You confirm this with the emirate's own licensing authority before you commit to an activity or a legal form, because approval is decided per activity and per emirate rather than published as one fixed national list.
- Identify the exact business activity code you want on the licence rather than the general sector name.
- Check that activity's ownership position with the relevant authority: the Department of Economy and Tourism (DET) in Dubai, the Abu Dhabi Department of Economic Development (ADDED), or the equivalent department in the other emirates.
- Ask whether any sector regulator needs to approve the activity separately, for example the Central Bank for finance-related activities.
- If the activity sits on or near the Cabinet's strategic list, request written confirmation of the ownership structure required before signing a lease or paying any fees.
- Confirm the legal form, LLC, civil company or branch, since the ownership rules and the need for a Local Service Agent depend on which one you choose.
Does switching to 100% ownership happen automatically for an existing company?
No. An LLC that was set up under the old 49/51 structure keeps that structure until the shareholders formally change it; ownership doesn't update on its own when the law changes. The shareholders need to amend the Memorandum of Association, agree the new share split in writing, and have the licensing authority re-register the company with the updated ownership before the UAE national's shares are legally removed. Until that amendment is filed, the UAE national shareholder remains a shareholder of record, whatever side arrangement exists privately.
100%: the share of a UAE mainland company a foreign investor can now hold outright for most commercial and industrial activities, with no UAE national shareholder required. Source: Federal Decree-Law No. 32 of 2021 on Commercial Companies, in force since 2 January 2022, checked October 2026.
What most guides don't tell you
- There's no single published "100% ownership list" you can download and rely on forever; eligibility sits with each emirate's licensing authority and can be applied inconsistently for the same activity code across emirates, so a verbal yes from one DET counter isn't a guarantee elsewhere.
- Moving from 49/51 to 100% foreign ownership is a formal amendment, and some banks re-run know your customer checks on the company once the shareholding changes, which can delay a signatory update even after the licence itself is amended.
- A Local Service Agent agreement for a civil company is a service contract, not a shareholding; if a company drafts it like a profit-sharing arrangement, it can blur into something that looks like disguised ownership and create disputes if the relationship ends.
- Full foreign ownership of the licence doesn't change separate approvals: a 100% foreign-owned company doing a strategic-impact activity, or needing a sector regulator's sign-off, still goes through that regulator regardless of the shareholding structure.
Which deadlines apply to your company?
Ownership rules are only one part of staying compliant once you're set up; licence renewal, visa renewals, corporate tax and VAT filings all run on their own separate deadlines. The free UAE compliance calendar lists these dates for your company once you answer a few questions about your setup.
Frequently asked questions
What is the cheapest free zone to set up a company in the UAE in 2026? Free zone fees change by activity and by how many visas you need, so there's no single "cheapest" answer that holds across every business. Compare the fee schedule each free zone publishes for your specific activity and visa count, since a low headline price often excludes required add-ons.
How much does it cost to open a company in Dubai, all in, including visas? The all-in cost of a mainland company depends on the activity, whether you need a physical office, and the number of visas, so there's no fixed UAE-wide figure to quote. Ask your licensing authority or service provider for an itemised quote that separates the licence fee, immigration file, establishment card and per-visa cost.
Which business activities still need a local Emirati partner or agent? Activities the UAE Cabinet treats as having strategic impact, such as security, banking, insurance and certain oil and gas activities, can still require UAE national ownership or extra approval. Professional licences run as civil companies also typically still need a Local Service Agent, a UAE national paid a fee who holds no shares in the business.
What is the difference between an LLC, a sole establishment and a branch in the UAE? An LLC is a separate legal entity with limited liability that can have one or more shareholders, and it's the structure that can now be up to 100% foreign owned for most activities. A sole establishment has one owner who is personally liable for its debts, while a branch has no separate legal personality of its own and operates as an extension of its parent company.
About Qawi · Qawi is a corporate services firm licensed in the Sharjah Media City (SHAMS) free zone, handling company formation, visas and PRO, bookkeeping, VAT and corporate tax for UAE businesses. Guides are researched from FTA, Ministry of Finance and free zone sources. Qawi on LinkedIn
Sources
- U.AE: Full foreign ownership of commercial companies
- Federal Decree-Law No. 32 of 2021 on Commercial Companies
- Federal Decree-Law No. 26 of 2020, amending Federal Law No. 2 of 2015 on Commercial Companies
- Ministry of Economy, United Arab Emirates
Last checked: 01 October 2026. This is general information, not tax or legal advice for your specific situation.