100% foreign ownership in the UAE what it actually means and what the exceptions are
This comes up constantly, and there is still a lot of confusion about it. The headline “100% foreign ownership is allowed” is broadly true, but the full position is more nuanced.
The basic rule: Following the 2020 amendments and Federal Decree-Law No. 32 of 2021 on Commercial Companies, foreign investors may own 100% of a mainland UAE company for most economic activities. The previous general requirement for a UAE national to hold 51% of a mainland LLC no longer applies across the board.
The exceptions: Certain activities with a strategic impact remain subject to additional ownership and licensing controls. These include specified security, defence, financial, telecommunications, religious-service and fisheries-related activities. Depending on the activity, the relevant regulator may determine the permitted foreign ownership percentage, UAE national participation, board composition and other conditions.
Free zones versus mainland: Free zones have generally allowed up to 100% foreign ownership, but free-zone companies have traditionally required additional licensing arrangements to conduct certain activities directly outside the free zone. Depending on the business, this could involve a mainland branch, distributor, dual licence or other regulatory approval.
What the 2025 Commercial Companies Law amendments added: Federal Decree-Law No. 20 of 2025 clarified that free-zone and financial-free-zone companies may establish branches or representative offices and conduct activities within the UAE, subject to the relevant free-zone rules and the necessary mainland licences and approvals. It also expressly confirmed that companies established in UAE free zones and financial free zones have UAE corporate nationality.
If you are setting up a business in the UAE and are unsure which structure suits you, the starting point should be your proposed business activity, where your customers are located and whether you require direct access to the mainland market.