Executive Council Resolution No. 11 of 2025 sets out when a free zone establishment may conduct activities OUTSIDE its zone, within the Emirate. There are exactly three instruments: a licence for a branch within the Emirate, a licence for a branch operating out of the free zone, and a temporary permit valid for up to six months. A branch has NO separate legal personality, and separate financial records are mandatory for activities outside the zone. The fees are named in the resolution itself — but only for two instruments out of three, and we say so plainly.
Verified against official sources on 2026-09-15: the text of Executive Council Resolution No. 11 of 2025 comes from the Dubai Legislation Portal (dlp.dubai.gov.ae), credited to the Supreme Legislation Committee of the Emirate, 2025. The portal notes that the English version is a translation and that the Arabic text prevails in case of conflict. This is not legal advice: a specific activity is judged on its own documents.
A Dubai property investor often holds or services assets through a free zone company. And the question that follows is almost always the same: where does the zone end. That answer now has an instrument of its own.
The document is Executive Council Resolution No. (11) of 2025 Regulating the Conduct of Free Zone Establishments' Activities within the Emirate of Dubai, issued by the Crown Prince of Dubai as Chairman of the Executive Council on 3 March 2025; it is published in the Official Gazette and comes into force on the day of publication (Article 15).
Scope — and an important carve-out
Article 2 defines the addressees: the provisions apply to establishments wishing to conduct their activities outside of free zones. And it immediately carves out:
"This Resolution does not apply to financial Establishments licensed to operate in the Dubai International Financial Centre." — Executive Council Resolution No. (11) of 2025, Article 2
This is the third way of handling the DIFC we have met in primary sources. The urban planning law and the waste bylaw include free zones and the DIFC by name; the special tribunal for unfinished projects excludes property within DIFC boundaries; here the carve-out covers not every resident of the centre but specifically financial establishments licensed in it. Boundaries run differently in different instruments and must be read afresh each time — who resolves a collision between them is covered under Decree 29/2024.
Two obligations that always apply
Article 3 allows activity outside the zone only with one of the instruments in Article 4, and adds two requirements for whoever holds one:
- comply with the federal and local legislation applicable to the activity itself;
- maintain separate financial records for activities conducted outside the zone, distinct from those kept for activities inside it.
And where the company intends to operate outside the Emirate, it must obtain the licences and permits of the competent entities in that jurisdiction (paragraph (c)).
Three instruments, with different terms
| Instrument | What it is | Term |
|---|---|---|
| licence for a branch within the Emirate (Art. 4(a)(1), Art. 5) | the branch is located inside the Emirate | one year, renewable for the same period |
| licence for a branch operating out of the free zone (Art. 4(a)(2), Art. 6) | the branch is established in the free zone in order to conduct activities within the Emirate | one year, renewable for the same period |
| temporary permit for specific activities (Art. 4(a)(3), Art. 7) | for part of the activities within the Emirate | no more than six months |
All three are issued by the Department of Economy and Tourism.
Conditions for a branch within the Emirate (Article 5): an application on the Department's forms; prior approval of the free zone's Licensing Authority; approvals of the government entities supervising the activity itself, where required; a valid establishment licence issued by the Licensing Authority; the branch located within the Emirate; payment of the prescribed fees; any other conditions set by a resolution of the Department's Director General.
Conditions for a branch operating out of the free zone (Article 6) are the same in substance, with a list of documents added: a copy of the establishment's memorandum of association, a copy of the trade licence issued by the Licensing Authority, and copies of the manager's passport and Emirates Identity Card.
And in both cases the same caveat, worth reading twice:
"An Establishment's branch licensed in accordance with paragraph (a) of this Article will have no separate legal personality nor be deemed independent of its parent Company." — Executive Council Resolution No. (11) of 2025, Articles 5(b) and 6(b)
A temporary permit (Article 7) is issued for no more than six months and requires, among other things, that the activity itself appears on the Article 9 list.
The workforce stays "zone" workforce
Article 8 settles the question usually asked first: an establishment licensed or authorised under this resolution may engage its existing workforce registered on the free zone portal and continue to benefit from all free zone employment privileges applicable to that workforce.
The list of activities is the key to the whole structure
Article 9 directs the Department of Economy and Tourism, in coordination with the relevant Licensing Authority, to issue within no more than six months of the effective date a list of economic activities an establishment may conduct within the Emirate, specifying which instrument each requires: a licence for a branch within the Emirate, a licence for a branch operating out of the free zone, or a permit.
Until a reader has that list, mapping their own activity onto an instrument is not possible — and we do not do it.
Oversight: the Emirate's legislation applies in full
Article 10 is blunt: establishments licensed or authorised under this resolution to conduct activities within the Emirate are subject to the legislation in force in the Emirate, including the administrative penalties and measures stipulated therein. Article 11 adds audit and inspection — under the applicable federal and local legislation and the procedures agreed between the Department and the Licensing Authority.
Fees: two of the three are named
Article 12 names the fees the Department collects, and does so directly:
| For what | How much | Article |
|---|---|---|
| issuing or renewing a licence for a branch operating out of the free zone | AED 10,000 per year | 12(1) |
| issuing or renewing a temporary permit for specific activities | AED 5,000 | 12(2) |
Note what this article does not contain: a fee for the licence for a branch within the Emirate. Article 5 requires fees to be paid "in accordance with applicable legislation", and Article 12 lists only two instruments out of three. Carrying a figure from one line to another is not allowed, and we do not carry it.
A year to come into line
Article 13 speaks to those already operating outside the zone on the effective date: they must comply within one year of that date, and the Director General may, where necessary, extend that grace period once for the same length.
Article 14 repeals any provision of other resolutions to the extent it contradicts this one.
What we do NOT claim here
- Which instrument a particular real-estate activity needs. That is the business of the Article 9 list, which we have not read and about whose current edition we claim nothing. Separately, brokerage has requirements of its own — the brokers register and a licence — and that is a different layer of rules.
- The fee for a licence for a branch within the Emirate. Article 12 does not name it; Article 5 defers to applicable legislation, which we have not read.
- The calendar date of entry into force. The resolution comes into force on the day of publication in the Official Gazette; we have not verified that date. The date of issuance is 3 March 2025.
- The Department's forms, processes and Director General's resolutions. The text defers to them repeatedly; we have not seen them.
- The contents of the instruments in the preamble — the federal commercial companies law No. 32 of 2021 and commercial register law No. 37 of 2021, Cabinet Resolution No. 55 of 2021 on activities with strategic impact, Law No. 13 of 2011 on economic activities and Law No. 5 of 2021 on the DIFC.
- Tax consequences. There are none in this resolution; Corporate Tax and its boundary for natural persons are covered separately from the tax authority's guide.
Sources
- Executive Council Resolution No. (11) of 2025 Regulating the Conduct of Free Zone Establishments' Activities within the Emirate of Dubai — Dubai Legislation Portal: issuance by the Chairman of the Executive Council on 3 March 2025 and entry into force on the day of publication in the Official Gazette (Article 15); definitions of the free zone, the establishment and the Licensing Authority (Article 1); scope and non-application to financial establishments licensed in the DIFC (Article 2); activity outside the zone permitted only with an instrument, the duty to comply with applicable legislation and to keep separate financial records, and the requirement to obtain licences in another jurisdiction when operating outside the Emirate (Article 3); three instruments and the one-year validity of the two licences (Article 4); seven conditions for a licence for a branch within the Emirate and the absence of separate legal personality (Article 5); conditions and the document list for a licence for a branch operating out of the free zone, including the memorandum of association, the trade licence and the manager's passport and Emirates Identity Card (Article 6); a temporary permit of no more than six months and the requirement that the activity be on the Article 9 list (Article 7); the right to engage workforce registered on the free zone portal with its employment privileges preserved (Article 8); the mandate to issue a list of activities within no more than six months specifying the required instrument (Article 9); application of the Emirate's legislation including administrative penalties and measures (Article 10); audit and inspection under agreed procedures (Article 11); fees of AED 10,000 per year for a licence for a branch operating out of the free zone and AED 5,000 for a temporary permit (Article 12); one year to comply with a single extension (Article 13); repeal of conflicting provisions of other resolutions (Article 14).
