The Essentials 

The ADGM Registration Authority has issued new guidance making audits mandatory for all companies electing Qualifying Free Zone Person (QFZP) status under the UAE Corporate Tax regime. This update impacts businesses of all sizes, removing previous audit exemptions and linking compliance directly to ADGM annual accounts filing. Companies must now use ADGM-registered auditors, file audited accounts with the Registrar, and meet strict filing deadlines. Transitional measures are in place, but timely compliance is critical to preserve tax benefits. 

The Abu Dhabi Global Market (ADGM) Registration Authority has issued new guidance for businesses electing Qualifying Free Zone Person (QFZP) status under the UAE Corporate Tax regime. This update introduces significant changes to audit and filing obligations, and for many companies, it may differ from previous expectations. 

If your business is considering or already holding QFZP status, understanding the new ADGM annual accounts filing requirements is critical to staying compliant and preserving tax benefits. 

ADGM Annual Accounts Filing: What Has Changed for ADGM QFZPs? 

The new guidance makes one point clear: audits are now mandatory for all companies opting for QFZP status. Whether your business is large or small, active or dormant, the exemption from audits no longer applies once you elect to be treated as a QFZP. 

Here are the key updates on ADGM Annual Accounts Filing ADGM company should note: 

1. Audit Now Mandatory for All QFZPs 

Companies that previously enjoyed audit exemptions including small businesses, certain subsidiaries, or even dormant entities must now arrange for audited accounts if they seek QFZP status. 

2. Use ADGM-Registered Auditors 

Only auditors registered with ADGM are permitted to carry out these audits. This ensures consistency with local regulatory standards and enhances the credibility of financial reporting. 

3. All Audited Accounts Must Be Filed 

After completion, audited accounts must be filed with the ADGM Registrar. This filing requirement applies universally, regardless of why the company needed the audit. Simply put, no ADGM annual accounts filing will be accepted without an audit. 

4. Transitional Arrangements in Place 

The ADGM has introduced certain transitional measures to ease the shift. However, businesses remain ultimately responsible for compliance, and the deadlines are approaching quickly. 

Deadlines for ADGM Annual Accounts Filing 

While the audit requirement is new for QFZPs, the obligation to file annual accounts has long been part of ADGM’s compliance framework. Businesses must continue to meet these existing ADGM annual accounts filing deadlines:  

If the first financial year is 12 months or less, annual accounts must be filed within nine (9) months of the Accounting Reference Date (ARD). 

• If the first financial year is more than 12 months, annual accounts must be filed within nine (9) months of the first anniversary of incorporation. 

• Subsequent Annual Accounts (for existing private companies or LLPs): 

• From the second year onwards, accounts must be filed within nine (9) months of the ARD. 

These timelines were already in place but take on greater importance now that all QFZPs must arrange audits before filing. 

How MS Can Help in ADGM Annual Accounts Filing 

At MS, we understand that compliance in ADGM is about ensuring your business continues to benefit from its chosen structure without unnecessary risk. With our strong presence in both ADGM and DIFC, we bring: 

• Expert Guidance on QFZP Status – Helping you assess eligibility and maximize the available corporate tax advantages. 

• Audit & Filing Support – Coordinating with ADGM-registered auditors and ensuring your audited accounts are prepared, reviewed, and filed on time. 

• Compliance Calendar Management – Tracking key dates such as ARD, incorporation anniversaries, and filing deadlines so you never miss a requirement. 

• End-to-End Corporate Services – From incorporation to ongoing governance, we provide a single-source solution tailored to your business needs. 

With filing ADGM annual accounts filing deadlines approaching and audit requirements now universal for QFZPs, MS can help you stay compliant and safeguard your tax position.