The short answer
ADGM companies must have their accounts audited by an ADGM registered auditor unless an exemption applies, mainly the small company exemption for turnover up to USD 13.5 million and no more than 35 employees. The ADGM Registration Authority confirms that a Qualifying Free Zone Person must have audited accounts even when it would otherwise be exempt.
Which ADGM companies can skip the audit?
Companies that qualify as small, broadly turnover of no more than USD 13.5 million and no more than 35 employees, or that meet another exemption in the ADGM Companies Regulations (ADGM Registration Authority guidance, August 2025).
What does ADGM say about QFZPs?
That a company relying on Qualifying Free Zone Person status must prepare audited accounts, even if it would otherwise be exempt, because the corporate tax rules require them (ADGM Registration Authority; Ministerial Decision No. 82 of 2023).
Who can audit an ADGM company?
Only an auditor registered with the ADGM Registration Authority (ADGM Registration Authority).
Before appointing any auditor, ask for proof that the firm is on the current ADGM approved list: a report signed by a firm that is not listed will be rejected at upload.
Frequently asked questions
What is the ADGM small company threshold?
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Turnover up to USD 13.5 million and no more than 35 employees, per the Registration Authority guidance.
Does an exempt ADGM company still file accounts?
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Yes, unaudited accounts are still prepared and filed.
Do ADGM QFZPs need an audit?
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Yes, even when they would otherwise be exempt.
Sources
- Guidance on accounts and audit for ADGM Qualifying Free Zone Persons (August 2025) — ADGM Registration Authority. Checked 17 October 2026.
- Ministerial Decision No. 82 of 2023 on audited financial statements (revenue above AED 50 million and Qualifying Free Zone Persons) — UAE Ministry of Finance. Checked 16 October 2026.