ADX Growth Market: new listing requirements and continued listing obligations

The ADX Growth Market is designed for private, family-owned or early-growth companies (including startups) that wish to become listed without incurring the same level of regulatory burden as Main Market listings. The Growth Market offers a streamlined listing and disclosure programme tailored to companies that are in their early stages of growth. Companies can access capital in return for transparency and manageable good governance.The below criteria detail the general requirements that a company seeking to file for a new listing on ADX’s Growth Market must comply with. Once the company is listed, continuing obligations would apply as outlined further below.&nbsp;New Listing RequirementsIncorporation AgeLocal Private Joint Stock Company: The listing must take place at least two years after incorporation, with two audited financial statements, OR through subsidiaries with less than two years of operations and audited statements.Foreign Company: The company must show at least two years of audited financials; it must be duly incorporated and regulated in its home jurisdiction.Free Zone Company: The company must provide audited financial statements for the preceding two financial years (standalone or consolidated). It may rely on parent company financials if it has been recently established.Net Equity / Paid-up CapitalLocal Private Joint Stock Company: Net equity must be at least equal to the paid-up capital.Foreign Company: Net equity must be at least equal to, or more than the paid-up capital. Paid-up capital must be fully paid and be at least AED 40 million (or equivalent) in many cases.Free Zone Company: The requirements are the same as for local or foreign companies depending on whether the free zone company is treated as local or foreign; but in every case net equity must be at least equal to the paid-up capital.ProfitabilityLocal Private Joint Stock Company: There are no explicit profitability requirements. The ADX Growth Market caters to family or growth companies and profitability is not a mandatory condition.Foreign Company: The company must have realised profits during at least the last two fiscal years.Free Zone Company: A set profitability is not required if the company is treated as a local entity; it is required as above if treated as a foreign entity.Ownership / ShareholdersLocal Private Joint Stock Company: The company must have at least two shareholders and a maximum 200 shareholders, as per UAE Commercial Companies Law.Foreign Company: There is no specific shareholder limit; foreign issuers must disclose the shareholding and ownership structure.Free Zone Company: The company must comply with shareholder requirements under free zone regulations; ADX focuses on ownership transparency.Minimum Capital / Free Float CapitalLocal Private Joint Stock Company: A minimum of 5% of the company’s share capital must be made available for public trading (free float).Foreign Company: A minimum of 5% of free float is expected; this may be adjusted based on the company’s listing structure or market liquidity.Free Zone Company: A minimum of 5% of free float is required unless waived by ADX based on the investor base or free zone regulator’s recommendations.Transferability and Share RightsLocal Private Joint Stock Company: Shares must provide equal equity rights and obligations to all holders in the same class. There should be no restrictions on transferring ownership of shares.Foreign Company: The same obligation as above applies; a foreign issuer must ensure shares are freely transferrable on a regulated exchange.Free Zone Company: The same obligation applies; where multiple share classes exist under free zone law, ADX may require unification for listing purposes.Regulatory OversightLocal Private Joint Stock Company: The listing will be subject to Securities &amp; Commodities Authority (SCA) supervision. The company must appoint a listing advisor licensed by the SCA to coordinate the listing and due diligence.Foreign Company: The company must be subject to an equivalent securities regulator in its home jurisdiction and appoint a local representative for compliance and dividend distribution.Free Zone Company: The company must obtain a ‘No Objection Certificate’ (NOC) from the relevant free zone authority. It will be under ongoing supervision by both the ADX and free zone regulators.Auditor / Financial StandardsLocal Private Joint Stock Company: Audited financials must comply with International Financial Regulation Standards and be prepared by an SCA-registered auditor. Submissions through the ADX portal must be completed in both Arabic and English.Foreign Company: Financial statements must follow International Financial Regulation Standards (IFRS) or an equivalent standard accepted by the ADX/SCA.Free Zone Company: Financial statements must follow IFRS unless another accepted standard applies (e.g. DIFC/ADGM). Reconciliation to IFRS may be required.&nbsp;Continued Listing ObligationsDisclosure of Material / Price-Sensitive InformationCompanies must disclose information, reports and decisions by the company that may affect the price of its securities (such as mergers, issuance of new securities, board / general assembly items or suspension of production lines) immediately. Reference: ADX Rulebook, Article 9(1) and (3).Significant Shareholding DisclosureIf a shareholder reaches 5% ownership (directly or indirectly), or increases shareholding beyond that by additional thresholds, this must be disclosed. Reference: ADX Rulebook, Article 9(1).Financial Reporting – Quarterly / Interim ReportsCompanies must submit quarterly financial statements (comparative to the same period in the previous year), including interim reports, approved by management. Reference: ADX circular: audited financial statements within 45 days of quarter end. ADX Rulebook – Article 9 (7).Annual Financial StatementsCompanies must publish audited annual financials within 90 days of the end of their fiscal year. Reference: ADX Rulebook – Article 9 (6) and (8).Board / Management Meeting DisclosuresIf a board meeting or General Assembly has on its agenda items that could affect share price, the agenda and schedule must be disclosed at least two business days prior to the meeting. Decisions must be disclosed immediately after the meeting. Reference: ADX circulars Sep 2024. ADX Rulebook – Article 9 (2) and (3).Prohibition on Insider Trading Ahead of Financial DisclosuresInsiders (board members, executives and relevant employees with access to material information) must not trade in the period preceding the disclosure of financial statements (this is a mandatory blackout period). The duration of the blackout period is governed by the Securities &amp; Commodities Authority’s Market Conduct Regulations and issuer policy.Corporate Governance &amp; Board / Shareholder TransparencyCompanies must disclose their major shareholders, board members and relatives of board members and any changes thereto. They must also disclose relationships with subsidiaries or affiliates and ensure shareholder rights and fair treatment. Reference: Application rules &amp; continuing obligations (adx.ae). ADX Rulebook – Article 9 (9).Maintaining Capital / Net Equity ConditionA company’s net equity must remain at least equal to paid-up share capital. If net equity falls below paid-up capital, the company must disclose the position and take remedial action. Reference: ADX Rulebook – Article 5(1)(a) and (b).Insider / Insider List ChangesCompanies must maintain an updated list of insiders (persons with access to unpublished material information) and notify the ADX of any additions, amendments or deletions to their insiders list. Reference: Securities &amp; Conduct Authority, Market Conduct Regulations.Disclosure Language and FormatFinancial statements and reports must be submitted in Arabic and English via ADX’s e-services, following International Financial Reporting Standards (IFRS). Reference: Circulars require bilingual disclosure and International Financial Reporting Standards (adx.ae).Trading Halts / SuspensionsADX may suspend trading if financial statements or other disclosures are not submitted in time or if price movements occur without explanation. Trading is also suspended until the company rectifies such delay or clarifies the cause. Reference: ADX FAQ: trading suspension for noncompliance (adx.ae). ADX Rulebook – Article 10.&nbsp;

This article outlines the key requirements for listing on ADX’s Growth Market

ADX Main Market: new listing requirements and continued listing obligations

The Main Market of the Abu Dhabi Securities Exchange (ADX) is its primary equity market segment, designed for established companies that meet the highest listing and regulatory standards in the UAE. It sits alongside the Growth Market (for younger and smaller companies) but the company requirements differ in terms of maturity, financial history and governance levels.The below criteria detail the general requirements that a company seeking to file for a new listing on ADX’s Main Market must comply with. Once the company is listed, continuing obligations would apply as outlined further below.New Listing RequirementsIncorporation AgeLocal Private Joint Stock Company: The listing must take place at least two years since incorporation, with two audited financial statements; or if it is operating via subsidiaries, it must have been operating for at least two years with audited statements thereof.Foreign Company: The company must have at least two years of audited financials.Free Zone Company: The company must have at least two years of audited financials, and must also demonstrate that net equity exceeds paid-up capital.Net Equity / Paid-up CapitalLocal Private Joint Stock Company: Net equity must be at least equal to the paid-up capital (i.e. net equity is equal to or greater than 100% of paid up).Foreign Company: Net equity must be at least equal to the paid-up capital (i.e. net equity is at least equal to 100% of paid up). For foreign companies, paid-up capital must be fully paid and be at least AED 40 million (or equivalent).Free Zone Company: Same as foreign and local requirements, depending on whether the free zone company is generally treated as foreign unless incorporated under UAE commercial law.ProfitabilityLocal Private Joint Stock Companies, Foreign Companies and Free Zone Companies all have the same requirements: The company must have realised profits (which are earned and recognised in the company’s audited financial statements, excluding fair-value gains) during at least the last two fiscal years.Ownership / ShareholdersLocal Private Joint Stock Company: The company must have at least two shareholders; and a maximum 200 shareholders.Foreign Company: The required number of shareholders depends on home jurisdiction; disclosure of significant shareholders is mandatory.Free Zone Company: Regulation depends on the free zone. There is no cap of 200 shareholders but transparency of ownership required.Minimum Capital / Free FloatLocal Private Joint Stock Company: The company must list at least 5% of its share capital in a public free float (subject to ADX/SCA discretion).Foreign Company: The company must list at least 5% of its share capital in a public free float.Free Zone Company: The company must meet minimum free float requirements prescribed by ADX.Regulatory OversightLocal Private Joint Stock Company: The company listing is regulated by the Securities &amp; Commodities Authority (SCA) and the ADX.Foreign Company: The company must be regulated in its home country by an equivalent authority with similar investor protection standards.Free Zone Company: The company must have regulatory oversight from free zone (e.g. DIFC, ADGM). This is subject to ADX clearance.Listing AdvisorLocal Private Joint Stock Companies, Foreign Companies and Free Zone Companies all have the same requirements: The company must appoint a listing advisor licensed by the Authority.ProspectusLocal Private Joint Stock Companies, Foreign Companies and Free Zone Companies all have the same requirements: This is mandatory and must be approved by the SCA prior to publication.No Objection from Free Zone AuthorityLocal Private Joint Stock Company: Not applicable.Foreign Company: Not applicable.Free Zone Company: The company must obtain a “no objection” from the regulatory authority in the free zone.Appointment of RepresentativeLocal Private Joint Stock Company: Not applicable.Foreign Company: The company must appoint a representative in the State to register the shares, distribute dividends, receive and issue reports and documents relevant to the company’s operations.Free Zone Company: Not applicable.Currency of ListingLocal Private Joint Stock Company: AED.Foreign Company: AED or home currency with prior SCA approval.Free Zone Company: Typically AED for UAE-based issuers.Additional Notes / ExemptionsLocal Private Joint Stock Company: ADX may grant exemptions for government-related or strategic entities.Foreign Company: May be a dual or secondary listing with disclosure requirements.Free Zone Company: Treated as domestic if incorporated in ADGM or DIFC (recognised jurisdictions).Continued Listing ObligationsFinancial Reporting – Quarterly / Interim ReportsCompanies must provide comparative quarterly financial reports (compared to the same quarter in the prior year). This includes financial statements, board report or MD&amp;A; and they must be approved by executive management. They must also submit audited financial statements within 45 days of quarter end. Reference: ADX Rulebook – Article 9 (7).Annual Financial StatementsCompanies must submit audited annual financial statements including the Board and auditor’s reports within 90 days of fiscal year-end, and a preliminary unaudited summary within 45 days after year-end. Reference: ADX Rulebook – Article 9 (6) and (8).Board / Management Meeting DisclosuresWhen board meetings are going to discuss matters that could affect share price, the company must:<ol><li>Disclose an agenda and schedule of the meeting at least two business days before the meeting date.</li><li>Disclose decisions made in that meeting immediately after the meeting ends (excluding the day of meeting).</li></ol>Advance disclosure is required two business days prior; decisions immediately after. Reference: ADX Rulebook – Article 9(2-3).Prohibition on Insider Trading ahead of Financial DisclosuresChairpersons, board members and employees with access to insider information cannot trade in the company’s securities (and certain related companies) during a blackout period (governed by the Securities &amp; Commodities Authority) ahead of financial disclosures. Typically, this is between 15 days before disclosure of financial statements and when disclosure is made.Language RequirementsReports are to be made in Arabic and English, through the ADX’s electronic disclosure system and prepared in accordance with IFRS standards. Financial reports, e.g. quarterly reports, must be in both languages.Free Float / Public Shareholder Base MaintenanceThe company must retain a required free float and a number of shareholders appropriate to the category (first / second category etc.). Breach can lead to movement between categories. This applies for as long as the company is listed and assessed annually (often at the end of fiscal year) for category membership.Notification of Significant Events / Material DevelopmentsCompanies must inform ADX and public of any events that are likely to affect a company's share price or may be material, as well as changes in substantial shareholdings (e.g. crossing thresholds). Disclosure to ADX must be done as soon as changes are made aware to the company.Maintaining Capital / Net Equity ConditionA company’s net equity must remain at least equal to its paid-up share capital. If net equity falls below paid-up capital, the company must disclose the position and take remedial action. Reference: ADX Rulebook – Article 5(1).Insider List ChangesCompanies must maintain an updated list of insiders. Any addition, amendment, or deletion of an insider (e.g. board member, persons with access to insider info) must be disclosed immediately. Disclosure to ADX must be done as soon as changes are made aware to the company.Trading Halts / Suspension for Non-complianceIf required disclosures or filings are delayed (e.g. financial reports, board meeting notices), suspended trading applies when deadlines are missed; for example, if financial reports are not submitted by a specified time ADX may suspend trading of the company's shares. Reference: ADX Rulebook – Article 10.

The requirements that a company seeking to file for a new listing on ADX’s Main Market must comply with.

New tax model on sugar-sweetened beverages in the UAE

The UAE Ministry of Finance has announced a set of proposed legislative amendments to embed the updated excise tax policy into the national legislation. This step is in line with the Gulf Cooperation Council’s adoption of a tiered model for excise tax on sugar-sweetened beverages (“SSB’s”).What’s changing?The UAE will introduce a new sugary and sweetened drink tax, taking effect from 1st January 2026. The current flat 50% excise tax will be replaced with a tiered system and SSBs with higher sugar or sweetener content will be subject to higher tax. Drinks with no added sugar will be excluded entirely.Importers and drinks manufacturers will have the flexibility to adjust taxes on stock already paid under the old tax system, ensuring a smooth transition. Persons or businesses who have imported or produced goods subject to 50% tax prior to the amendments coming into effect, and whose tax liability would decrease as a result of these amendments (before selling the goods for which tax was previously paid), will be able to deduct part of the previously paid tax.All sugar-sweetened and beverages with additional sweeteners (artificial and otherwise) sold in the UAE will be subject to the new regime. The Ministry of Finance’s stated objective is to reduce sugar consumption, promote wellness and maintain fiscal sustainability.What are the categories?Here ‘sweetener’ refers to sugar or non-artificial added sweetener.<ul><li>More than 8g&nbsp;of sweetener per 100ml: drink will be ‘High Sugar’ and subject to the highest tax rate.</li><li>Between 5g and 8g&nbsp;of sweetener per 100ml: drink will be ‘Moderate Sugar’&nbsp;and subject to a middling tax rate.</li><li>Less than 5g of sweetener per 100ml: drink will be ‘Low Sugar’ and subject to the lowest tax rate.</li><li>If a drink only has artificial sweeteners (and no sugar or non-artificial sweeteners) it will be exempt under the new tax model.</li></ul>This article will be updated to confirm the tax rates at each level once these have been announced.&nbsp;

The UAE Ministry of Finance proposed amendments to embed the updated excise tax policy in law.

DWTCA’s Multiple Share Class Framework

The Dubai World Trade Centre Authority (DWTCA) has once again demonstrated its forward-thinking leadership by introducing a multiple share class framework for companies registered within the DWTC Free Zone. This reform, simple in concept but profound in impact, represents a major leap in how businesses in the UAE can structure ownership, attract investment, and manage control.A Bold Step Beyond Traditional LimitsUntil now, UAE law has only allowed companies to issue a single class of shares, meaning that every shareholder held identical rights - equal voting power, dividends, and control. This uniform structure has long limited flexibility, especially when compared to global markets like the US, UK, and Singapore, where companies routinely issue various classes of shares to tailor ownership structures to their strategic needs.In those markets, ordinary shares grant both voting rights and dividends, preference shares offer priority on profits without voting power, and founder shares can protect the influence of original entrepreneurs. This diversity of options enables startups, family offices, and large corporations alike to fine-tune their governance and capital-raising models.With DWTCA’s new framework, that flexibility has finally arrived in the UAE.Empowering Businesses and InvestorsThe reform allows companies within the DWTC Free Zone to issue a range of share types, including preference, founder’s, restricted, and tiered share classes (A, B, C, D). Each class can be customized in a company’s Memorandum of Association, specifying rights over dividends, voting power, transfer conditions, and safeguards for minority shareholders.This change isn’t just regulatory fine print, it’s a catalyst for growth. It gives founders the ability to retain strategic control while bringing in investors, enables companies to attract diverse capital from different risk profiles, and even allows for employee equity incentives that align long-term interests.As Abdalla Al Banna, VP of Free Zone Regulatory Operations at DWTC, aptly put it:“By aligning with Dubai’s vision to be among the world’s leading global business hubs, we are creating an environment that empowers companies to scale and attract investment. Today’s founders and investors need flexible and transparent corporate structures to balance control, raise capital and retain talent.”A Move Aligned with Dubai’s Economic VisionThis initiative is a strategic piece of Dubai’s larger economic puzzle - the Dubai Economic Agenda D33, which aims to double the emirate’s economy by 2033 and position it among the world’s top three urban economies.By introducing flexible share structuring, DWTCA is directly addressing one of the key factors that global investors and entrepreneurs look for: corporate agility. It brings Dubai in line with leading international business hubs, strengthening its reputation as a progressive, innovative, and investor-friendly environment.Why This Is a Brilliant and Game-Changing MoveFrom my perspective, this is nothing short of a brilliant move, a game changer for the UAE’s corporate and investment ecosystem.For years, the “one-share-one-right” model limited how companies could grow, negotiate with investors, and protect founder interests. Now, with this framework, we can finally see the emergence of more sophisticated ownership structures, venture-backed startups, and family businesses that can plan for generational transitions with greater clarity.The timing couldn’t be better. As Dubai expands its jurisdiction to landmark developments like One Za’abeel and continues to attract global enterprises across more than 40 sectors, the DWTCA’s reform will unlock new possibilities for innovation, funding, and long-term sustainability.Looking AheadWith full foreign ownership, a 0% corporate tax rate, and now the ability to issue multiple share classes, the DWTC Free Zone is positioning itself as a benchmark for modern corporate governance in the region.This isn’t just a policy change, it’s a paradigm shift that will reshape how businesses are built, scaled, and sustained in the UAE. It reflects a maturing economy that understands the need for flexibility, investor confidence, and structural sophistication.And for entrepreneurs, investors, and visionaries who have long believed in Dubai’s potential, this framework proves once again that the emirate is not just keeping pace with global innovation, but setting the standard for it.

DWTCA’s Multiple Share Class Framework: A Game-Changer for the UAE’s Business Landscape

Dubai’s Dynamic Economic Growth

Dubai continues to reinforce its position as one of the world’s most vibrant and future-focused economies. The emirate recorded strong and sustainable growth across all key sectors, with its GDP rising 4.4% in the first half of 2025, reaching AED 241 billion compared to the same period in 2024. This momentum accelerated further in the second quarter of 2025, with GDP increasing 4.7%, underscoring Dubai’s resilience, diversification, and economic dynamism.This performance reflects Dubai’s strategic vision under the leadership of His Highness Sheikh Mohammed bin Rashid Al Maktoum, who continues to guide the emirate toward sustained global competitiveness and innovation-led progress. As highlighted by Sheikh Hamdan bin Mohammed, Crown Prince of Dubai, the results demonstrate the strength of collaboration between public and private sectors as the emirate moves steadily toward the ambitious objectives of the Dubai Economic Agenda D33.Driving Future Growth with Vision and AmbitionThe D33 strategy aims to double the size of Dubai’s economy to AED 32 trillion over the next decade and to firmly establish the emirate among the world’s top three global cities. The plan includes supporting 30 companies to achieve “unicorn” status, promoting innovation, and strengthening foreign direct investment. Dubai aims to increase average annual FDI from AED 32 billion to AED 60 billion, targeting AED 650 billion in total investment over the next 10 years.Key Growth Sectors Fueling Dubai’s Economic ExpansionDubai’s economic growth is broad-based, with significant contributions from multiple sectors:<ul><li>Real Estate: One of the fastest-growing pillars, the sector expanded 7% in the first half of 2025, adding AED 19.8 billion in value and contributing 8.2% to GDP. Investor confidence remains strong, driven by residency reforms, high demand, and global interest.</li><li>Tourism and Hospitality: Dubai welcomed 12.54 million international overnight visitors in the first eight months of 2025, supported by the continued growth of Dubai International Airport, which is projected to handle more than 95 million passengers this year.</li><li>Financial Services: The financial and insurance sector grew 6.7%, contributing AED 30.2 billion to GDP as Dubai strengthens its role as a global finance and capital hub.</li><li>Construction, Healthcare, Logistics, and ICT: These sectors all recorded strong growth, reflecting diversified and forward-looking development across the economy.</li></ul>Dubai’s continued success is supported by long-term visa initiatives, business-friendly regulation, competitive taxation, and sustained public infrastructure investment. These factors reinforce Dubai’s role as a global destination for entrepreneurship, investment, and innovation.A Gateway of OpportunityDubai’s rapid growth provides businesses and investors with unparalleled opportunities across real estate, corporate expansion, commercial transactions, private capital markets, and international trade. With its global connectivity, regulatory stability, and pro-investment environment, Dubai stands as a launchpad for regional and global business success.&nbsp;How ALBM Excello Law Can Support YouAt ALBM Excello Law, we are proud to be part of Dubai’s story of growth and progress. Our firm is strategically positioned to support businesses, investors, and entrepreneurs in navigating the evolving regulatory and commercial landscape.We offer a full suite of legal services across key practice areas, including:<ul><li>Corporate &amp; Commercial Law</li><li>Real Estate &amp; Property Transactions</li><li>Company Formation &amp; Structuring</li><li>M&amp;A and Joint Ventures</li><li>Regulatory &amp; Compliance Advisory</li></ul>Our experienced team provides practical, tailored advice to help clients achieve their commercial goals in one of the world’s most dynamic markets.ALBM Excello Law – Your legal partners in Dubai’s growing economy.

Dubai continues to reinforce its position as one of the world’s most vibrant and future-focused economies.

The launch of Dubai Hub London, Dubai Chambers’ first international centre offering integrated government and private sector services for UK businesses expanding into Dubai.&nbsp;

Dubai Hub London

On 17th July 2025, Dubai Chambers officially launched Dubai Hub London, its first international centre designed to provide a one-stop platform for UK-based investors and companies seeking to expand into Dubai. This landmark initiative integrates government and private sector services—including trade licensing, legal attestation, real estate registration, immigration support, and more—under a single roof, significantly streamlining market entry and reinforcing bilateral economic ties.The hub aligns with Dubai’s Economic Agenda (D33) and the leadership’s vision to position the emirate among the top global business hubs. By centralising property, licensing, legal, and administrative processes, Dubai Hub London simplifies procedures for international investors while enhancing Dubai’s reputation as a business-friendly destination.Supervised by Dubai Chambers and operated by Al Burj Holding, the hub provides licensed services from key Dubai entities, including the Dubai Land Department, Department of Economy and Tourism, Dubai Courts, and the General Directorate of Identity and Foreigners Affairs. Services range from property valuation and trade licensing to contract attestation, document translation, and signature verification. London was strategically chosen for this first hub due to its global financial prominence and access to a broad investor base.This is precisely where ALBM Excello Law comes into play. With offices in both the UK and Dubai, we provide seamless legal and regulatory support for businesses navigating cross-border expansion.Whether you are a UK company looking to establish operations in Dubai or a UAE investor exploring opportunities in the UK, ALBM Excello Law’s dual-jurisdiction presence ensures that every stage of your business journey—from strategy to execution—is fully supported. Clients benefit from tailored legal advice, efficient compliance solutions, and access to integrated services like those offered by Dubai Hub London.The launch of Dubai Hub London represents a transformative step for international trade and investment between the UK and Dubai. With ALBM Excello Law by your side, businesses can confidently navigate this streamlined ecosystem, taking advantage of Dubai’s strategic location, regulatory flexibility, and thriving economic landscape.

Dubai Hub London: Dubai Chambers’ first international centre offering integrated government and private sector services for UK businesses expanding into Dubai.

UAE to Introduce Sugar-Linked Excise Tax on Sweetened Beverages by 2026

There’s a significant development coming out of the UAE that I believe our FMCG clients, particularly those in beverages and consumer goods, should pay close attention to.The UAE Ministry of Finance and the Federal Tax Authority have announced a major change in how sugar-sweetened beverages (SSBs) will be taxed. Starting in 2026, the excise tax on these products will no longer follow a flat, percentage-based model. Instead, it will shift to a tiered volumetric structure, linking the tax directly to the amount of sugar per 100ml in the product.In short: the more sugar per 100ml, the higher the tax per litre. This is a clear policy move aimed at encouraging manufacturers to reduce sugar content and promoting healthier dietary choices among consumers, aligning with global public health trends.From my perspective, this is more than just a tax update - it’s a signal that nutritional reformulation and product transparency are about to become strategic priorities for brands operating in the UAE. FMCG businesses should start thinking now about how their current SKUs stack up against this upcoming model.The early announcement gives manufacturers, importers, and distributors time to:<ul><li>Review and potentially reformulate products.</li><li>Update internal tax systems and labelling.</li><li>Strategically plan for pricing and inventory around the implementation timeline.</li></ul>The government has stated that awareness campaigns will be launched, and businesses will be given sufficient time to adapt, but make no mistake, this is a big shift for any company dealing in sugary drinks.We’ll be following this development closely, and we’ll provide detailed updates and guidance for our clients as more information becomes available.If you’re in the UAE’s FMCG space, now is the time to get ahead of this change.

Discover how the UAE’s upcoming sugar-linked excise tax on sweetened beverages by 2026 will impact businesses and consumers. ALBM Excello explains the legal, regulatory, and economic implications of this new taxation policy.

There’s a significant development coming out of the UAE that I believe our FMCG clients, particularly those in beverages and consumer goods, should pay close attention to.

Dubai Court Ruling on Late Payment Charges: Key Implications | ALBM Excello Blog

This week’s news out of Dubai could mark a great development for Islamic finance and for the UAE as a whole. The Court of Cassation has issued a binding ruling prohibiting Islamic banks and Takaful companies from charging late payment interest or penalties, even when delays are intentional. For someone like me who’s long believed in the need for clarity and consistency in Sharia-compliant finance, this is a big moment.Of course, we’ll need to read the full ruling carefully. But at first glance, this appears to be a decisive step toward resolving one of the most contentious and misunderstood areas in Islamic finance. Watch this space.According to reports from&nbsp;<a href="https://www.emaratalyoum.com/">Emarat Al Youm</a>, the court ruled that Islamic financial institutions, whether operating fully or partially under Sharia, cannot impose charges on delayed payments. It doesn’t matter what the charge is called: interest, compensation, late fees, or anything else. If the underlying transaction is Sharia-compliant, then punitive charges for delay are not allowed. The court went further to state that this is a matter of&nbsp;public order, meaning it must be applied automatically by judges, even if previous rulings have said otherwise.The decision comes after a formal request by the head of the Court of Cassation to resolve conflicting decisions from previous cases. Now, the matter has been referred to the General Assembly of the Court of Cassation for a unified interpretation under Article 20 of Law No. 13 of 2016 - the law that governs Dubai’s judiciary.This kind of legal clarity is exactly what the Islamic finance industry needs. When financial institutions and regulators operate in a grey zone, uncertainty reigns&nbsp; and that doesn’t serve anyone well, whether you’re a bank, a customer, or an investor. I’ve always believed that Sharia-compliant finance can be both principled and practical, but that depends on clear, consistent application of the rules. This ruling is a step in that direction.There will no doubt be implications for contracts, risk assessments, and even customer behaviour, but those are details we will explore once the full judgment is released. For now, I see this as an encouraging signal: the UAE is serious about reinforcing the foundational values of Islamic finance, and willing to make tough legal calls to do so.

Understand why Dubai’s latest ruling on late payment charges is a game-changer for businesses and creditors. ALBM Excello explains the legal clarity this decision provides and its impact on commercial contracts and financial practices.

This week’s news out of Dubai could mark a great development for Islamic finance and for the UAE as a whole.

A Step Toward Clarity: Why the Dubai Ruling on Late Payment Charges Matters

Free Trade Talks GCC–Malaysia–UK: Economic Ties on the Rise | ALBM Excello Blog

I’m excited to see these new trade agreements taking shape as it will be a real game changer for regional and global partnerships.The GCC and Malaysia have officially launched negotiations for a Free Trade Agreement (FTA), which is fantastic news for expanding economic ties between the Gulf states and Southeast Asia. What’s even more interesting is that a GCC–UK FTA is also being explored - both stories appeared in the same news report!This is an incredible opportunity. If these agreements come to fruition, we could play a pivotal role as a bridge connecting these dynamic markets. Helping businesses navigate and benefit from these new trade routes is something I’m truly eager to support.Thank you to the UAE, the GCC countries, Malaysia, and the UK for driving these forward. It’s great to see such collaborative momentum.To give some context: The GCC, which includes Saudi Arabia, the UAE, Qatar, Kuwait, Bahrain, and Oman, and Malaysia have kicked off official negotiations after signing a joint statement between GCC Secretary-General Jasem Mohamed Albudaiwi and Malaysia’s Minister of Investment, Trade, and Industry, Tengku Zafrul Abdul Aziz. The announcement came during the recent GCC-ASEAN summit in Kuala Lumpur.The scope of these talks is broad covering trade in goods and services, investment, and wider economic cooperation. This aligns perfectly with global trends toward diversifying partnerships beyond traditional Western markets.Trade between Malaysia and the GCC already hit $22.3 billion in 2024, covering everything from electronics and jewelry to petroleum products and palm oil. The potential for growth here is huge.Moreover, the ASEAN-GCC connection offers exciting prospects in energy development, investment, and food security. As ASEAN transitions to greener energy and seeks energy security, collaboration with the Gulf -experts in energy- becomes increasingly valuable. On top of that, ASEAN’s strong agricultural base could complement the Gulf’s food security efforts.I’m looking forward to seeing how these agreements evolve and how we can support businesses and investors in seizing the opportunities ahead.&nbsp;

Explore the new free trade negotiations between the GCC, Malaysia, and the UK. ALBM Excello analyzes the legal, commercial, and strategic implications of these talks and how they could reshape regional and global trade.

I’m excited to see these new trade agreements taking shape as it will be a real game changer for regional and global partnerships.

New Free Trade Negotiations Between GCC, Malaysia, and UK Signal Growing Economic Ties

Reflecting on the UAE’s New Merger Control Thresholds | ALBM Excello Blog

March 31, 2025 marked a key milestone for antitrust practitioners and dealmakers in the UAE. On that day, the UAE’s new mandatory and suspensory merger control regime officially came into effect under the country’s updated Competition Law. As someone who has been closely tracking these developments, I was genuinely struck by the scale and significance of the changes.The new regime, first introduced through Federal Decree Law No. 36 of 2023, was supplemented by Ministerial Decree No. 3 of 2025, which was published in the Official Gazette on January 30 and took effect 60 days later. For the first time, the UAE introduced a&nbsp;turnover threshold alongside the existing&nbsp;market share threshold which is a meaningful shift toward international merger control standards.As of March 31, any transaction that constituted an "Economic Concentration" with a nexus to the UAE became subject to mandatory notification to the Ministry of Economy's Competition Department if it exceeded either of the following:<ul><li>Turnover Threshold: AED 300 million (approximately USD 81.6 million) in total annual sales within the UAE's "Relevant Market" during the most recent fiscal year.</li><li>Market Share Threshold: A combined market share exceeding 40% in the "Relevant Market" in the UAE.</li></ul>Importantly, the concept of the "Relevant Market" was defined in two dimensions: the&nbsp;Relevant Product Market and the&nbsp;Relevant Geographic Market, in line with international best practices. The new Decree also reaffirmed that a&nbsp;dominant position exists when a firm holds more than 40% market share, not prohibited in itself, but subject to behavioural constraints to prevent anticompetitive practices.Although the implementing regulations for the new Competition Law had not been issued at that time, the older 2014 regulations remained in place, leaving some procedural uncertainties. However, the Decree's clear thresholds gave us a much firmer foundation to assess whether a transaction triggered notification obligations and is a welcome development for practitioners like me advising on cross-border and regional deals.Looking back, the addition of the turnover threshold represented a major departure from the previous regime, where only market share determined whether a filing was required. While this undoubtedly broadened the scope of potentially notifiable transactions, it also brought greater clarity and predictability, particularly for foreign-to-foreign deals with UAE revenue exposure.Still, a lot hinged (and still hinges) on how the Ministry interprets key elements of the law in practice, especially when it comes to defining relevant markets and determining whether a local nexus exists. We’re also awaiting additional guidance through implementing regulations and exemptions, which will further shape how the regime is applied going forward.For companies contemplating mergers or acquisitions involving businesses with UAE operations or revenue, this reform underscored the importance of:<ul><li>Reviewing their UAE market exposure under both thresholds;</li><li>Factoring merger control timelines into deal planning early on; and</li><li>Seeking legal guidance to mitigate the risk of delays or regulatory issues.</li></ul>As an advisor, I’ve encouraged clients to treat this not as a box-ticking exercise but as a core strategic consideration in deal execution. These rules are now part of the M&amp;A landscape in the UAE, and compliance is essential, not just to avoid penalties, but to ensure smoother transactions in a market that continues to grow in strategic importance.

Discover how the UAE’s revised merger control thresholds impact businesses and regulators. ALBM Excello explains the key legal considerations, compliance strategies, and what companies need to know about the updated regulations.

March 31, 2025 marked a key milestone for antitrust practitioners and dealmakers in the UAE.

Reflecting on the UAE’s New Merger Control Thresholds

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UAE Federal Decree-Law No. 6 of 2025: what’s changing?

UAE Federal Decree-Law No. 6 of 2025: what’s changing?

On 8th September 2025, the UAE issued the Federal Decree-Law No. 6 of 2025 (“the New Law”). Its principal objective is to consolidate financial/payment and insurance regulation under one unified legal framework. This will expand the regulatory power of the of the Central Bank of the UAE (“CBUAE”) and remove existing ambiguities.The New Law repeals:<ul><li>Federal Decree-Law No. 14 of 2018 (the prior central bank / financial institutions law);</li><li>Federal Decree-Law No. 48 of 2023 (the insurance regulation law).</li></ul>The main changes and reforms have been collated in this article.Expanded regulatory perimeterThe New Law broadens the definition of Licensed Financial Activities to include “Open Finance Services”, “payment services using virtual assets”, insurer and reinsurance businesses and insurance-related professions.Many fintechs, infrastructure providers, APIs and decentralised platforms (which may have been in regulatory grey zones) are now explicitly brought under the supervision of the CBUAE.Technology / Enabling Infrastructure Inclusion (Article 62)Article 62 of the New Law states that entities offering, facilitating or even enabling licensed financial activities—via technology, platforms, protocols or infrastructure—must be licensed and regulated even if they are not themselves banks or insurers.This is a more forward-looking provision that recognises the growing importance of fintechs: “enablers” cannot hide behind being a pure technology company.Early Intervention Resolution RegimeThe New Law gives CBUAE statutory powers over recovery and resolution. It can intervene early (requiring companies enact capital / liquidity add-ons, structural changes, removal of senior management or forced mergers). The CBUAE can also take steps including bridge institutions, write-downs, liability transfers, stays, moratoria, and overriding certain creditor rights.This aligns the UAE with international resolution frameworks; the law also sets a creditor hierarchy, and instruments like statutory bail-in.Digital Dirham and payments frameworkThe New Law formally recognises “digital currency / digital Dirham” as currency and grants CBUAE exclusive authority over payments systems, digital money, tokenisation, stored value facilities and cross-border payments.This provides a legal foundation for the CBUAE’s ambitions, clarifies the status of digital Dirham and ensures legal certainty for digital money / tokenised payments.Insurance business integrationRather than being regulated under a separate law, insurance, reinsurance and insurance-related activities (brokers, agents, third-party administrators) will be fully integrated into the financial regulation law under CBUAE.This promotes harmonisation of rules, oversight consistency and cross-sector coordination between banking, payments and insurance.Enhanced penalties and enforcementThe New Law significantly increases the ceilings for administrative fines (up to AED 1 billion), introduces minimum penalties for unlicensed activity, raises penalties for individuals (Authorised Individuals) and criminalises unlicensed financial activity.This signals stronger regulatory “teeth” and more of a deterrent role for CBUAE. Entities must allocate compliance resources accordingly.Transition / grace periodEntities newly brought into scope or those needing to realign will have until 15 September 2026 to do so, subject to extensions at CBUAE’s discretion.During this period, legacy regulations (from the 2018 Law and 2023 Insurance Law) remain effective – until they are replaced by regulations under the new law.&nbsp;

UAE Federal Decree-Law No. 6 of 2025: what’s changing in new financial regulation regime?

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UAE Federal Decree-Law No. 6 of 2025: what’s changing?