Why This Was Impossible Until Recently
For years, every consultant in the UAE gave the same answer to a company that had outgrown its free zone: there is no way to “move” to the mainland. You could open a branch, or liquidate and incorporate fresh — losing your contracts, your bank account, your track record and your corporate history. For a trading business with live counterparties and receivables, that was often a deal-breaker.
“Free zone companies can’t migrate to the mainland.”
— The free zone’s first-line support, mid-case. The law said otherwise.
That changed with Federal Decree-Law No. (20) of 2025, which introduced Article (15) bis into the Commercial Companies Law: a free zone company may transfer its registration to the mainland authority — in Dubai, DET — while retaining its legal personality. The company that arrives is legally the same company: same obligations, same rights, same contracts, same history.
The law existed on paper. What did not exist was practice — no published procedure on either side. What follows is the procedure we built, documented from a completed file.
An Operating Business With No Home
Our client was a real estate brokerage licensed in a Dubai free zone, brokering property transactions outside the UAE for an international client base. A healthy business — profitable in its first audited period, debt-free, its assets essentially all in cash.
Two things forced the move. First, on renewal, the free zone informed the company that its licensed activity was no longer available on the zone’s activity list — an operating business suddenly had no home for its licence. Second, the company had UAE-based clients waiting: engagements it could not accept, because a free zone licence does not permit onshore activity.
The mainland was not an upgrade; it was the only path that kept the business alive and growing.
The Deadlock — and How We Broke it
The hardest part was not paperwork. It was a chicken-and-egg problem between two authorities, each waiting for the other to move first: the free zone would only issue its No-Objection Certificate upon a request sent directly by the mainland authority, and the mainland authority would only act once it had reviewed a complete application dossier.
NOC only on a request from the mainland authority
⟵ waits
Acts only on a complete dossier
The answer was to stop asking either side for the outcome and instead give the mainland authority everything it needed to act. We assembled a complete legal dossier for DET’s Legislation and Disputes Sector, with a cover letter that did one crucial extra thing: it documented, with the free zone’s own written confirmation attached, exactly where and how DET could send its NOC request. We closed the loop for them.
The dossier — now the de facto standard. Previews illustrative; sensitive data does not appear.
We prepared the feasibility study, guarantee and cover letter bilingually — the reviewing sector works in Arabic, and a bilingual submission reads as a serious file. Three days after the complete dossier went in, DET issued its initial approval: “no objection in principle to proceeding with the transfer of registration.” The deadlock was over — the free zone’s NOC followed shortly after.
The Full Sequence, Step by Step
Here is the complete sequence from our file, start to finish — the procedure that did not exist until this case produced it.
Zone formalities; the DET dossier assembled and submitted
DET initial approval — no objection in principle
The deadlock breaks
Zone NOC; Articles attested at the Notary Public
Mainland steps in 3 working days; licence + continuity certificate
Same legal person, onshore
Shareholder resolution calling for the redomiciliation, attestation, and the zone’s NOC fee — roughly AED 10,000–11,000 at this stage, depending on the zone.
Audited financials, feasibility study, corporate guarantee, constitutional documents, and the cover letter that connects the two authorities — submitted before anything else can move.
No objection in principle after legal review, conditional on one document: updated Articles of Association attested by the Notary Public, compliant with the amended Companies Law.
Issued once the mainland authority’s position is on the table.
Name reservation, initial approval certificate, the new MoA signed through DET’s eNotary, and a registered office with Ejari — completed within three working days in our case.
Dubai
The Business Continuity Certificate, issued with the mainland licence, formally certifies the registration was transferred with incorporation intact — what you show your bank, your counterparties and any authority to prove the company is the same legal person.
The zone issues its migration certificate and closes the file; visas and the establishment card move across; bank and FTA records update on the strength of the continuity certificate — accounts and tax registrations continue rather than restart. RERA registration activates the onshore activity.
About six weeks from first inquiry to mainland licence — the mainland leg itself under three weeks.
Nothing was liquidated.
Nothing was reopened.
The company just moved.
Same incorporation date, certified by DET
No novation — every agreement survived
Accounts and registrations continued on the continuity certificate
RERA-registered brokerage, mainland clients signed
One of the first transfers of its kind in the UAE — the sequence it produced is the one we now run for every re-domiciliation.
Five Lessons from the File
The dossier is the key that turns the lock. Nobody hands you a checklist. The authorities respond to a complete, well-argued file — and the feasibility study is where the case is actually won. Frame it around what the Emirate gains: tax contribution, employment, fees, and business waiting to be done onshore.
Close the loop between the authorities yourself. Each side genuinely needed something from the other, and neither had a process for asking. Our cover letter told DET exactly where to send its NOC request and attached the zone’s written confirmation that it would respond. Make the bureaucratic path physically easy to walk.
Continuity of legal personality is the entire point — document it. The corporate guarantee protecting third-party rights reassures the regulator; the continuity certificate reassures everyone else. Together they mean no novation of contracts, no new bank account, no broken history.
Watch the clocks. Free zone licences and establishment cards keep expiring while you negotiate, with monthly penalties for missed deadlines. Sequence visa cancellations so that no one is left without residency status mid-transfer.
And a first refusal is not the answer. The first response we received was that migration was impossible. The law said otherwise. Persistence, escalation, and a file the reviewing lawyers could approve turned “impossible” into a signed continuity certificate.
Making a Good Reform World-Class
We want to be clear: Article 15 bis is an excellent reform, and once our complete file was on the table, DET moved with impressive speed — initial approval in days, a licensed mainland company within three weeks. The mechanism works. What follows is offered in the spirit of making a good reform world-class, in line with the D33 agenda’s ambition to make Dubai the easiest place on earth to do business.
Because the mechanism is so new, every company attempting it today must discover the procedure the way we did — by building it. Four things would unlock redomiciliation at scale:
A published, unified procedure. One official checklist — documents, fees, timelines, and the sequence between the free zone and DET — would let businesses plan the transfer like any other licensing transaction, and spare the authorities hundreds of exploratory inquiries.
A standard NOC protocol between authorities. A standing inter-authority channel — even a designated email and a template request — would remove the deadlock entirely.
A digital journey. Invest in Dubai, eNotary and Ejari already handled most of our mainland steps brilliantly — a dedicated “transfer from free zone” journey would make Dubai the first jurisdiction anywhere with fully digital corporate redomiciliation.
Activity-continuity guidance. Where a zone activity maps to a regulated mainland activity — as ours did, into RERA’s perimeter — transitional sequencing would let companies arrive operational from day one.
Companies that outgrow their free zones today choose between staying constrained and leaving the UAE entirely. Article 15 bis gives them a third option — staying, and growing, in Dubai. We would be glad to share our complete case file with any authority working on these procedures.
This case study describes a completed client engagement, anonymised for confidentiality. Figures are from the audited financials and public-register documents. It is general information, not legal advice — regulations and authority practice evolve, and each case should be assessed individually.