A free zone company that wants the mainland has never been stuck. You could open a branch. You could take a mainland trade permit alongside your zone licence and sell to UAE customers without leaving.
What you could not do was move.
The entity itself stayed where it was registered. If you wanted the company — the same company, with its trade name, its registration number, its banking history and its signed contracts — to sit under a mainland authority instead of a zone authority, there was no route. You cancelled and re-incorporated, and everything that made the old entity worth keeping was left behind with it.
Federal Decree-Law No. 20 of 2025 opened that route. A UAE company can now transfer its registration from one competent authority to another — free zone to mainland, mainland to free zone, or between emirates — and remain the same legal person throughout.
The route is open. It is not yet paved everywhere. What follows is what the law grants, what the licensing authorities can process today, and where the distance between those two things will cost you weeks.
What changed on 15 October 2025
Federal Decree-Law No. 20 of 2025 amends the Commercial Companies Law, Federal Decree-Law No. 32 of 2021. It was issued on 1 October 2025, published in the Official Gazette on 14 October, and took effect the day after publication.
The Ministry of Economy and Tourism describes the decree as running to fifteen articles, alongside a new article that regulates and legitimises the transfer of a company’s registration in the commercial register. Galadari Law identifies that new provision as Article 15 bis.
What it creates is a statutory mechanism for a company to transfer its registration from one jurisdiction to another within the UAE — from one emirate’s authority to another, or between a free zone and the mainland — while remaining the same legal entity. The transfer requires partner approval, by absolute majority depending on the company’s structure, and preserves the entity’s legal identity, rights and obligations across the move.
Why this needed a law at all
The barrier was never a prohibition. It was an absence.
Galadari Law’s account of the position before the amendment is unusually direct. Moving a company from mainland UAE into a free zone required a no-objection certificate from the relevant mainland authority — and in practice, no known procedure or mechanism existed to obtain that consent. There was no form and no department. The inability to get an answer halted any attempt at re-domiciling.
Article 15 bis supplies what was missing: a statutory basis, and with it an obligation on the authorities to build the process.
The clarification that made it possible
Alongside the transfer mechanism sits an amendment to Article 9(3), and it is the more consequential of the two.
Any company incorporated within the territorial limits of the UAE — including companies incorporated in free zones and financial free zones such as the DIFC and ADGM — holds UAE nationality. The provision was drafted to remove residual ambiguity, putting to rest earlier speculation that free zone entities might be treated as foreign companies lacking UAE nationality.
Read it next to Article 15 bis and the logic assembles itself. A free zone company is a UAE juridical person that happens to be regulated by its zone. The mainland registrar and the zone registrar are both registrars of the same state. Once that is settled in statute, moving a file between them is an administrative act, not a legal event.
That is the whole reform. Everything else in this article follows from it.
The obligation nobody is reading carefully
The same amendment runs in the other direction, and it deserves more attention than it is getting.
A free zone company that operates on the mainland — through a branch, a representative office, or otherwise — falls under the Commercial Companies Law in respect of those onshore activities. Inside the zone, zone regulations govern. Outside the zone and within the mainland, federal company law applies to that activity.
Free zone companies quietly serving mainland clients now have a statement of their position in writing. For some, a transfer is the cleaner answer than a compliance patch.
What re-domiciliation is, and three things it is not
Re-domiciliation is a change of registrar, not a change of company.
Your entity keeps its legal personality. Under a transfer, the company retains its identity, rights and obligations across the move — the registration number that appears on your contracts, the corporate history a bank underwrites against, the regulatory registrations you have already earned. There is no winding-down period. No novation of agreements. No re-execution of anything that was already signed.
The company does not stop existing and get replaced. It changes the authority that holds its file.
Three other routes get confused with this one. Each is a different transaction with a different cost, and choosing the wrong one is the most expensive mistake in this whole area.
It is not a licence conversion
There is no mechanism by which a free zone licence becomes a mainland licence. The zone authority cancels your registration; the Department of Economy and Tourism issues a new one. What Article 15 bis does is allow the company to survive that handover intact.
The distinction sounds academic until you are at a bank counter. A converted licence with a new entity behind it means a new account, new signatories, new KYC. A transferred registration means the account you already have.
It is not dual licensing
A free zone company that wants to sell directly to UAE consumers can apply for a mainland trade permit alongside its free zone licence — a route we already run for clients at Ajman Free Zone. The company stays in the zone. It buys access to the mainland market on top.
That is an addition. Re-domiciliation is a departure. If you want mainland customers but value your zone’s cost base, visa allocation and audit regime, dual licensing is very likely the cheaper answer and you should stop reading here.
It is not the same as moving a foreign company into the UAE
An offshore holding company in the BVI or Cayman can continue into the UAE — DIFC, ADGM and RAK ICC are the principal inbound destinations, and several free zones publish dedicated inbound procedures. That is a cross-border continuation, governed by the rules of two jurisdictions at once, and it turns on whether your home registry permits outbound transfer at all.
What Federal Decree-Law No. 20 of 2025 introduced is the domestic mechanism: transfers between UAE authorities. Different process, different documents, different timeline. If your company is already registered somewhere in the Emirates, this article is the one that applies to you.
Why the domestic version needed its own law
Because a free zone company was never foreign to begin with.
The amendment confirms that any company incorporated within UAE territory — free zones and financial free zones included — holds UAE nationality. Before that clarification, a transfer between a zone and the mainland sat in an awkward space: not quite a domestic reorganisation, not quite a cross-border migration, and processed as neither.
Once both authorities are registrars of the same state, holding files on the same juridical person, the transfer becomes an administrative act rather than a legal event. That is the reform. Everything else in this article follows from it.
Why a free zone company moves to the mainland
Most transfers come down to one of four pressures. It is worth knowing which one is yours, because two of them have cheaper answers than a transfer.
Market access
Free zone entities are built for export, technology and service businesses, and they carry restrictions on direct onshore selling. Mainland entities carry none. They trade across the UAE domestic market without a distributor, an agent, or a permit sitting between them and the customer.
If your revenue is already coming from UAE clients rather than international ones, your licence and your business model have drifted apart. That drift is the single most common reason a transfer gets raised.
Government contracts
Mainland entities are eligible to bid for government work. Free zone entities are generally not, and no amount of structuring inside a zone changes it.
For contracting, logistics and corporate services firms, this is frequently the whole argument. The pipeline is public-sector and the licence locks you out of it. A mainland licence is the only structure that opens it.
Banking
Mainland registration materially improves account access. UAE-registered onshore entities open accounts more readily than offshore vehicles in the current KYC environment, and a transfer that preserves your registration number preserves the account history a bank is underwriting against.
The alternative — dissolve, re-incorporate, re-apply — puts you in front of a compliance officer as a company with no trading history. You had a decade of it yesterday.
Ownership is no longer the obstacle it was
The historical case against the mainland was the local partner requirement. That barrier is largely gone: mainland companies now offer 100% foreign ownership for most commercial activities, and the 2025 amendments broadened it further. Certain strategic and regulated activities still require additional approvals, and those are the exception rather than the rule.
For a founder who last examined the mainland option five years ago and dismissed it, the arithmetic has changed underneath them.
What the law permits, and what the authorities can process today
Federal Decree-Law No. 20 of 2025 is in force. Article 15 bis exists. The right to transfer your registration is real and you can rely on it. None of that means you can walk into a licensing authority tomorrow and be handed a process.
The decree does not implement itself
The amendment introduces several concepts that are subject to more detailed implementing regulations, which will elaborate on and operationalise the key provisions. Until those regulations are released, the existing regulations enacted under the Commercial Companies Law continue to apply, insofar as they do not conflict with the amendment.
Implementation is also staged. The effective date and transitional application vary by provision, with phased rollout anticipated across roughly twelve to twenty-four months from the amendment.
Article 15 bis granted a right. The machinery that delivers it is still being built, department by department.
The receiving authority may need approvals of its own
Mainland re-domiciliation is more nuanced than the free zone route. The expanded foreign-ownership provisions removed a key historical barrier, but the precise process may still require additional regulatory or cabinet-level approvals depending on the activity licence being sought.
Which is to say: your activity determines your friction. A general trading company and a regulated financial services company are asking the same registrar for the same thing, and only one of them will get a straightforward answer.
Both ends must agree
A transfer is not a unilateral act. The departing authority has to release the file and the receiving authority has to accept it. The first practical step in any re-domiciliation is confirming that both the origin and the destination jurisdiction permit the transfer in the direction you intend.
That confirmation is not a formality. Before the amendment, the whole mechanism stalled precisely because no authority had a procedure for saying yes.
What this means for your timeline
If your zone has published an outbound transfer procedure and your intended mainland activity is unregulated, you are executing a defined process.
If either of those is untrue, you are the first case that authority has handled, and your timeline is governed by how quickly a department that has never done this decides how to do it.
Establish which of those two you are before you commit to anything. It is the difference between a project and an open-ended wait.
The procedure doesn't exist yet
Article 15bis establishes the legal framework for transfers within the UAE, but Cabinet-level implementing regulations detailing specific procedures for each scenario have not yet been fully published.
So every “step-by-step” currently ranking for this query is a law firm’s reconstruction of what the process will probably look like, not a procedure any authority has issued. If we publish ten numbered steps, we are doing the same thing while wearing your brand.
Worse, the step lists don’t agree with each other, and the most detailed one describes something that isn’t a transfer at all. Global Law Experts’ free-zone-to-mainland path reads: obtain a no-objection certificate or exit clearance from the current free zone authority, then submit a new trade licence application to DET with the NOC, amended constitutional documents and UBO declaration.
That’s a new licence. The one thing the article’s title promises you avoid.
Two claims I got wrong
The banking claim in Section 3 is unsafe. I wrote that a transfer preserves the account history a bank underwrites against. My source for that was writing about a BVI company continuing into the UAE — cross-border inbound. The exact contamination I warned about in Section 4, and I walked straight into it a second time.
Meydan Free Zone, speaking as an authority about its own inbound process, says the opposite: banking treatment is determined by the bank, not the free zone; some banks allow the existing corporate account to continue after licence migration, others require fresh onboarding and KYC review.
The “keep everything” framing is too strong. Meydan states plainly that under current UAE regulations residence visas cannot be transferred and establishment cards cannot be transferred. New visas must be issued after re-domiciliation.
So the honest position is: the entity survives. Its legal personality, contracts and corporate history survive. Its visas do not. Its establishment card does not. Its bank account might not. Its licence is reissued by the new authority.
That is still a meaningful and newsworthy improvement over liquidating. It is not what our first three sections implied.
What a transfer involves, and why nobody can give you a timeline yet
There is no published procedure. That is the most useful sentence in this article.
Article 15 bis establishes the legal framework for transfers within the UAE. The Cabinet-level implementing regulations that would set out specific procedures for each scenario have not yet been fully published. Until they are, the existing regulations under the Commercial Companies Law continue to apply where they do not conflict with the amendment.
Every step-by-step guide you will find on this topic today is a reconstruction — a reasonable inference of what the process should look like, written by people who have not yet been through it, because it has not yet been built. Some of them are careful. None of them is an authority speaking.
What follows is what is actually established.
The departing authority must release you first
A transfer is not a unilateral act. Before a receiving authority can accept a company, the current authority must formally release it. Meydan Free Zone, describing its own inbound process, states there is no fixed timeline — the duration depends on how quickly the departing authority issues the exit certificate once exit procedures are complete.
This is the step that governs your calendar, and it sits with the authority you are leaving. Their incentive to move quickly is not obvious.
Your licence is reissued, not carried across
The company survives. The licence does not travel with it. The receiving authority issues a new licence under its own regime, against the clearance from the departing one.
This is the distinction that gets lost. Re-domiciliation preserves the legal person. It does not preserve the paperwork that person was holding.
Visas and establishment cards do not transfer
Under current UAE regulations, residence visas cannot be transferred and establishment cards cannot be transferred. New visas must be issued under the receiving authority after re-domiciliation.
Every employee is re-issued. Medical tests, Emirates ID, the full sequence. If you have thirty staff, that is thirty processes, and they happen after the licence is live, not alongside it.
Your bank account is the bank’s decision, not the registrar’s
Banking treatment is determined by the bank, not the licensing authority. Some banks allow an existing corporate account to continue after a licence migration. Others require fresh onboarding and a full KYC review.
Nobody can promise you continuity here, and anyone who does is describing their hopes.
Compliance obligations do not migrate automatically
Your corporate tax position, your VAT registration, your federal register entry — each is a separate notification to a separate body. None of it follows the licence across on its own.
So what actually survives?
The company. Its legal personality, its corporate history, its registration continuity, its signed contracts. That is the entire prize, and it is a real one — it is the difference between a counterparty seeing the same entity they contracted with, and seeing a new company with no trading record.
What does not survive is most of the administration. You are keeping the person and reissuing everything the person was carrying.
If that trade is worth it, a transfer is right. If your value sits in the paperwork rather than the entity — no long contracts, no financing tied to the company, no counterparties who care — then closing and reopening is faster and cheaper, and the honest answer is to do that instead.
What you will need to produce
No authority has published a document checklist for an intra-UAE transfer, because no authority has published the procedure. What follows is assembled from the decree itself and from what the departing and receiving authorities each need in principle. Treat it as preparation, not as a form to complete.
From the company
A shareholder or partner resolution approving the transfer. The decree requires approval by absolute majority of partners, depending on the company’s legal structure — check your own constitution before you count votes, because the threshold is not uniform.
Amended constitutional documents. Your memorandum and articles were drafted under one authority’s regime and must be restated under the other’s.
Read your pre-emption clauses first. Most memoranda carry provisions giving existing partners first refusal on outgoing shares. These rights have to be addressed and resolved before any transfer proceeds, regardless of whether the company sits in a free zone or on the mainland. If a transfer triggers them and you have not dealt with it, you have a shareholder problem before you have a licensing one.
Beneficial ownership declaration. Required by the receiving authority, and the UBO framework applies across both regimes.
From the departing authority
Exit clearance, or a no-objection certificate. This is issued only once outstanding fees, lease obligations and regulatory filings are settled. Meydan’s own guidance is clear that exit procedures — including visa and establishment card cancellation — come before the exit certificate, not after it.
Read that sequence carefully. You cancel your team’s visas to obtain the clearance that lets you apply for the licence under which you will reissue them.
From you, afterwards
Notification to the Ministry of Economy and Tourism to update the federal commercial register. Notification to the Federal Tax Authority. Notification to your bank. Notification to counterparties, whether or not your contracts require it.
None of these follow the licence across on their own.
The sequencing trap
The order above is not a preference. It is a constraint, and it is where the cost hides.
Your visas are cancelled to obtain clearance. Clearance is what the receiving authority needs to issue the licence. The licence is what you need to apply for new visas. Between the first step and the last, your staff hold no residence permits and your company holds no establishment card.
Nobody has published how long that window is. It depends on how quickly the departing authority moves, which is the one variable you do not control.
That gap is the reason this is a project rather than a form. It is also the reason most companies attempting it engage someone to run the two authorities in parallel rather than in sequence.
When a transfer is the wrong answer
A transfer preserves the entity and reissues everything else. That trade is worth making in a narrow set of circumstances, and most companies asking about it are not in that set.
You want mainland customers, and nothing more
Then buy access rather than relocating to it. A free zone company can hold a mainland trade permit alongside its zone licence and sell directly to UAE customers. You keep the zone’s cost base, its visa allocation, its audit regime. Nothing gets cancelled, nothing gets reissued, and the decision is reversible.
If market access is the entire problem, dual licensing solves it and a transfer does not solve it better.
Your company has nothing worth carrying
The prize in a transfer is continuity — contracts a counterparty signed with a named entity, financing tied to a registration number, a trading history a bank has already assessed.
If you have month-to-month client work, no external financing, and counterparties who will not notice a new company name on the invoice, you are paying for continuity you do not need. Close the zone entity, incorporate on the mainland, and be trading in weeks rather than negotiating with two authorities across an unpublished process.
This is the right call for a large share of small companies, and almost nobody in this market will tell you so.
Your activity is regulated
Mainland re-domiciliation may require additional regulatory or cabinet-level approvals depending on the activity licence sought. Financial services, healthcare, education — a regulated activity means a second approval chain layered on top of a process that does not yet exist.
You are not the second case. You are the first, twice.
You cannot absorb the gap
Visas are cancelled to obtain clearance. Clearance produces the licence. The licence produces new visas. The window between is unbounded and outside your control.
If your business cannot run with staff off-visa for an unknown period, the transfer is not available to you today regardless of what the law permits. It becomes available when the implementing regulations set a timeline. Not before.
Frequently Asked Questions
Yes. Federal Decree-Law No. 20 of 2025 introduced a statutory mechanism allowing a company to transfer its registration from one competent authority to another within the UAE, while remaining the same legal entity. You avoid liquidation. You do not avoid the administrative reissue that follows.
Yes. That is the point of the mechanism. The transfer preserves the entity’s legal identity, rights and obligations across the move. Your contracts, corporate history and registration continuity survive.
No. The licence is reissued by the receiving authority under its own regime, against clearance from the authority you are leaving. The company survives; its licence is replaced.
They are cancelled and reissued. Under current UAE regulations, residence visas cannot be transferred, and establishment cards cannot be transferred. New visas must be issued under the receiving authority once the new licence is live.
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