Navigating Dubai Dual Licensing – Opportunities for Free Zone Companies
December 08 2025
Dubai's business landscape has undergone significant regulatory reforms to enhance operational flexibility and attract global investment. One of the most notable developments is the introduction of dual licensing for free zone companies, enabling them to operate in both their designated free zones and mainland Dubai without establishing separate legal entities. Dual licensing allows companies to expand their market reach while maintaining the benefits of their free zone registration.
Dual licensing allows companies established in Dubai's free zones to obtain additional licenses that permit them to conduct business activities in mainland Dubai. This system eliminates the need for free zone companies to set up entirely separate legal entities to engage with mainland clients or participate in government tenders. Instead, they can operate under a unified licensing structure that recognizes their free zone status while granting access to the broader Dubai market.
The legal framework for dual licensing is primarily governed by Executive Council Resolution No. (11) of 2025, which outlines a structured framework for free zone entities to extend their operations into mainland Dubai. The resolution provides several licensing options, including a mainland branch license, a dual license for a free zone branch, and temporary operating permits. Companies seeking dual licensing must comply with all relevant federal and local legislation applicable to their activities, maintain separate financial records for mainland operations, and secure any other necessary licenses or permits if they intend to operate outside Dubai in other Emirates.
As of October 2025, dual licensing is actively being implemented. The Dubai Department of Economy and Tourism, in collaboration with the Dubai Free Zone Council, has launched the Free Zone Mainland Operating Permit, which allows eligible free zone companies holding a Dubai Unified Licence to apply digitally via the Invest in Dubai platform. The permit is valid for six months and is renewable, offering a cost-effective entry point for businesses seeking to expand into the mainland market.
While dual licensing provides significant operational advantages, it also introduces specific legal obligations. The free zone entity remains the primary legal entity, and the mainland license appears as a branch of the free zone entity on the DED Trade License, although it is not a true UAE foreign branch and does not require Ministry of Economy registration. Companies must comply with regulations in both jurisdictions, which can be complex but are essential for maintaining the dual license status. Additionally, the dual license does not permit registration with the Ministry of Labor, so all staff must be employed under the free zone company and hold free zone resident visas.
The introduction of dual licensing offers strategic benefits for businesses, including the ability to serve mainland clients while retaining the operational advantages of a free zone structure, reducing administrative and legal costs, and simplifying operations by maintaining a single corporate identity and documentation trail. Dual licensing represents a significant advancement in Dubai's regulatory landscape, providing companies with broader market access while preserving free zone benefits.
Navigating the legal and regulatory requirements of dual licensing can be complex, including compliance with both free zone and mainland regulations, corporate structuring, and employment obligations. MIS Legal can assist businesses in understanding these requirements, preparing and submitting applications for dual licenses, ensuring compliance with all relevant laws, and providing ongoing legal support to optimize operations across Dubai’s free zones and mainland. With expertise in corporate licensing and UAE commercial law, MIS Legal offers tailored solutions to help companies leverage the full benefits of dual licensing while minimizing regulatory risks.
