Strengthening Compliance and Oversight
The UAE has introduced Cabinet Resolution No. 209 of 2025, marking a significant step in aligning with global tax transparency standards. The framework adopts the OECD Exchange of Information upon Request model and enhances regulatory oversight across entities operating in the UAE.
Effective from 30 January 2026, the resolution expands compliance requirements and introduces stricter expectations around documentation, governance, and regulatory readiness.
A Broader Scope of Applicability
The updated framework applies across a wide range of entities, including natural licensed persons, legal entities, legal arrangements, and permanent establishments. It also applies across mainland and Free Zone jurisdictions without exception.
This expansion ensures that tax transparency requirements are consistently applied across the UAE business environment.
Core Compliance Requirements
The framework is built around three key pillars that define how organizations must manage and maintain information.
| Pillar | What It Requires |
| Ownership and Identity Transparency | Maintain accurate UBO details, ownership structures, and identity records |
| Evidentiary Accounting Records | Retain invoices, contracts, correspondence, and financial records to support transactions |
| Net Asset and Financial Transparency | Maintain records of assets, liabilities, income, and financial position, including banking information |
These pillars shift compliance from documentation to demonstrable transparency and accessibility.
Record Retention and Accessibility
Organizations must retain records for a minimum of five years, or longer where required by other regulations. Documentation must be accessible within the UAE and provided promptly upon request.
This reinforces the importance of structured record management and real time availability of information.
Enforcement and Penalty Framework
The resolution introduces a structured enforcement approach with defined penalties for non compliance.
| Violation | Penalty |
| Failure to retain records or provide information | AED 20,000 |
| Providing inaccurate information | AED 60,000 |
| Concealing or manipulating records | AED 100,000 |
Authorities also have the power to suspend or cancel licenses in cases of serious non compliance.
Strategic Impact for Businesses
The framework represents a shift toward active transparency and governance. Organizations must ensure that ownership structures, financial records, and internal controls are accurate, complete, and readily accessible.
It is important to note that compliance with Corporate Tax does not automatically ensure compliance with this framework. Both operate independently and require separate governance structures.
How MCA Gulf Can Support
MCA Gulf supports organizations in assessing readiness for the new transparency framework, strengthening ownership documentation, and implementing robust record retention and governance processes. Our approach focuses on ensuring compliance while maintaining operational efficiency.
For guidance on UAE tax transparency and EOIR compliance readiness, reach out to mcatax@mcagulf.com.
