A client with entities in two free zones came to us in July. The DIFC company had filed cleanly. The DMCC one was three weeks late and the portal had already flagged it. Same year end, same books, same auditor. Nobody had checked that the two zones run on different clocks.
TL;DR: DMCC requires audited accounts within six months of your financial year end. ADGM gives private companies nine months. DIFC ties filing to when you circulate accounts to shareholders, with a seven-month outer limit. JAFZA and IFZA link it to licence renewal instead. Your corporate tax return is a separate deadline.
What are the audited accounts deadlines in DIFC, ADGM and DMCC?
DMCC gives you six months after year end. ADGM gives private companies nine months after their accounting reference date. DIFC works differently again: you file within 30 days of circulating accounts to shareholders, and circulation itself must happen within six months.
| Free zone | Filing deadline | Basis |
|---|---|---|
| DMCC | 6 months after year end | Company Regulations, Art 73.6; DMCC submission guide |
| ADGM (private) | 9 months after accounting reference date | Companies Regulations |
| ADGM (public) | 6 months after accounting reference date | Companies Regulations |
| DIFC | 30 days after circulation, 7 months at the outside | Companies Law No. 5 of 2018, Art 124 |
| JAFZA | Condition of licence renewal | Jafza Rules 2023, Rule 7.3(b) |
| IFZA | At licence renewal | IFZA renewal requirements |
A 31 December year end puts a DMCC filing at 30 June and an ADGM private company at 30 September. Hold both and you are running two audit timetables, not one.
DMCC: six months, and where the 90-day figure comes from
DMCC companies must have accounts prepared, approved by the directors, audited by a DMCC-approved auditor and laid before a general meeting within six months of year end (DMCC Company Regulations, Art 73.6, 2024). For a 31 December 2025 year end, that is 30 June 2026.
You will still find guidance saying 90 days. That figure comes from a 2019 DMCC guideline the current Regulations superseded, which DMCC unhelpfully still hosts. Its April 2025 submission guide confirms six months.
Two specifics catch people out. The auditor must be approved by DMCC, and accounts must be prepared under IFRS. What we see most often is a group appointing one auditor across all its UAE entities without checking that firm's DMCC status.
Dormancy is the one genuine let-off. A company dormant for the whole financial year is exempt from preparing, filing and auditing accounts (Articles 73.4, 73.7 and 78.11), unless a 10% shareholder objects within a month of year end.
On extensions: DMCC has granted concessions in some past years, but none is announced for the 2025 financial year. Work to 30 June.
How does ADGM's nine-month window work?
ADGM mirrors the UK structure most founders already recognise. Private companies and LLPs file annual accounts within nine months of their accounting reference date where the financial year runs 12 months or less. Public companies get six (ADGM, 2026).
ADGM also runs the most generous small company regime of the three. A firm with turnover of no more than USD 13.5 million and no more than 35 employees can file an unaudited balance sheet rather than full audited accounts (ADGM, 2026). Public interest entities and financial services firms are excluded regardless of size.
Late filing draws an administrative fine, typically USD 150 or USD 300 depending on the filing type (ADGM, 2026). Extensions of up to three months are available, but you must apply before the due date (ADGM extension guidance, 2024).
DIFC starts its clock at circulation, not year end
This one trips up finance teams moving from another zone. Under Article 124(4) of the DIFC Companies Law, accounts must be prepared, approved, audited and sent to every shareholder within six months of year end. Article 124(5) then requires filing with the Registrar within 30 days of circulation (DIFC Companies Law No. 5 of 2018, consolidated version).
So the seven-month backstop only applies if you circulate at the last moment. Circulate in month three and your filing deadline is month four, which is worth flagging to your board.
The DIFC Confirmation Statement is a separate obligation on an unrelated clock. It goes in with your annual licence renewal, not with your accounts.
Does your company qualify for a small company exemption?
Each zone sets its own test and they share no common threshold. DIFC's is the most valuable, because it removes the audit, the circulation and the Registrar filing entirely.
A DIFC private company qualifies if consolidated turnover is no more than USD 5 million and it has no more than 20 shareholders, in the current year and, where it has been going that long, the year before (DIFC Companies Law, Art 124(6), consolidated version). Two catches: your articles can switch the exemption off, and any shareholder holding 10% or more can force an audit by notice a month before year end.
IFZA runs a two-part test too, allowing simplified statements only where turnover is AED 3 million or less and the company had nine employees or fewer at any point in the year. Those still need a registered UAE auditor. DMCC has no size-based exemption: only dormancy helps there.
Does corporate tax override your free zone's deadline?
No. It adds a second one, and the two are unrelated. Ministerial Decision No. 84 of 2025, applying to tax periods beginning on or after 1 January 2025, requires audited financial statements from any taxpayer with revenue above AED 50 million and from every Qualifying Free Zone Person whatever its revenue. All tax groups must now prepare audited special purpose statements, where before only those above that same line had to (KPMG, 2025).
Your corporate tax return falls due nine months after your tax period ends, so 30 September 2026 for a 31 December 2025 year end. We covered what to get ready before that date separately.
For most free zone companies the zone's deadline lands first. A DMCC entity claiming Qualifying Free Zone Person status needs its audit done by 30 June, three months before the FTA wants the same numbers. Distributors in designated zones have a further reporting step on top.
What happens if you file late?
The published penalties are modest. The real damage is to your licence.
DIFC sets a maximum administrative fine of USD 10,000 for breaching the accounts requirements, under Schedule 2. ADGM late fines run at USD 150 or USD 300. DMCC publishes no fines schedule: its Regulations let it set a penalty at its discretion and suspend the trade licence of a company that has not complied.
That suspension power is the point. In JAFZA and IFZA, audited accounts are a stated condition of licence renewal, so a missing audit blocks the renewal itself (Jafza Rules 2023, Rule 7.3(b), 2023). A blocked renewal then blocks establishment cards, visa processing and share transfers. One question clients always ask is whether they can renew first and file later. In renewal-linked zones, no.
Corporate tax carries its own late filing penalty of AED 500 per month for the first twelve months, then AED 1,000.
Planning around two clocks
Work backwards from the earlier of your two dates, not the one you remember. For most December year ends that means the free zone deadline, and booking the auditor in Q1 rather than Q2.
Then three checks: that your auditor is on your zone's approved list, that your articles have not quietly disapplied an exemption you were relying on, and what your licence renewal date is if you are in JAFZA or IFZA. That last one is the deadline nobody writes down, because it moves with your incorporation anniversary rather than your year end.
Frequently Asked Questions
Can I use the same auditor for my DMCC and DIFC companies?
Only if that firm holds both registrations. DMCC requires an auditor on its Approved Auditor List, DIFC requires registration with the DIFC Registrar of Auditors, and both publish those registers. Check your firm appears on the right one before signing the engagement, not after the audit is done. DMCC appointments also expire annually.
Does my free zone filing count as filing with the FTA?
No. Free zone accounts go to your zone's registrar or member portal; corporate tax returns and supporting financial statements go to the FTA through EmaraTax.
What if my company is dormant?
In DMCC, dormancy through the whole financial year exempts you from preparing, filing and auditing accounts unless a 10% shareholder objects. Elsewhere it is less generous: a dormant company generally still files, though it will usually clear the turnover test for whatever small company regime its zone offers.
Does changing my financial year end move the deadline?
Yes, and it moves the free zone and corporate tax deadlines by different amounts, because they run from different reference points. Check both before you file the change.
What if my DMCC deadline has already passed?
File as soon as the audit is complete rather than waiting for the next cycle. An outstanding filing at renewal time is a much bigger problem than a late one cleared beforehand.
If you hold entities across more than one free zone and want a single view of what's due when, get in touch. We work with DIFC, ADGM, DMCC and mainland structures, and we'll map your filing calendar against your corporate tax dates. Still deciding where to set up? Start with our comparison of mainland and free zone options.