Dubai's Department of Economy & Tourism (DET) refreshed the activity matrix governing 100% foreign ownership on the mainland. The headline movement: two activities previously categorised as strategic (and therefore requiring Emirati participation) moved out, and three activities moved in.
Out: certain wholesale-distribution categories for non-strategic goods, and one consulting subcategory tied to government procurement processes that has been deprecated. Both now allow 100% foreign ownership.
In: three activities related to critical-infrastructure consulting, certain energy-trading subcategories, and a specific defense-adjacent professional service. These now require Emirati participation per the strategic-activities list.
What this means for our clients
We re-screen any active mainland engagement when DET refreshes this matrix. Most of our clients sit in commercial, professional, and tourism categories that have been 100% foreign-owned for years; the refresh does not affect them. The handful of clients in advisory work tied to critical infrastructure or energy deserve a fresh look.
If you are mid-incorporation on the mainland and your activity is in any of the three newly-strategic categories, we'll either restructure with an Emirati partner clean from day one, or — more often — recommend pivoting to a free zone where the activity is licensed without partnership.
DET's update is linked below. We screen for the matrix automatically during scoping; no action needed if you're already on a retainer.