Dubai Knowledge Park in 2026: HR, Training and Professional Development — Licences, KHDA and Tax

August 28, 2026

Dubai Knowledge Park (DKP) is a district of the Dubai Development Authority free zone in which companies engaged in human resources, recruitment, corporate training and professional development are licensed. The annual licence costs AED 15,000 for any of the fourteen segments in Part Six of Decision No. 1 of 2021, the minimum paid-up capital of an FZ-LLC is AED 10,000, and a freelancer permit is AED 7,500 a year. The defining feature of the jurisdiction: training activity requires two permissions at once — a DDA licence and a KHDA Authorisation — while recruitment activity runs into the federal prohibition in Article 6 of Federal Decree-Law No. 33 of 2021.

Note: the central tax finding of this article cuts against the common understanding of free zones. Training, HR consultancy and recruitment do not appear in the list of Qualifying Activities in Article 2 of Ministerial Decision No. 229 of 2025. For a DKP company selling to mainland and overseas clients, that income is not Qualifying Income, and the de minimis threshold of 5% of revenue or AED 5,000,000 is a tolerance for incidental leakage, not a business model. Losing Qualifying Free Zone Person status means nine per cent on the whole of taxable income for the current Tax Period and the four that follow — not on the excess.

What follows is an analysis of the regime under the instruments in force as at August 2026: Dubai emirate-level laws, DDA decisions, Executive Council resolutions and federal tax legislation. Dates of issue and dates of entry into force are stated separately, and the federal, emirate and free zone layers are kept distinct.

A general overview of UAE free zones, and how the choice between them works, is covered separately: an overview of UAE free zones.

What Dubai Knowledge Park Is, and How It Differs from the Neighbouring TECOM Districts

Dubai Knowledge Park is a commercial district of a free zone, not a free zone created by an instrument of its own.That is the first thing to fix, because the whole chain of regulatory citations depends on it.

No Dubai law, decree or resolution establishes “Dubai Knowledge Village” or “Dubai Knowledge Park”, or renames one into the other. The free zone itself was created by Dubai Law No. 1 of 2000, Article 3 of which establishes the “Dubai Technology, Electronic Commerce and Media Free Zone”, issued on 31 January 2000 (25 Shawwal 1420 AH). The districts within it — Internet City, Media City, Knowledge Park, Design District and the rest — were created administratively by the zone authority under its own powers, not by separate legislative acts.

The formulation has to stay precise: the district is mentioned in legislation but not established by it. The name Knowledge Village appears incidentally in later instruments — for example in Decree No. 32 of 2020 on the ownership of educational land, which refers to educational land in education districts “such as the Dubai Academic City and the Knowledge Village”, and in DDA Decision No. 2 of 2005 on advertising by Knowledge Village licensees and Decision No. 1 of 2014 on licence categories. None of them creates the district.

The renaming of Knowledge Village to Knowledge Park around 2016 was not effected by any instrument. It was a commercial rebrand by the operator, and it needed no instrument precisely because the district was never established by a law of its own. Material citing a “decree renaming DKP” describes something that does not exist.

A caveat on the date of Law No. 1 of 2000: the archive index on DDA’s website gives 29 January 2000, while the text of the law itself — both on the Dubai Legislation portal and in DDA’s own copy — is dated 31 January 2000.The Hijri date, 25 Shawwal 1420, corresponds to 31 January, so the index is wrong and the text of the instrument is what should be cited.

The district has operated since 2003. On the operator’s own figures as at December 2023, DKP had more than 700 customers, roughly 30,000 students at the universities located on its campus, 170+ nationalities and 800+ courses on offer; no more recent customer count has been published. The “3,000+ professionals” figure appears on the district’s website with no date and is not corroborated in the group’s reporting — flag it as undated if quoting it. The most recent official figure for the sector is a combined one: as at 15 January 2026 more than 38,500 students were based at Dubai International Academic City and Dubai Knowledge Park, 15% growth since the end of the 2023/24 academic year, drawn from 170+ countries and studying on 600+ programmes; the release gives no split between the two districts.

Feature	Dubai Knowledge Park (DKP)	Dubai International Academic City (DIAC)	Dubai Outsource City (DOC)
Part of Decision No. 1 of 2021	Part Six, segments 21.x	Part Seven, segments 22.x	Segments 17.x
Number of segments	14	5	Outsourcing and adjacent
Profile	Corporate and professional training, HR consultancy, executive search, assessment, content, R&D	Higher education, schools, nurseries	Business process outsourcing, manpower supply
May confer degrees	No	Yes — segment 22.1 Higher Education Provider	No
Minimum FZ-LLC capital	AED 10,000 (the default)	AED 50,000 (expressly listed in Article 15)	AED 300,000 for the Outsource segment
Annual licence	AED 15,000 (freelancer AED 7,500)	AED 15,000	By segment
KHDA requirement	NOC before licence issuance for segments 21.1–21.7	Academic Authorizationfor 22.1; NOC for 22.3 and 22.4	Not applicable

The practical point that clears up the most common confusion: the physical address does not determine the licence category — the segment does. The branch campuses of Manchester, Middlesex, Heriot-Watt, Murdoch, Wollongong and Birmingham sit physically on the DKP campus, but the right to confer degrees comes from segment 22.1 of Part Seven, which belongs to DIAC. A DKP company cannot confer a degree in any circumstances.

The Regulatory Framework: Which Instruments Actually Govern DKP in 2026

The DKP regime rests on three layers: Dubai emirate laws governing the free zone itself, subordinate DDA decisions on licences and companies, and UAE federal legislation on tax, employment and recruitment. What follows is limited to instruments in force.

Layer 1. Dubai emirate laws

Instrument	Date of issue	Entry into force	What it does
Dubai Law No. 1 of 2000 on the Dubai Technology, Electronic Commerce and Media Free Zone	31 January 2000	on publication in the Official Gazette (Art. 30)	Creates the free zone (Art. 3) and its authority; superseded on the matters governed by Law No. 15 of 2014
Dubai Law No. 15 of 2014 Concerning Creative Clusters in the Emirate of Dubai	27 October 2014	on publication (Art. 32)	Article 3(b) substitutes “Dubai Technology and Media Free Zone” with “Creative Clusters in the Emirate of Dubai” and Article 3(c) substitutes “Dubai Technology and Media Free Zone Authority” with “Dubai Creative Clusters Authority”, throughout the legislation of the Emirate; Article 31(a) supersedes Law No. 1 of 2000. Note that the substitution operates on the zone’s shortened name, not on the full name used in the 2000 instrument
Dubai Law No. 10 of 2018 Changing Names Related to the Dubai Creative Clusters Authority	19 September 2018	on the day it is issued, not on publication	Replaces “Dubai Creative Clusters Authority” with Dubai Development Authority, and “Creative Clusters” with “Clusters”
Dubai Law No. 8 of 2023 Amending Law No. 15 of 2014 Concerning the Dubai Development Authority	6 February 2023	on the day it is issued (Art. 2)	Replaces Article 3 of Law No. 15 of 2014 in its entirety, redefining the scope: DDA as a public authority with legal personality and financial and administrative autonomy, the clusters and specified plots as a free zone, and provision for further plots to be brought in by resolution of the Ruler
Dubai Law No. 15 of 2016 Concerning the Regulatory Legislation Issued by Free Zone and Special Development Zone Authorities in the Emirate of Dubai	1 November 2016	30 November 2016 — on publication (Art. 6), Official Gazette No. 406	Article 3 requires every authority to publish its legislation on its own website free of charge; Article 5 makes published legislation binding and brings it into force 30 days after publication unless the instrument provides otherwise; Article 2 extends the Law to the DIFC as well
Executive Council Resolution No. 50 of 2015 Regulating Training Institutes in the Emirate of Dubai	19 November 2015	on publication in the Official Gazette (Art. 24)	Makes KHDA Authorisation mandatory for any training activity, expressly including free zones
Executive Council Resolution No. 30 of 2021 Regulating Vocational Education	14 September 2021	on publication	A separate regime for “vocational education institutions” and “vocational activities”; Article 27 repeals only conflicting provisions of other resolutions, so it does not displace ECR No. 50 of 2015; Article 19 leaves fees to a separate resolution of the Chairman of the Executive Council
Administrative Resolution No. 2 of 2018 — implementing bylaw of ECR 50/2015	31 January 2018	on publication	The procedure for initial approval, authorisation and single-course approval
Dubai Law No. 2 of 2021 Concerning the Knowledge and Human Development Authority	3 March 2021	on the day it is issued (Art. 14)	KHDA’s constitutive law; Article 13(a) repeals Law No. 30 of 2006
Executive Council Resolution No. 11 of 2025 Regulating the Conduct of Free Zone Establishments’ Activities within the Emirate of Dubai	3 March 2025	on publication (Art. 15)	Three routes to mainland access through DET; separate books; a one-year transition
Decree No. 13 of 2024establishing the Unified Digital Window (“Invest in Dubai”)	2024	on publication (Art. 11)	Article 2 extends the regime to all economic activity in the Emirate, and the definition of “Licensing Entity” expressly includes free zone authorities

Dubai Law No. 8 of 2023 is almost never included in published accounts of the DDA chain, even though it is in force and replaces Article 3 of the principal law in full. Reviews that stop at Law No. 10 of 2018 give an incomplete chain. The reason the error is so common is easy to see: DDA’s own laws and regulations page does not list the instrument at all and still shows Law No. 10 of 2018 as the last link, while the Dubai Legislation portal carries its text. DDA’s index is stale on this point, and dlp.dubai.gov.ae is the reliable source.

Dubai Law No. 30 of 2006 on KHDA is repealed and cannot be cited. It was replaced by Law No. 2 of 2021; Law No. 9 of 2018, which amended the 2006 act, is spent along with it.

Layer 2. Subordinate DDA instruments

Instrument	Status	Subject matter
Dubai Creative Clusters Private Companies Regulations 2016(“PCR 2016”)	In force from 1 February 2017	The zone’s company law: forms, capital, directors, registers, share pledges, winding up. Superseded the Private Companies Regulations of 9 April 2003 and absorbed Decisions No. 3/2004, No. 1/2005 and No. 2/2010
Decision No. 1 of 2021 Concerning Licence Categories	In force; replaced Decision No. 1 of 2018	Segments and activities per district, fees (Art. 14), minimum capital (Art. 15), restrictions (Arts. 3 and 5), freelancers (Art. 9)
Decision No. 3 of 2017on PCR 2016 fees	In force from the day of publication on the Authority’s website	The tariff for corporate transactions: registration, name change, shares, pledges, winding up
Decision No. 2 of 2017on fines for contraventions of PCR 2016	In force	Sanctions for breaches of the company rules
Dubai Technology and Media Free Zone Licensing Regulations 2003	In force	Regulation 10 — grounds for revocation, suspension and cancellation of a licence; Regulation 12.1 — no business may be carried on in the UAE outside the zone on the strength of a zone licence alone; Regulation 31 — the power to prescribe sanctions
Dubai Technology and Media Free Zone Employment Regulations 2004	In force, as amended	Sponsorship of employees by the zone authority, a bank guarantee per employee, the sponsorship agreement
Decision No. 3 of 2008on penalties for breach of the Employment Regulations 2004	In force	Employment-related fines, including for supplying one’s own sponsored employees to third parties
Circular 423 of 17 November 2022	In force	The obligation to file audited financial statements and an annual return through the AXS portal
Circular 670 of 3 June 2026	In force	The procedure for confirming ultimate beneficial ownership data through AXS

A naming caution worth observing when citing: the company regulations are still titled “Dubai Creative Clusters Private Companies Regulations 2016” and were not retitled when the authority was renamed in 2018. A citation to “DDA Companies Regulations 2016” is formally wrong.

Decision No. 1 of 2021 carries no date on its face. Neither a date of issue nor a date of entry into force appears on the document; DDA indexes it as “Licensing Categories 2021”. This article cites it by number and year, without a day or month.

Legally that is not a gap but a consequence of Article 5 of Dubai Law No. 15 of 2016: an instrument of a free zone authority is deemed proclaimed to everyone subject to it and comes into force 30 days after publication on the authority’s website, unless the instrument itself provides otherwise. The clock runs from publication on dda.gov.ae rather than from signature, so the absence of a date on the cover does not deprive the Decision of effect.

The preamble also shows who issued it and on what footing: it is signed by Malek Sultan Al Malek, Director General of the Dubai Development Authority, “after perusal of the Dubai Technology and Media Free Zone Licensing Regulations 2003 and Regulation 3.2 thereunder”, and it expressly replaces Decision No. 1 of 2018 concerning licence categories as amended. The Decision’s full title lists the nine districts alongside Emirates Towers. The series has been revised repeatedly: Decision No. 1 of 2014, Decision No. 1 of 2018, Decision No. 1 of 2021.

Layer 3. UAE federal legislation

Federal Decree-Law No. 33 of 2021 on the Regulation of Employment Relations (issued 20 September 2021, in force 2 February 2022, amended by Federal Decree-Law No. 20 of 2023), together with its Executive Regulation — Cabinet Resolution No. 1 of 2022 (issued 3 February 2022, effective 2 February 2022) — supplies the substantive law of employment for DKP companies as well. The tax and compliance layer is analysed in the sections below.

The mechanics of hiring a first employee in the UAE and the employer duties that follow are covered separately: how to hire your first employee in the UAE.

Who Regulates DKP: DDA as Authority, TECOM as Operator

The regulator and licensing authority for DKP is the Dubai Development Authority; TECOM Group PJSC is the commercial developer and operator of the districts. These are not two names for the same thing — the division of roles is explicit and both sides describe it identically.

DDA’s own formulation: the group’s districts “are located and operated under the jurisdiction of Dubai Development Authority (DDA), which is in charge of company registration and licensing, employee services, planning and development as well as developing and implementing regulations.”

TECOM Group PJSC is a listed company, trading on the Dubai Financial Market since 5 July 2022 under the ticker TECOM. The offering sold 625,000,000 ordinary shares — 12.5% of issued share capital — at AED 2.67 per share, raising approximately AED 1.7 billion. That percentage is the IPO free float and is not a statement about the current one.

TECOM manages ten business districts, of which DKP is one. The full list: Dubai Internet City, Dubai Outsource City, Dubai Media City, Dubai Production City, Dubai Studio City, Dubai Knowledge Park, Dubai International Academic City, Dubai Science Park, Dubai Design District (d3) and Dubai Industrial City.

A counting discrepancy worth knowing: DDA’s own page on TECOM lists twelve entries, adding in5 and D/Quarters. Those are an incubator platform and a flexible-workspace brand, not licensed districts. The correct figure is ten districts.

The practical consequence of the split: commercial lease terms are agreed with TECOM, while the licence, amendments to it, visas and corporate actions all go through DDA. A licensing problem is not solved through the landlord, and the reverse holds equally.

The portal: why filings go through AXS rather than Invest in Dubai

All DDA registration and licensing services are filed through the AXS portal. The same platform handles letter validation and the application for a No Objection Certificate to the Department of Economy and Tourism. Technically it is a Salesforce Experience Cloud site, which explains its form-driven rather than document-driven character: filings are made by completing fields, not by uploading agreements.

Yet Decree No. 13 of 2024 formally binds DDA to the “Invest in Dubai” Unified Digital Window. Article 2 extends the decree to all economic activity in the Emirate, the definition of “Licensing Entity” expressly includes free zone authorities, and Article 4 obliges them to issue, renew, amend and cancel licences through that window. The decree sets no implementation timetable — Article 9 delegates it to implementing resolutions.

The gap between the rule and the practice should be stated plainly: as at August 2026 every published DDA service page still directs applicants to AXS, and no DDA circular announcing a migration to the Unified Digital Window has been published. DKP companies work with AXS in practice; the decree’s obligation nonetheless stands.

The comparison between a free zone and a mainland registration, and what actually changes with the choice, is covered separately: free zone or mainland in the UAE.

The Fourteen DKP Licence Segments: What Can Actually Be Licensed

Dubai Knowledge Park is Part Six of Decision No. 1 of 2021, and its licence segments are numbered 21.1 to 21.14.There are fourteen in all. The Decision does not use “Education”, “Human Resources” or “Training” as top-level categories — the structure runs district → Part → segment → activity.

Article 2.1 reads: “Licences are issued by the Authority for each of DIC, DMC, DKP, DIAC, DPC, DOC, DSC, DSP and D3 for their respective licence segments.” Article 3.1: “Each of DIC, DMC, DKP, DIAC, DPC, DOC, DSC, DSP and D3’s licence categories are divided into segments and a number of activities may be carried out under each segment.”

Segment	Name	Annual fee	Activities included	KHDA NOC required
21.1	Professional and Management Development Training	AED 15,000	Three	Yes
21.2	Computer Training	AED 15,000	One	Yes
21.3	Language Training	AED 15,000	One	Yes
21.4	Fine Arts Training	AED 15,000	One	Yes
21.5	Child Skills Development Training	AED 15,000	One	Yes
21.6	Tutoring Services	AED 15,000	One	Yes
21.7	Technical & Occupations Skills	AED 15,000	Three	Yes
21.8	Human Resources Consultancy	AED 15,000	Three	No
21.9	Research & Development	AED 15,000	One	No
21.10	Content Development	AED 15,000	One	No
21.11	Assessment and Testing	AED 15,000	One	No
21.12	Executive Search	AED 15,000	One	No, but an AED 100,000 guarantee
21.13	Freelancers	AED 7,500	One	No
21.14	Association (Non-Profit)	AED 15,000	One	No, but CDA approval

The annual licence fee is identical across every DKP segment at AED 15,000, apart from the freelancer permit at AED 7,500. The differentiator is not price but how many activities the fee buys: three for segments 21.1, 21.7 and 21.8; one for everything else.

The practical consequence: an HR consultancy licence carries three activities for the same money as an executive search licence carrying one. When planning a service line that difference is material.

What the activities inside segments 21.1 to 21.14 actually are

Across its fourteen DKP segments, Decision No. 1 of 2021 defines forty-seven activities, and they are distributed very unevenly. Four segments are set out in detail; nine carry exactly one activity each.

Segment	Number of activities	Numbering
21.1 Professional and Management Development Training	9	21.1.1–21.1.9
21.2 Computer Training	1	21.2.1 Computer Skills Training
21.3 Language Training	1	21.3.1 Language Training
21.4 Fine Arts Training	2	21.4.1–21.4.2
21.5 Child Skills Development Training	1	21.5.1 Child Skills Development Centre
21.6 Tutoring Services	1	21.6.1 Supplementary Education Services
21.7 Technical & Occupational Skills Training	13	21.7.1–21.7.13
21.8 Human Resources Consultancy	9	21.8.1–21.8.9
21.9 Research & Development	1	21.9.1 Research and Development Centre
21.10 Content Development	1	21.10.1 Content Development Centre
21.11 Assessment and Testing	1	21.11.1 Assessment Centre
21.12 Executive Search	1	21.12.1 Executive Search
21.13 Freelancers	5	21.13.1–21.13.5
21.14 Association (Non-Profit)	1	21.14.1 Professional Association

Segment 21.1, “Professional and Management Development Training”, is divided into nine activities: 21.1.1 educators professional training; 21.1.2 social and behavioural training; 21.1.3 sales and marketing training; 21.1.4 accounting and finance training; 21.1.5 insurance training; 21.1.6 legal training services; 21.1.7 human resources training and development; 21.1.8 management training; 21.1.9 business and secretarial training.

Segment 21.7, “Technical & Occupational Skills Training”, is divided into thirteen activities: 21.7.1 media production training; 21.7.2 transport services training; 21.7.3 hospitality and tourism training; 21.7.4 agriculture training; 21.7.5 domestic services training; 21.7.6 garment design training; 21.7.7 hair stylist training; 21.7.8 beauty care training; 21.7.9 occupational safety and firefighting training; 21.7.10 security training; 21.7.11 architecture design training; 21.7.12 construction, mechanical and the built environment skills training; 21.7.13 health care awareness training.

Contrary to the common assumption, 21.7 is not “the construction and engineering trades”. Construction occupies one of its thirteen positions (21.7.12); the other twelve cover media, transport, hospitality, agriculture, domestic services, the beauty industry, security and health care. The scope of 21.7.13 is drawn broadly in the Decision — from first aid and nursing to physiotherapy, nutrition and radiography — which makes it the segment’s most sensitive activity for sector approvals.

Segment 21.8, “Human Resources Consultancy”, is divided into nine activities: 21.8.1 organizational restructuring and reorganizing; 21.8.2 strategic HR planning; 21.8.3 job description and job evaluation; 21.8.4 international re-locations and orientation; 21.8.5 change management; 21.8.6 compensation, benefits and recognition; 21.8.7 performance management; 21.8.8 career development and management; 21.8.9 HR audits and accountabilities.

From which follows a practical point that is regularly missed: the annual fee for segment 21.8 covers three of the nine available activities. The company selects three from the list; it does not acquire the segment whole, and a fourth activity onwards is paid for separately.

Two restrictive provisos are written into the activity descriptions themselves rather than into the Decision’s general articles. The description of 21.11.1 Assessment Centre ends by stating that, for the avoidance of doubt, recruitment and placement services are neither included in nor permitted under that activity. The description of 21.12.1 Executive Search confines the activity to retainer-based search on behalf of client organisations — classic retained search rather than contingency placement.

Segment 21.13, “Freelancers”, contains five categories: 21.13.1 Education Advisor; 21.13.2 eLearning Advisor; 21.13.3 Executive Coaching; 21.13.4 Researcher; 21.13.5 Trainer. That list matches, word for word, the one published on the GoFreelance platform: here the marketing page reproduces the instrument rather than departing from it.

A note on spelling: segment 21.7 is named three ways within the Decision itself — “Technical & Occupations Skills” in the Article 14 fee table, “Technical & Occupational Skills” in Article 5.5, and “Technical & Occupational Skills Training” in Part Six. The inconsistency is internal to the instrument, and a citation should reproduce whichever form appears in the article being cited.

Adding a segment from another cluster is possible but discretionary. Article 11.1 reads: “A Licensee licensed in one Cluster may add an additional segment or activity from another Cluster at the sole discretion of the Authority.”

What a second segment costs

Article 10.1 sets up a discount: an additional segment costs AED 10,000 a year on top of the standard fee, provided the segment being added is a standard one charged at AED 15,000 a year. Where the added segment carries a higher fee than AED 15,000, no discount applies. There is no pro-rating regardless of when the licence falls due for renewal.

A DKP company running both training and executive search pays AED 15,000 + AED 10,000 = AED 25,000 a year, not AED 30,000. That follows directly from Article 10.1 and is one of the few incentives built into the tariff to widen the licence perimeter.

What DKP does not have: manpower supply

The activity “Manpower Supply” belongs to the Outsource segment (17.1) in Dubai Outsource City, not to DKP. Its stated scope: companies providing manpower supply services (skilled and semi-skilled workforce) within the free zonefor third-party licensees to meet their labour-intensive requirements. The condition of issue: the activity is restricted to organisations already licensed by the relevant Department of Economic Development in the UAE.

The practical consequence, and it changes the shape of a project: a staffing or outstaffing business cannot be licensed in DKP at all. It is steered to DOC, requires an existing mainland DED licence, and is confined in scope to supply within the free zone.

Two Provisos in Decision No. 1 of 2021 That Change a Project’s Economics

Decision No. 1 of 2021 contains two conditions specific to DKP segments, and both are easy to miss when reading the tariff table.

The first proviso: a KHDA NOC as a condition of licence issuance

Article 5.5 reads: “Licensees under Professional and Management Development Training (Segment 21.1), Computer Training (Segment 21.2), Language Training (Segment 21.3), Fine Arts Training (Segment 21.4), Child Skills Development Training (Segment 21.5), Tutoring Services (Segment 21.6), Technical & Occupational Skills (Segment 21.7), Educational Support Services (Segment 22.3), and School (Segment 22.4) must obtain a No Objection Certificate (NOC) from KHDA prior to issuance of licence.”

Seven of the fourteen DKP segments are gated by KHDA at the point of licence issue — every training segment, 21.1 through 21.7. Segments 21.8 to 21.12 — HR consultancy, R&D, content development, assessment and testing, executive search — are not in that list and need no NOC.

The practical consequence: the dividing line inside DKP does not run between “education” and “business” but between training and everything else. An HR consultant is licensed by DDA directly; a training company only after obtaining the NOC.

The second proviso: an AED 100,000 bank guarantee for executive search

Article 3.7 reads: “Licensees under Executive Search (Segment 21.12) are required to provide and maintain a deposit or bank guarantee with the Authority in the amount of AED100,000.”

This condition has nothing to do with share capital and is not mentioned in Article 15. For a recruitment business it is economically far more significant than the AED 10,000 minimum capital requirement, and overlooking it when budgeting is a common error.

Structurally it is the free zone analogue of the bank guarantees MOHRE requires from mainland recruitment agencies. The very existence of such a guarantee in a DDA decision is a strong indication that the Authority treats executive search as the outer boundary of what it is prepared to license in this field.

Contravention under Schedule 4	Penalty
Licence renewed more than 30 but not more than 60 daysafter the expiry date	AED 2,500
Licence renewed more than 60 but not more than 90 daysafter the expiry date	AED 5,000
Licence renewed more than 90 days after the expiry date	AED 10,000
Carrying on business in the Zone without a licence	AED 10,000; AED 25,000 for any subsequent offence
Carrying on business of a different segment or activity from that on the licence	AED 10,000
Furnishing misleading or inaccurate information to the Authority	AED 5,000
Hindering or preventing inspectors appointed by the Authority	AED 5,000
Failing to provide ultimate beneficial ownership on the Authority’s demand	AED 5,000, additionally or alternatively the sanctions in Regulation 10

The employment fines that are published, and bear directly on an HR business

Decision No. 3 of 2008 on penalties for breach of the Employment Regulations 2004 is published in full and contains two entries that are critical for a personnel business specifically.

Contravention	Fine
Illegally employing employees of other licensees	AED 5,000 per employee
Employing persons not sponsored or approved by the Authority	AED 7,500 per person; AED 10,000 if continued
Supplying sponsored employees to third parties	AED 5,000 per person + visa cancellation
Supplying visit visa holders to third parties	AED 5,000 per person + visa cancellation
Failing to renew a residence or employment visa before expiry	AED 2,500 per person; AED 5,000 if more than 90 days
Failing to cancel a visa within 30 days of departure	AED 2,500 per person; AED 5,000 if more than 90 days
An employee outside the UAE for more than 6 months	AED 5,000 per person
Failure to report an absconded or missing employee within 14 days	AED 5,000 per person
Employing a person on a visit visa	AED 5,000 per person
Failing to ensure a visit visa holder departs before expiry	AED 1,500 per person

The two entries on “supplying employees to third parties” are the enforcement counterpart to manpower supply not being a DKP activity. A company licensed in DKP for training or HR consultancy that places its own sponsored staff with a client is fined per person and loses the visas, however the client contract is drafted.

Does a DKP Training Company Need a KHDA Authorisation? Yes — and It Is a Separate Permission

Training activity in Dubai requires two permissions at once: a KHDA Authorisation and a licence from the relevant licensing authority — for a DKP company, a DDA licence. The free zone does not remove a training institute from KHDA’s jurisdiction.

The legal basis is Executive Council Resolution No. 50 of 2015 Regulating Training Institutes in the Emirate of Dubai, issued 19 November 2015 and in force from publication in the Official Gazette.

Article 4, in substance: no person may offer training activities to others in the Emirate without first obtaining the relevant Authorisation from KHDA and a licence from the relevant Licensing Authority. A training institute may not operate outside the scope of its Authorisation, and a venue owner may not permit training to be delivered unless the person delivering it holds KHDA approval.

Article 2 extends the Resolution to any person conducting training activity in the Emirate, including free zones and special development zones. The Article 1 definition of “Licensing Authority”: an entity legally authorised to license economic activities in the Emirate, in a free zone, or in a special development zone. DDA falls squarely within it.

KHDA’s constitutive Dubai Law No. 2 of 2021 confirms the reach from the other side: Article 3(a)(2) extends it to all educational institutions licensed to operate in the Emirate, including in special development zones and free zones.

From DDA’s side the loop closes with Article 5.5 of Decision No. 1 of 2021, which makes a KHDA NOC a condition precedent to licence issuance. The claim that a DKP training licence does not engage KHDA is wrong as a matter of law and wrong as a matter of DDA’s own practice.

Who does NOT need a KHDA Authorisation: the Article 2(b) exclusions

Resolution No. 50 of 2015 does not apply to five categories, and one of them has direct commercial significance:

No.	Exclusion
1	Government training institutes and government entities
2	Entities authorised by a government entity to conduct training activity
3	Private entities that provide training programmes by themselves to their employees in order to increase their knowledge and develop their skills
4	Training programmes related to licensed conferences
5	Other entities exempted by resolution of the Chairman of the Executive Council

The third exclusion is the one that matters for planning: in-house training of a company’s own staff falls outside the Resolution and needs no KHDA Authorisation. A group’s internal corporate university, teaching only its own employees, sits outside the regime. The words “by themselves” carry weight: the exclusion covers training the company delivers with its own resources, not training bought in from an outside provider — an external provider brought in remains within the regime and must hold an Authorisation. The moment the same programme is sold to an external client, the exclusion falls away for the company too.

The fourth exclusion should be read narrowly: it covers training programmes connected with licensed conferences, not any event styled as a conference.

The structure of KHDA permissions: three tiers, not four

The procedure is set by Administrative Resolution No. 2 of 2018, issued 31 January 2018.

Tier 1 — Initial Approval. Valid for no more than six months, used to reserve the name and complete licensing. It requires a commercial licence application and a feasibility study covering vision, mission, staffing criteria, training activities, admission standards, quality systems and the list of programmes.

Tier 2 — the Authorisation, styled the Educational Services Permit. It requires a valid Initial Approval, a licence from the relevant licensing authority, compliant premises, resources matching the feasibility study, and a live website listing the programmes.

Tier 3 — single-course Authorisation (Article 14). This is for any person other than a training institute delivering a single course. The instructor’s passport, Emirates ID and CV are required; processing takes five working days.

There is no separate “individual trainer permit” and no separate “consultancy permit” for trainers within the training-institute regime. The route for one-off delivery is Article 14. HR consultancy is not the subject of a KHDA permission at all: it is a DDA licence category (segment 21.8) with no external approvals.

Validity and KHDA fees

An Authorisation is valid for one year and renewable for the same period; the renewal application is filed no later than 30 days before expiry (Article 9 of Resolution No. 50 of 2015).

There is a divergence here between the text of the Resolution and KHDA’s operative tariff, and it should be shown rather than smoothed over.

Source	Basis of calculation	Rates
Schedule 1 to Resolution No. 50 of 2015	By number of programmes	Application for Authorisation AED 5,000; Authorisation 1–2 programmes AED 25,000; 3–4 AED 30,000; 5–6 AED 35,000; 7 or more AED 40,000; Authorisation for a non-institute party AED 15,000 per course; add a training programme AED 2,500; advertisement approval AED 100; variation of details AED 100; certificate attestation AED 50
Schedule 2 to Resolution No. 50 of 2015	Renewal by programmes and year	1–2 programmes: AED 10,000 / 18,750 / 25,000 for year 1 / 2 / 3 and after; 3–4: AED 10,000 / 22,500 / 30,000; 5–6: AED 10,000 / 26,250 / 35,000; 7 or more: AED 10,000 / 30,000 / 40,000
KHDA’s live service page (August 2026)	By number of activities	Issuance: 1–2 AED 15,000; 3–4 AED 18,000; 5–6 AED 20,000; seven or more AED 25,000; turnaround 8 working days. Renewal at the same rates, turnaround 3 working days. Single-course Authorisation for a person that is not a training institute AED 5,000, turnaround 6 working days

The divergence can be explained on the substance, and the explanation is worth setting out in full because it dissolves most of it. The band structure is word-for-word the same in both sources: 1–2, 3–4, 5–6, seven or more. So are the ancillary fees: adding a programme (activity) AED 2,500, advertising approval AED 100, amending particulars AED 100. The decisive evidence comes from an earlier official document of the authority itself — KHDA’s Customer Service Charter: it gives renewal rates of AED 25,000 / 30,000 / 35,000 / 40,000, but already labels them “activities” rather than “programmes”.

Two changes therefore happened, and not at the same time: the unit of calculation was relabelled first, at unchanged amounts, and only later were the amounts themselves cut. “Activity” on KHDA’s service pages is an administrative synonym for the “training programme” of Schedule 1; what actually changed is the four headline rates and the single-course fee for a person that is not a training institute (from AED 15,000 to AED 5,000). The Arabic text of the Resolution uses البرامج التدريبية — training programmes — and prevails in the event of a conflict between the language versions.

What could not be found is the instrument by which the reduction was approved. Neither the Dubai legislation portal nor KHDA’s own site carries an Executive Council Resolution, decree or administrative resolution amending Schedule 1 or Schedule 2. That matters, because Article 7(b)(4) of Dubai Law No. 2 of 2021 permits KHDA’s Director General only to propose fees and submit them to the competent government entities for approval — the authority cannot reset the rates unilaterally. The likeliest home for the operative instrument is the resolution of the Chairman of the Executive Council to which Article 19 of Executive Council Resolution No. 30 of 2021 on vocational education refers; it could not be located in the public domain.

The practical position: budget from the tariff on KHDA’s service pages, and in a legal opinion state expressly that no instrument aligning the Resolution’s schedules with that tariff could be found in open sources. Administrative Resolution No. 2 of 2018 contains no fee schedule and does not amend the schedules; it refers only to “the prescribed fees” (Articles 2(6), 5(6) and 19(2)), leaving Schedule 1 as the sole normative source of amounts.

A related continuity point: Article 13(c) of Dubai Law No. 2 of 2021 preserves instruments made under the repealed Law No. 30 of 2006 “until new superseding legislation is issued”. That is why Resolution No. 50 of 2015 and Administrative Resolution No. 2 of 2018 remain in force notwithstanding the repeal of their parent law.

Further KHDA fees confirmed on the service pages: add a course AED 100 (8 working days), add a programme or activity AED 2,500, amendment (name, manager, shareholder, location) AED 100 each, advertisement approval AED 100 (2 working days).

Courses are approved one by one, and it is a separate step

A training institute may not offer a programme that is not stated in its Authorisation, or modify one that is, without KHDA’s prior written approval (Article 12 of Resolution No. 50 of 2015).

Operationally this is the “add course” (AED 100) and “add programme” (AED 2,500) services. The tariff difference between a “course” and a “programme” is twenty-five-fold, and a product line should be planned with that in mind.

Advertising is also subject to KHDA prior approval — a requirement most commentary omits, and breaching it costs AED 25,000.

KHDA fines: Schedule 3 to Resolution No. 50 of 2015

Contravention	Fine
Operating without an Authorisation	AED 50,000
Non-compliance with the terms of an Authorisation	AED 50,000
Unauthorised training activity	AED 50,000
Venue owner permitting delivery without Authorisation	AED 50,000
Non-compliance within the grace period	AED 50,000
Assigning an Authorisation without permission	AED 30,000
Unauthorised programme or modification	AED 25,000
Varying a licence or Authorisation without approval	AED 25,000
Misleading advertising	AED 25,000
Off-premises delivery without approval	AED 20,000
Failure to provide reports or information	AED 20,000
Failure to create trainee and staff records	AED 20,000
Inadequate equipment or supplies	AED 20,000
False documents or information	AED 20,000
Misuse of premises	AED 20,000
Unauthorised gifts or donations	AED 20,000
Unauthorised building, closure or lease	AED 20,000
Non-compliance with premises standards	AED 20,000
Operating on an expired Authorisation	AED 15,000 per month, capped at AED 100,000
Conducting activity before disclosing fees	AED 10,000
Failure to maintain records	AED 10,000
Non-compliance with KHDA resolutions	AED 5,000
Obstructing an inspection	AED 5,000

Fines double on repetition within a year, capped at AED 100,000, and KHDA may also suspend the activity, bar enrolment or revoke the Authorisation.

The comparison both tables exist to make: an annual DDA licence costs AED 15,000, while the fine for training without a KHDA Authorisation is AED 50,000. Saving on the second permission produces a negative return on first detection.

Can a DKP Company Recruit for Mainland Employers?

The answer depends on which of three activities is meant, and the line does not fall where it is usually drawn.Executive search advisory, agency placement, and manpower supply have to be separated.

The federal prohibition: Article 6 of Federal Decree-Law No. 33 of 2021

Article 6(3) reads: “It is not permissible to carry out the activity of recruitment or mediation to recruit or employ Workers without a licence from the Ministry.”

Article 6(1): “Work may not be practiced in the State, and the Employer may not recruit or employ any Worker, except after obtaining a work permit from the Ministry.” Article 6(4) prohibits an employer from charging recruitment costs to the worker.

Article 3(1) applies the Decree-Law to all establishments, employers and workers in the private sector in the State.Article 3(2) lists the excluded categories — federal and local government employees, the armed forces, police and security forces, and domestic workers — and free zones are not among them; Article 3(3) allows the Cabinet to exclude further categories on the Minister’s proposal, but no such resolution has been made for free zones. The words “free zone” do not appear anywhere in the Decree-Law. That matters: the position of free zones here is a question of construction, not of express words.

Three activities, three different answers

The first — executive search advisory. Licensable in DKP. Segment 21.12, annual fee AED 15,000, one activity, plus a deposit or bank guarantee of AED 100,000 under Article 3.7 of Decision No. 1 of 2021. No external approvals are required.

The second — agency placement of candidates with mainland employers. At the level of the instruments there is no answer either way; at the level of administrative practice the answer is negative.

The legislative layer is silent. Neither Article 6(3) of Federal Decree-Law No. 33 of 2021, nor Article 9 of Cabinet Resolution No. 1 of 2022, nor Ministerial Decree No. 51 of 2022, nor Ministerial Resolution No. 302 of 2022 amending it, contains the words “free zone”, “Department of Economic Development” or “trade licence”. The conditions in Article 9(2) of Cabinet Resolution No. 1 of 2022 are exhaustive and are in substance capable of being met by a free zone company: no conviction for crimes of honour or trust or for human trafficking, a bank guarantee, a credit report, and “any other conditions stipulated in a resolution issued by the Minister”. Article 3 of Decree No. 51 of 2022 adds requirements on the applicant (not a Ministry employee or a relative of one to the second degree; a headquarters with a clearly defined address; a written attestation of understanding the rules), and Resolution No. 302 of 2022 adds a fourth condition on not owning or partnering in an establishment against which grounds for suspension exist.

The administrative layer answers differently. MOHRE’s own service page for issuing a new licence for a temporary employment and mediation agency lists, as the first required document, initial approval from the Department of Economic Development, and separately a copy of the applicant’s valid trade licence. No instrument imposes that requirement: it exists only at service-catalogue level. Tellingly, renewal requires only a copy of the trade licence and a police clearance certificate — there is no second DED check.

DDA points the same way from its own side. Where the Authority permits manpower supply at all — activity 17.1.8 in Dubai Outsource City — it expressly conditions it on the applicant already holding a licence from the relevant mainland Department of Economic Development. Regulation 12.1 of the Licensing Regulations 2003 adds the general bar: a person may not carry on any business in the UAE outside the zone solely on the strength of a licence granted under those regulations.

This article therefore puts the answer this way: there is no federal prohibition on a free zone company, but MOHRE’s published procedure is built around a mainland applicant, and nothing in the public domain confirms that the Ministry will accept a free zone licence and a free zone authority’s initial approval in place of the DED documents. The practical recommendation: obtain written confirmation from MOHRE on the specific structure before building a business model on it, and in parallel confirmation from DDA that it would add the corresponding activity.

A separate note on an unreliable statement on a government portal: the u.ae page on recruitment agencies asserts that MOHRE grants recruitment agency licences “to UAE citizens only”. No nationality condition appears in Cabinet Resolution No. 1 of 2022 or in Ministerial Decree No. 51 of 2022; the wording reads as inherited from the pre-2022 regime and should not be relied on.

The third — manpower supply and staffing. Not licensable in DKP. Manpower Supply is activity 17.1.8 of the Outsource segment in Dubai Outsource City. Its condition: the activity is restricted to organisations already licensed by the relevant Department of Economic Development in the UAE, and its scope is supply within the free zone to third-party licensees.

A related threshold worth noting: under Article 3.8 of Decision No. 1 of 2021, licensees under Operations Support (activity 17.1.7) must retain copies of their third-party contracts for verification by the Authority and may not supply operations support services through any employee earning less than AED 3,000 a month.

MOHRE recruitment licences: categories, fees and guarantees

Cabinet Resolution No. 1 of 2022, Article 9, separates two regimes. “Mediation” is bringing the positions of both parties together in order to hire and establish an employment relationship: the agency introduces, the client employs. “Temporary employment and outsourcing” is hiring the worker with the intention of outsourcing to a third party: the agency employs, the client uses.

Category	Issuance fee	Renewal fee	Bank guarantee	Validity
Mediation agency	AED 25,000	AED 12,500	not less than AED 300,000	2 years
Temporary employment and outsourcing agency	AED 50,000	AED 25,000	not less than AED 1,000,000	2 years
Combined licence (temporary employment + outsourcing + mediation)	AED 75,000	AED 37,500	not less than AED 1,000,000	2 years

The Article 9 conditions include no convictions for crimes of honour or trust or human trafficking, a credit report and the guarantees above, together with a prohibition on an agency supplying workers to another agency for onward employment with a beneficiary. An insurance scheme may substitute for the bank guarantee.

A divergence within MOHRE’s own publications worth knowing: MOHRE’s FAQ page gives the mediation licence a one-year term at the same fees, while the service pages give two years. The service pages belong to the 2022 regime and are the more current artefact; the FAQ appears stale. This article states the two-year term while noting the divergence expressly.

MOHRE’s sector instruments on agencies are Ministerial Decree No. 51 of 2022 on licensing and regulating the activities of recruitment agencies and Ministerial Resolution No. 302 of 2022 amending it. Decree No. 51 of 2022 runs to thirteen articles: definitions adopted from the Decree-Law and its Executive Regulation, the licence requirement, licence conditions, the agency licence, branches, obligations, suspension and cancellation, implementation, repeal and publication. Its Article 5 is the one to note when planning geography: an agency may open branches in the same emirate in which it is licensed, or in any other emirate “according to the requirements of local licensing” — the only point in the framework that touches emirate-level licensing, and it presupposes rather than displaces it. The separate regime for domestic-worker recruitment agencies (Ministerial Resolution No. 676 of 2022 and Administrative Resolution No. 5 of 2024) must not be conflated with the subject of this article.

The clean route: HR consultancy

Segment 21.8, “Human Resources Consultancy”, is the only DKP category in the personnel field with no external approvals and no special financial requirement. Annual fee AED 15,000, three activities included, no KHDA NOC, no bank guarantee.

The practical conclusion for structuring: advisory work on human resources, assessment, reward design and organisational design proceeds in DKP without complication; anything that shades into placement with an employer, or into supplying personnel, needs separate analysis and most likely a different UAE jurisdiction.

Payroll mechanics, WPS and end-of-service gratuity are covered separately: UAE payroll — the complete employer guide.

Entity Forms, Capital and DDA Fees: What a DKP Company Actually Costs to Open

Three forms are available in the DDA free zone: an FZ-LLC, a branch of an existing foreign or UAE company, and a freelancer permit. There is no public “FZ-CO” form in this zone — that form belongs to other UAE free zones, and citing it for DKP is an error.

The FZ-LLC is the only incorporated form. Regulation 12.3.1 of PCR 2016 requires the name to end with the word “FZ-LLC” as its last word. DDA offers three shareholder configurations: a natural person; a corporate person; natural and corporate persons together. Branches are governed by Regulations 91 to 96 of PCR 2016.

Minimum paid-up capital

Regulation 25.1 of PCR 2016 reads: “The minimum issued fully paid up share capital of a company shall be such amount as the Registrar specifies from time to time.” The figure itself is not in the regulation — the provision delegates it.

The figure is set by Article 15 of Decision No. 1 of 2021: “Subject to certain minimum paid up capital amounts set out below for specific segments and activities, for all other activities and for the purposes of Regulation 25.1 of the PCR, the minimum paid up capital of an FZ-LLC shall be AED 10,000.”

No DKP segment is named in the Article 15 table, which means there is no uplifted capital requirement for training, HR consultancy or executive search — the AED 10,000 default applies. By contrast, DIAC’s education segments are expressly listed in Article 15 at AED 50,000 each.

Regulation 25.2 requires shares to be denominated in dirhams unless the Registrar agrees otherwise; Regulation 25.4 requires initial capital to be subscribed in cash unless the Registrar approves otherwise.

A practical point worth emphasising: for a recruitment business the real capital requirement is not the AED 10,000 minimum but the AED 100,000 guarantee under Article 3.7. The difference is tenfold, and it does not appear in Article 15 at all.

Corporate fees: Decision No. 3 of 2017

The provenance of the tariff is worth fixing: the preamble of Decision No. 3 of 2017 recites the Private Companies Regulations 2016, the Licensing Regulations 2003 and Dubai Law No. 15 of 2016, and its Article 2 repealed and replaced the schedule of fees enclosed in Decision No. 1 of 2017 of 9 February 2017. Article 3 brings it into force on the day of its publication; it remains the operative tariff in 2026.

No.	Service	Fee
1	Incorporation and registration of a company	AED 3,500 + activity fees
2	Change of company name	AED 2,000 per transaction
3	Change of parent company name	AED 2,000 per transaction
4	Change of director or secretary	AED 200 per person, capped at AED 1,000
5	Change of financial year end	AED 200 per transaction
6	Amendment of the articles (clauses, articles)	AED 500 per transaction
7	Increase of share capital	AED 3,000 per transaction
8	Reduction of share capital	AED 3,000 per transaction
9	Transfer of shares	AED 3,000 per transaction
10	Pledge registration, amendment, transfer or termination	AED 3,000 per transaction
11	Conversion from branch to FZ-LLC	AED 3,500
12	Amalgamation of companies	AED 3,500
13	Continuation of a company into DCC	AED 5,000 + activity fees
14	Continuation of a company outside DCC	AED 10,000
15	Change of general manager	AED 1,000
16	Change of company address	AED 500 per transaction
17	Voluntary winding up of a company	AED 1,500
18	Request for extract	AED 500 consolidated; AED 200 per list
19	Re-issue of constitutional documents	AED 1,000 per document
20	Attestation — true copy or original seen	AED 100 per document
21	Notarisation of a constitutional document	AED 200 per document
22	Certificate of Good Standing or Incumbency	AED 1,000 per certificate
23	Company information letter	AED 500 per letter
24	Letter or NOC to a third party	AED 250 per letter
25	Tax exemption certificate	AED 250 per certificate

Each service additionally carries AED 20 in Knowledge & Innovation Dirhams: AED 10 Knowledge Dirham and AED 10 Innovation Dirham per transaction.

The full first-year cost for a DKP company

Item	Amount	Source
FZ-LLC registration	AED 3,500	Decision No. 3 of 2017, item 1
Annual licence for any 21.x segment	AED 15,000	Decision No. 1 of 2021, Article 14
Second segment (if added)	+AED 10,000 a year	Decision No. 1 of 2021, Article 10.1
Knowledge & Innovation Dirhams	AED 20 per transaction	Decision No. 3 of 2017, notes
Minimum paid-up capital	AED 10,000	Decision No. 1 of 2021, Article 15
Executive search guarantee (if segment 21.12)	AED 100,000 deposit or bank guarantee	Decision No. 1 of 2021, Article 3.7
KHDA Authorisation (training segments 21.1–21.7)	AED 15,000 – 25,000 by number of activities	KHDA service page
Establishment card (GDRFA)	AED 200 issuance + AED 50 service fee + AED 20 Knowledge & Innovation; renewal AED 100 a year	GDRFA Dubai
Freelancer permit (alternative)	AED 7,500 a year	Decision No. 1 of 2021, Article 9.2

A checkable detail confirming that the sources reconcile: DKP publishes its freelance package at AED 7,520, which is exactly the AED 7,500 set by Article 9.2 plus AED 20 in Knowledge & Innovation Dirhams. The tariff and the regulation agree precisely.

What DDA does not publish, and it should be said plainly: any name reservation fee and any separate initial approval fee. Neither appears in Decision No. 3 of 2017, on the service pages, or in the Licensing Regulations 2003. The late renewal penalty, by contrast, is published: paragraph 1 of Schedule 4 to Decision No. 1 of 2021 sets it at AED 2,500, AED 5,000 or AED 10,000 depending on how long the delay runs.

A discrepancy on DDA’s own page that should not be taken as a tariff: the “add activity” service page states the fee as “AED 500.00 per additional location”, which duplicates the add-location fee and does not match Articles 10 and 14 of Decision No. 1 of 2021. It reads as a content error on the page and cannot be relied on.

The freelancer permit: Article 9

Article 9 of Decision No. 1 of 2021 in full: “9.1 Issuance of permits under the Freelancer Segments (Segment 16.5, Segment 18.9, Segment 21.13 and Segment 25.10) will only be to individuals on a sole practitioner basis. 9.2 The fee for a Freelancer permit is AED7,500 per annum. 9.3 A Freelancer is not an employee for the purposes of the Employment Regulations.”

There are four freelancer segments, each tied to a district: 16.5 for Dubai Internet City, 18.9 for Dubai Media City, 21.13 for Dubai Knowledge Park, and 25.10 for Dubai Design District. Only segment 21.13 is relevant to the training and personnel field.

On the district’s own publication, the “Education (Dubai Knowledge Park)” GoFreelance category covers: education advising, e-learning advisory, executive coaching, research and training. That is the only published answer to whether coaching is licensable in DKP: yes, at freelancer-permit level. DDA publishes no company-level segment called “Coaching”.

Clause 9.3 has a practical consequence: a freelancer is not an employee for the purposes of the Employment Regulations, so the sponsorship rules and the associated employment fines in Decision No. 3 of 2008 do not apply to one.

Premises, Visa Quota and Registration Timelines in DKP

The visa quota in Dubai Knowledge Park is tied to the area of the leased premises: one employee visa per 80 square feet of leased space. That is the district’s own answer, verbatim, to the question of whether there is a limit on employees per company.

Eighty square feet is approximately 7.43 square metres per visa. The rule is published by the district rather than set by a DDA decision, so it is properly described as an operational rule rather than a regulation: no corresponding instrument is in the public domain.

The federal portal u.ae corroborates this indirectly, stating that the number of visas depends on “the package they have signed up for” and directing enquirers to the relevant free zone authority for details. The quota is contractual, not regulatory.

The premises product line

Product	What it is	Visa quota
Open Quarters (D/Quarters)	Shared desks	1 work permit
Desk Quarters (D/Quarters)	A private desk reserved for the user	2 permits
Office Quarters (D/Quarters)	A fully furnished private office	2 or more permits
Hot Desk at the Business Centre	A single desk in a shared office environment	1 visa per freelancer
Commercial Spaces	Fully serviced suites or a flexible office to let	Per the 80 sq ft rule
Built-to-Suit	A standalone building to the client’s specification	Per the 80 sq ft rule
Retail & Restaurant Spaces, Land	Retail and land products	Not relevant to this article’s profile

Neither DKP nor TECOM publishes a rent per square foot for Dubai Knowledge Park. The district’s FAQ says only that pricing is “designed to be competitive and in alignment with prevailing market rates”. Any specific “AED x per sq ft for DKP” figure circulating online comes from sources this article does not use and is confirmed neither by the district nor by the operator.

The only confirmed rates are market-wide rather than DKP-specific: TECOM Group’s FY2025 integrated report gives a Dubai average office rate of AED 205 per square foot, up roughly 20% year on year. That is market context, not a DKP rent, and the two must not be substituted for one another.

TECOM’s FY2025 group figures, as at 31 December 2025: 12,200+ customers, 147,000+ professionals, 97% overall occupancy; commercial gross leasable area of 10.9 million sq ft at 95% occupancy. The report contains no breakdown for DKP or DIAC.

More recent figures come from the first half of 2026, published on 30 July 2026: revenue up 11% to more than AED 1.5 billion, recurring net profit up 9% to AED 805 million, EBITDA above AED 1.2 billion at a 79% margin, 61 new licences issued, and an interim dividend of AED 440 million. Occupancy as at 30 June 2026 was 97% overall — 96% commercial with 94% tenant retention, and 98% industrial with 99% retention. The half-year reporting discloses neither a customer count, nor a professionals count, nor gross leasable area.

A trap worth flagging, because almost every survey falls into it: the group’s own websites publish the “professionals” figure in three different vintages at once. The homepage, the About Us page and the investor relations page carry the current 147,000+ (FY2025); the business districts page pairs the current 12,200+ customers with a stale 137,000+ professionals (FY2024); and the district’s own site, dkp.ae, still carries an earlier pair, “over 11,800 customers and more than 124,000 professionals” (FY2023). The year-on-year progression runs: 31 December 2023 — 11,000+ customers, 124,000+ professionals, 89% occupancy; 31 December 2024 — 11,900 customers, 137,000 professionals, 94%; 31 December 2025 — 12,200+ and 147,000+, 97%.

The methodological point repeats what is visible at the level of the instruments: a publisher’s own index or shop window is not a source, even when the publisher is the group itself. Rely on the integrated report and the results releases, not on district marketing pages.

A separate administrative detail: DDA’s customer service centres are physically located at Dubai Studio City and Dubai Knowledge Park. DKP is one of only two walk-in counters for the whole DDA free zone.

Registration timelines: two official versions that do not reconcile

Stage	Per DDA’s service pages	Per the Dubai Knowledge Park FAQ
First phase	Provisional approval — 10 working days	Initial application approval — 4 working days
Second phase	Registration — 2 working days	Licence issuance — 3 working days
Total	12 working days	7 working days

Both figures are published officially by the same free zone and do not agree with one another. This article gives both and does not choose: for planning purposes the longer figure is the prudent assumption.

Other confirmed DDA timelines: add an activity — 2 working days; add a segment — 7 working days; change of company name — 4 working days; commercial and freelancer licence renewal — “immediate”; request for extract — “immediate”.

Licences are valid for one year and renewed annually.

Documents for registering an FZ-LLC with a natural person shareholder

DDA lists: the application form; valid passport copies of the natural member or members, the director or directors and the general manager, with the residence visa page where applicable; a resolution for the incorporation of an FZ-LLC; a declaration of appointment as general manager (applicable where the appointee holds a valid visa); and a power of attorney for a legal representative or negotiator where used, with a passport copy. The power of attorney must be notarised and attested up to the level of the UAE Embassy.

Neither a name reservation stage nor an immigration file (e-channel) stage appears in DDA’s published process.The establishment card is a GDRFA product obtained after licensing, and DDA does not publish it as one of its own services.

How hiring into a DKP entity works

Employees of free zone companies are sponsored by the zone authority, not by the employer. Regulation 4.1 of the Employment Regulations 2004: the authority may sponsor employees who are to be engaged by licensees to work for those licensees in the zone. The u.ae portal states the same: free zone employees are sponsored by the respective free zone authority and not by their employer.

Regulation 5.1 requires the licensee to lodge with the authority’s administration department a bank guarantee for each non-UAE-national employee, or for the anticipated total headcount. This is a freestanding requirement, distinct from the AED 100,000 executive search guarantee.

Regulation 14.5 requires every employee to sign an employment contract complying with the minimums of UAE labour law. Regulation 8.8 entitles the authority to charge a licensee for any passes, permits and visas, at the administration department’s own schedule.

DDA does not publish a visa or establishment card tariff. Regulation 8.8 delegates it to an internal administration-department schedule, and GDRFA’s service catalogue displays no amounts at catalogue level. For that reason this article does not state a cost for a DKP employee visa: every figure in circulation comes from sources inadmissible under the editorial standard applied here.

What can be stated with confidence: MOHRE work permits are not used inside the DDA zone, personnel administration runs through the zone authority, and the substantive employment law nonetheless remains federal.

Which employment law applies to a DKP company’s staff

The substantive employment law for a DKP company is Federal Decree-Law No. 33 of 2021, not an autonomous free zone code. DDA’s own standard employment terms define “Labour Law” precisely as Federal Decree-Law No. 33 of 2021, subject the contract to the laws of the UAE, give the Dubai Courts exclusive jurisdiction over disputes, and calculate end-of-service gratuity under the federal scheme.

There is an internal inconsistency in the corpus DDA publishes, and it should be shown: DDA still publishes the Employment Regulations 2004, which reference the repealed Federal Law No. 8 of 1980 and make no mention of the 2021 Decree-Law. The 2004 regulations were always subordinate to federal law rather than a substitute for it: they require compliance with UAE labour law and provide that working conditions must at minimum meet it. Their federal cross-references are nonetheless stale, and they have not been formally withdrawn.

The accurate formulation for DKP: DDA administers permits, sponsorship and contract registration; Federal Decree-Law No. 33 of 2021 supplies the substantive floor; the forum is the Dubai Courts. The free zones with genuinely autonomous employment law are DIFC and ADGM, not DDA.

Emiratisation: does it reach a DKP company?

The Emiratisation targets apply to employers registered with MOHRE that employ 50 or more workers. The mechanism is Ministerial Resolution No. 279 of 2022, issued 6 June 2022: an annual 2% increase in the Emirati share of skilled roles, reaching 10% by 2026. Ministerial Resolution No. 455 of 2023 extended the targets to establishments with 20 to 49 employees in selected economic activities.

A DKP company is not registered with MOHRE: its employees are sponsored by, and contracted through, the free zone authority. It follows that the Emiratisation targets do not reach it.

Quotas, penalties, Nafis and the half-year deadlines for those employers the regime does reach are covered separately: Emiratisation in 2026.

The exclusion is structural rather than express, and that caveat matters. No instrument located says “free zones are exempt”. The exemption follows from the MOHRE-registration precondition — an administrative gate that could be closed by resolution without any change to primary legislation.

The penalties instrument has been replaced and the old one must not be cited: Cabinet Resolution No. 43 of 2025, issued 16 April 2025 and in force 30 April 2025, by its Article 7 repealed Cabinet Resolution No. 95 of 2022 as amended, which carries away Cabinet Resolution No. 44 of 2023 with it. Under Cabinet Resolution No. 43 of 2025, sham Emiratisation attracts a fine of AED 20,000 to AED 100,000 per worker, and circumventing the targets attracts AED 100,000 for a first offence, AED 300,000 for a second and AED 500,000 for a third.

The monthly contribution per unfilled post for 2026 could not be confirmed from a primary source. The figure reported by MOHRE in June 2026 was AED 10,000 a month, that is AED 120,000 a year for each unfilled Emirati post, with the first half-year deadline on 30 June 2026. The text of Ministerial Resolution No. 279 of 2022 could not be obtained in the public domain, so that figure is given as reported rather than as confirmed against the primary text. For a DKP company the question is contextual in any event.

Corporate Tax: Why QFZP Status Is Practically Out of Reach for a Training Company

A Dubai Knowledge Park company is legally capable of being a Qualifying Free Zone Person, but its core activity does not appear in the list of Qualifying Activities, so the zero rate on income from mainland and overseas clients is unattainable. This is the central tax finding of the article, and it cuts against the common understanding of free zones.

The five conditions in Article 18(1) of Federal Decree-Law No. 47 of 2022

Article 18(1) reads: “A Qualifying Free Zone Person is a Free Zone Person that meets all of the following conditions: a. Maintains adequate substance in the State. b. Derives Qualifying Income as specified in a decision issued by the Cabinet at the suggestion of the Minister. c. Has not elected to be subject to Corporate Tax under Article 19 of this Decree-Law. d. Complies with Articles 34 and 55 of this Decree-Law. e. Meets any other conditions as may be prescribed by the Minister.”

Article 3(2) sets the rates: “Corporate Tax shall be imposed on a Qualifying Free Zone Person at the following rates: a. 0% (zero percent) on Qualifying Income. b. 9% (nine percent) on Taxable Income that is not Qualifying Income under Article 18.”

The amendment chain of Federal Decree-Law No. 47 of 2022:

Amending instrument	Date of issue	Entry into force
Federal Decree-Law No. 60 of 2023	2 October 2023	1 November 2023
Federal Decree-Law No. 40 of 2024	1 October 2024	1 June 2023 (retroactive)
Federal Decree-Law No. 28 of 2025	1 October 2025	15 October 2025

The substance of the regime sits in two subordinate instruments. Cabinet Decision No. 100 of 2023 on determining Qualifying Income was issued 25 October 2023, is effective from 1 June 2023, and its Article 10 repeals Cabinet Decision No. 55 of 2023. Ministerial Decision No. 229 of 2025 on Qualifying Activities and Excluded Activities was issued 28 August 2025, took effect from 1 June 2023 retroactively, and its Article 6 repeals Ministerial Decision No. 265 of 2023.

Decisions No. 55 of 2023 and No. 265 of 2023 are repealed and cannot be cited.

Qualifying Activities: Article 2(1) of Ministerial Decision No. 229 of 2025

Paragraph	Activity
a	Manufacturing of goods or materials
b	Processing of goods or materials
c	Trading of Qualifying Commodities
d	Holding of shares and other securities for investment purposes
e	Ownership, management and operation of Ships
f	Reinsurance services
g	Fund management services
h	Wealth and investment management services
i	Headquarter services to Related Parties
j	Treasury and financing services to Related Parties or for its own account
k	Financing and leasing of Aircrafts
l	Distribution of goods or materials in or from a Designated Zone
m	Logistics services
n	Activities ancillary to those specified in paragraphs (a) to (m)

Training, education, HR consultancy and recruitment do not appear anywhere in that list. A targeted search of Ministerial Decision No. 229 of 2025 finds the words “training”, “education”, “consultancy”, “recruitment” and “human resources” in none of the paragraphs. The only cognate term, “advisory”, appears solely in the definitions of financialactivities, attached to fund management and wealth management.

The Excluded Activities sit in Article 2(2), not in Article 3 as they are sometimes cited: (a) transactions with natural persons, except transactions relating to certain Qualifying Activities; (b) banking activities; (c) insurance activities with stated exceptions; (d) finance and leasing activities with stated exceptions; (e) ownership or exploitation of immovable property, other than commercial property in a free zone where the transaction is with a Free Zone Person; (f) activities ancillary to those in paragraphs (a) to (e). Article 3 is the de minimis article, not the Excluded Activities article.

The ancillary escape hatch does not help. Article 2(3) provides that an activity is ancillary where it is necessary for the performance of the main activity, or where it makes a minor contribution to it and is so closely related to it that it should not be regarded as a separate activity. For a company whose main activity is training or HR consultancy there is no Qualifying Activity for that work to be ancillary to. Ancillarity runs downward from a Qualifying Activity; it cannot manufacture one.

The point that reverses the picture: the counterparty matters

Article 3(1) of Cabinet Decision No. 100 of 2023 lists four sources of Qualifying Income:

Paragraph	Source
(a)	Income derived from transactions with a Free Zone Person, except income derived from Excluded Activities
(b)	Income derived from transactions with a Non-Free Zone Person, but only in respect of Qualifying Activities that are not Excluded Activities
(c)	Income from the ownership or exploitation of Qualifying Intellectual Property under Article 7(1)
(d)	Any other income provided the de minimis requirements under Article 4 are satisfied

Paragraph (a) is not confined to Qualifying Activities — it excludes only Excluded Activities. The Qualifying Activity filter bites solely in paragraph (b). Two different answers follow for one and the same service:

Training, HR consultancy or executive search supplied to another Free Zone Person that is the Beneficial Recipient is Qualifying Income under paragraph (a), taxed at zero per cent, even though training is not a Qualifying Activity.

The same services supplied to a mainland client, an overseas client or a natural person are not Qualifying Income.They fall under paragraph (b), which admits only Qualifying Activities, and become non-qualifying Revenue.

A Beneficial Recipient is defined in Article 3(3) as a person who has the right to use and enjoy the service or the good and does not have a contractual or legal obligation to supply it to another person. For training and executive search this is acute: if the contract is with a free zone entity but the training is in fact delivered to a mainland group affiliate, or the candidate is placed into one, the Beneficial Recipient is the mainland entity and the income drops out of paragraph (a).

The de minimis threshold and the five-period cliff

Article 3 of Ministerial Decision No. 229 of 2025 provides that the de minimis requirements are satisfied where the non-qualifying Revenue of a Qualifying Free Zone Person in a Tax Period does not exceed 5% of that person’s total Revenue in that period or AED 5,000,000, whichever is lower.

Article 5(1) adds two further conditions to the five in Article 18(1): non-qualifying Revenue must not exceed the de minimis, and the person must prepare audited financial statements in accordance with Ministerial Decision No. 84 of 2025.

Article 5(2) reads: a Qualifying Free Zone Person that at any particular time during a Tax Period fails to meet any of the conditions in Article 18(1) of the Corporate Tax Law and this Decision, and any other conditions prescribed by the Minister, shall cease to be a Qualifying Free Zone Person from the beginning of the relevant Tax Period and for the subsequent four Tax Periods.

The point most often stated wrongly: on a de minimis breach, nine per cent applies not to the excess but to the whole of taxable income, and not for one year but for five. This is not a marginal effect but a total cliff.

Correspondingly, where de minimis is respected the logic runs the other way: all income including the non-qualifying revenue is taxed at zero, because that revenue lands in paragraph (d) of Article 3(1) of Decision No. 100 of 2023 — “any other income provided the de minimis requirements are satisfied”.

What this means for a DKP training company in figures

For a DKP company with a normal client base — corporates in mainland Dubai, regional clients abroad — non-qualifying revenue is effectively 100% of turnover, not 5%. The 5% or AED 5,000,000 threshold is a tolerance for incidental leakage, not a business model.

The practical conclusion: Qualifying Free Zone Person status is, for the overwhelming majority of DKP HR consultancies and training providers, unattainable in substance. The realistic position is nine per cent on taxable income above the AED 375,000 nil band under Article 3(1) of Federal Decree-Law No. 47 of 2022, or Small Business Relief.

The only scenario in which QFZP has practical value is a company whose client base consists predominantly of free zone residents that are the Beneficial Recipients. For corporate training that client profile is rare, and it requires documentary support transaction by transaction.

The conditions of the QFZP regime and how it applies across business profiles are covered separately: the Qualifying Free Zone Person regime in 2026.

Small Business Relief and the Domestic PE: Two Mechanisms That Serve DKP Better Than QFZP

Small Business Relief exempts a company with revenue up to AED 3,000,000 in a Tax Period from corporate tax, and for a typical DKP training or HR company it is a more workable answer than QFZP status.

Small Business Relief: conditions and duration

The mechanism is set by Ministerial Decision No. 73 of 2023, issued 3 April 2023 and in force fifteen days after publication.

The threshold in Article 2(1) is AED 3,000,000 for each Tax Period. The test runs on revenue, not profit, so a comfortably profitable consultancy can stay within the regime.

Article 2(3) carries an irreversibility rule: the relief is lost for all later periods once revenue has exceeded the threshold in the relevant or any previous Tax Period. Cross it once and there is no way back in.

Article 3 excludes two categories: a constituent company of a Multinational Enterprises Group as defined in Cabinet Decision No. 44 of 2020, and a Qualifying Free Zone Person. Small Business Relief and QFZP are mutually exclusive — this is a genuine election, not a combination.

Ministerial Decision No. 131 of 2026, issued 29 July 2026 and in force the day after publication, replaced Article 2(2) of Ministerial Decision No. 73 of 2023. The new wording: the threshold applies to Tax Periods commencing on or after 1 June 2023 and continues to apply to subsequent Tax Periods ending on or before 31 December 2029. The previous end date of 31 December 2026 has been replaced by 2029.

The practical consequence: the Small Business Relief planning horizon has been extended by three years and now covers Tax Periods through to the end of 2029.

Why this beats QFZP for DKP

Parameter	Qualifying Free Zone Person	Small Business Relief
Availability to a DKP training or HR company	Practically unattainable — training and HR consultancy are not Qualifying Activities and the clients are typically mainland and overseas	Available where revenue is up to AED 3,000,000
Basis of the test	The share of non-qualifying revenue	Revenue in total, regardless of profit
Outcome	0% on Qualifying Income, 9% on the rest	The person is treated as having derived no Taxable Income for the period
Transfer pricing documentation	Required — Article 55 is among the Article 18(1) conditions	Not required — Article 21(2)(e) disapplies Article 55
Audited financial statements	Mandatory under Article 5(1)(b) of Ministerial Decision No. 229 of 2025	The regime imposes no such requirement
Cost of getting it wrong	Loss of status for the current and four subsequent Tax Periods	Loss of the relief prospectively, with no retrospective effect
Restrictions	—	Losses of a relief period cannot be carried forward (Article 4); net interest expenditure of a relief period cannot be carried forward (Article 5)

Article 21 of Federal Decree-Law No. 47 of 2022 frames the relief as a right to elect: a person may elect to be treated as not having derived any Taxable Income for a Tax Period where revenue is below the threshold set by the Minister. Clause 2(e) of that Article disapplies Article 55, and with it the transfer pricing documentation obligation.

The restrictions in Articles 4 and 5 of Ministerial Decision No. 73 of 2023 mean little to a services firm: a profitable, low-leverage consultancy forgoes almost nothing by being unable to carry forward losses and net interest expenditure from a relief period.

Article 6 contains an anti-avoidance rule against artificially separating a business to keep revenue below AED 3,000,000. Splitting a training company into several entities to sit under the threshold is precisely what that provision targets.

The election mechanics: the right to elect is conferred by Article 21, but neither Ministerial Decision No. 73 of 2023 nor Article 21 itself specifies the procedural vehicle. In practice it is made in the tax return for the relevant period and is annual rather than once and for all; this article states that as practice rather than as a rule, and recommends confirming the procedure against the FTA’s current guidance before filing. Registration for corporate tax and filing the return remain mandatory: Small Business Relief removes the tax, not the compliance.

Mainland access and the Domestic Permanent Establishment

Executive Council Resolution No. 11 of 2025, issued 3 March 2025 and in force from publication, regulates the conduct by free zone establishments of activities outside the free zones within the Emirate of Dubai.

Article 4 provides three routes through the Department of Economy and Tourism: a licence to establish a branch of the establishment within the Emirate; a licence to establish a branch of the establishment operating out of the free zone; or a permit to conduct specific activities within the Emirate. Branch licences are valid for one year and renewable for the same period; permits for specific activities are capped at six months.

Article 3(b)(2) requires separate financial records for activities conducted outside the free zone and those conducted within it. Article 8 allows an establishment to engage its existing workforce registered on the free zone portal and to continue to benefit from all free zone employment privileges. Article 2 excludes financial establishments licensed by the DIFC.

Article 13 gave existing establishments one year to comply, extendable once by the Director General for an equal period. The base one-year period expired in March 2026 — before the date of this publication — and no public information confirms whether the extension was exercised. Companies operating on the mainland without authorisation should assume the transitional window has closed.

The tax outcome of a mainland presence, which is not the one usually expected

Cabinet Decision No. 100 of 2023 defines a Domestic Permanent Establishment as “a place of Business or other form of presence of a Qualifying Free Zone Person outside the Free Zone in the State”.

Article 5(1): income attributable to a Domestic Permanent Establishment or a Foreign Permanent Establishment is Taxable Income and is taxed under paragraph (b) of Article 3(2) of the Corporate Tax Law — that is, at 9%.Article 5(2) requires it to be computed as if the establishment were a separate and independent person that is a Related Party of the Qualifying Free Zone Person.

The key mechanical point, and it runs against intuition: revenue attributable to a Domestic Permanent Establishment is not non-qualifying revenue and does not consume the de minimis headroom — it is excluded from the de minimis calculation altogether. On the FTA’s own illustration, where a Free Zone Person derives revenue of AED 10,000,000 of which AED 2,000,000 is attributable to a Domestic Permanent Establishment, total revenue for de minimis purposes is AED 8,000,000.

From which follows a planning conclusion worth stating separately: formalising mainland delivery through a DET branch or permit protects QFZP status rather than destroying it. The dangerous configuration is the opposite — a DKP company servicing mainland clients without DET authorisation and without recognising a Domestic Permanent Establishment, booking that revenue in the free zone entity. That revenue becomes non-qualifying under paragraph (b) of Article 3(1) of Decision No. 100 of 2023, counts against de minimis, and on any realistic client mix breaches the threshold, forfeiting status for five Tax Periods.

The separate-records requirement in Article 3(b)(2) of Resolution No. 11 of 2025 and the separate-entity attribution required by Article 5(2) of Decision No. 100 of 2023 point the same way: here the licensing obligation and the tax mechanics coincide.

A caveat that removes unnecessary complexity: this analysis matters only to a DKP company with a QFZP position worth protecting. Most training and HR companies do not have one, and for them the Domestic PE question never arises — they simply pay nine per cent, or elect Small Business Relief.

VAT: Is Corporate Training Zero-Rated? No

Corporate training, executive coaching, HR consultancy and recruitment in the UAE are subject to VAT at the standard rate of 5%. The zero rate for educational services does not reach a commercial professional-development provider, and there is no exemption for education in the law at all.

The distinction between zero-rating and exemption matters here and has opposite consequences for input tax: education, where it qualifies, is zero-rated but never exempt. The exempt list in Article 46 of Federal Decree-Law No. 8 of 2017 covers financial services, residential buildings, bare land and local passenger transport — there is no education head in it.

The conditions for zero-rating: Article 45(13) of the law and Article 40 of the Regulation

Article 45(13) of Federal Decree-Law No. 8 of 2017 reads: “The supply of educational Services and related Goods and Services for nurseries, preschool, school education, and higher educational institutions owned or funded by Federal or local Government, as specified in the Executive Regulation of this Decree-Law.”

Article 40(1) of the Executive Regulation sets three conditions, and they are cumulative:

No.	Condition
(a)	The educational services are provided in accordance with a curriculum recognised by the federal or local competent government agency regulating the education sector where the course is delivered
(b)	The supplier is an educational institution recognised by the federal or local competent government agency regulating the education sector where the course is delivered
(c)	Where the supplier is a higher education institution, it must be owned by the federal or local government or receive more than 50% of its annual funding directly from it

Article 40(4) further carves out of zero-rating a range of supplies even within a recognised institution: uniforms, electronic devices, food and beverages, non-curriculum field trips and extracurricular activities. That shows how narrowly the relief is drawn even where it applies in principle.

A DKP company licensed for corporate training and professional development satisfies none of the three conditions: it offers proprietary commercial content rather than a curriculum recognised by an education regulator; it is licensed by DDA as a commercial free zone entity rather than recognised by KHDA or the Ministry of Education as an educational institution; and it is privately funded.

The practical consequence: a DKP training company registers for VAT on ordinary principles and charges 5% on all of its services. The other side of that is favourable: because the supplies are taxable rather than exempt, input tax on rent, equipment and services is fully recoverable — which it would not be under an exemption.

Registration thresholds: mandatory at AED 375,000, voluntary at AED 187,500. The amounts are set in the Executive Regulation, to which Articles 13 and 17 of the Decree-Law refer out.

Designated Zones: why the question is beside the point for DKP

Dubai Knowledge Park is not on the list of Designated Zones for VAT purposes. The FTA’s current list rests on Cabinet Decision No. 59 of 2017 as amended by Decisions No. 35 of 2018, No. 43 of 2019, No. 34 of 2021, No. 63 of 2021 and No. 81 of 2021. For Dubai it names: Jebel Ali Free Zone (North-South), Dubai Cars and Automotive Zone (DUCAMZ), Dubai Textile City, the Free Zone Area in Al Quoz, the Free Zone Area in Al Qusais, Dubai Aviation City, Dubai Airport Free Zone, International Humanitarian City – Jebel Ali, and Dubai CommerCity.

Neither Dubai Knowledge Park nor the Dubai Development Authority, nor Dubai Internet City, Media City, Studio City, Production City, International Academic City, Design District or TECOM appears on the list.

But the stronger point is this: even if DKP were on the list it would change nothing for a training or HR business, because the Designated Zone fiction applies only to goods. Article 51(6) of the Executive Regulation: the place of supply of any services is considered to be inside the State if the place of supply is in a Designated Zone. The FTA’s Designated Zones guide says the same: services in a Designated Zone are taxed under the general VAT rules for such services.

For DKP’s profile the Designated Zone question is a red herring, and it deserves to be answered as one.

A distinction to keep separate and never conflate: the VAT Designated Zones list and the Free Zone concept for corporate tax are two different regimes with different lists and different consequences. DKP’s absence from the Designated Zones list does not affect its capacity to be a Free Zone for corporate tax; Designated Zone status confers no zero rate for corporate tax. The single point of intersection is paragraph (l) of Article 2(1) of Ministerial Decision No. 229 of 2025, which makes distribution in or from a Designated Zone a Qualifying Activity — and it does not reach DKP.

The VAT amendment chains

Federal Decree-Law No. 8 of 2017 on VAT has been amended three times:

Amending instrument	Date of issue	Entry into force
Federal Decree-Law No. 18 of 2022	26 September 2022	1 January 2023
Federal Decree-Law No. 16 of 2024	30 September 2024	30 October 2024
Federal Decree-Law No. 16 of 2025	1 October 2025	1 January 2026

Federal Decree-Law No. 16 of 2024 is missing from most published chains, though it is in force.

Federal Decree-Law No. 16 of 2025 inserted Article 54 bis, effective 1 January 2026: “The Authority shall reject the deduction of the Recoverable Input Tax if it is established to the Authority that the supply subject to the deduction was part of a supply or a chain of supplies related to Tax Evasion, and the Taxable Person was aware of this relation upon deducting the Recoverable Input Tax.”

The Executive Regulation — Cabinet Decision No. 52 of 2017 — has been amended by Decisions No. 46 of 2020 (4 June 2020), No. 24 of 2021 (11 March 2021), No. 88 of 2021 (28 September 2021), No. 99 of 2022 (21 October 2022), No. 100 of 2024 (6 September 2024) and No. 100 of 2025 (12 August 2025).

A caveat that prevents a standard error: both Cabinet Decision No. 100 of 2024 and Cabinet Decision No. 100 of 2025 amend the same regulation. They are easy to transpose, and the consequences differ.

A general account of UAE VAT, covering registration, rates and reporting, is set out separately: UAE VAT — the complete business guide.

E-Invoicing, UBO, AML and ESR: What a DKP Company Must Actually Do

A DKP company is within the perimeter of mandatory UAE e-invoicing and must confirm its beneficial ownership data, but it is not a DNFBP under the anti-money-laundering law and has filed no economic substance report since 2023.

E-invoicing: the deadlines for a DKP company

The regime is set by Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System and Ministerial Decision No. 244 of 2025 on its implementation; instrument No. 66 of 2026 amended the implementation timetable.

A note on the last instrument’s style: the Ministry of Finance lists it in its register as Ministerial Resolution No. 66 of 2026, while the header of the PDF itself reads Ministerial Decision No. 66 of 2026. The Ministry uses “Decision” and “Resolution” interchangeably in its English publications; the safer citation is by number, year and title rather than by instrument type.

Article 3 of Decision No. 243 of 2025 applies the system to any person conducting business in the State in respect of every business transaction. Article 4 contains no free zone exclusion, and the exclusions it does contain — sovereign government activity, international airline services, exempt and zero-rated financial services — do not reach a DKP company.

Article 5(1): the issuer and the recipient, as applicable, shall appoint an Accredited Service Provider.

Category	Appoint an Accredited Service Provider	Begin issuing e-invoices
Revenue AED 50,000,000 and above	30 October 2026 (moved from 31 July 2026 by Decision No. 66 of 2026)	1 January 2027 — unchanged
Revenue below AED 50,000,000	31 March 2027	1 July 2027
Government entities	31 March 2027	1 October 2027

Business-to-consumer transactions are outside the system for now: they are not subject to the Electronic Invoicing System until the Minister determines otherwise. That matters to a training provider selling open-enrolment courses to individuals.

What a mid-sized DKP company must do: appoint an Accredited Service Provider from the Ministry of Finance register no later than 31 March 2027, and from 1 July 2027 issue and receive all B2B and B2G invoices through the Peppol-based system. The real work falls in 2026: billing-system readiness, master-data cleanup (client tax registration numbers, standardised item descriptions for training, consultancy and placement fees) and provider selection. A company approaching the AED 50,000,000 threshold should assume the earlier band applies: crossing it pulls the deadlines forward by a year.

A related instrument for completeness: Ministerial Resolution No. 56 of 2026 amended Ministerial Resolution No. 64 of 2025 on the accreditation criteria for service providers.

Beneficial ownership

The instrument in force is Cabinet Decision No. 109 of 2023 Regulating the Real Beneficiary Procedures, issued 6 November 2023 and in force the day after publication.

Article 22 reads: “The Cabinet Resolution No. (58) of 2020 regulating Real Beneficiary Procedures shall be cancelled.” Resolution No. 58 of 2020 cannot be cited.

The threshold is 25%: a real beneficiary is the natural person who owns or ultimately controls a legal person through direct or indirect ownership of twenty-five per cent or more of that legal person’s capital, with fallback tests of control by other means and, failing those, the identification of a senior management official.

Deadlines: the real beneficiary register must be established and maintained within 60 days and updated within 15 days of a change coming to knowledge (Article 8); the partners and shareholders register is updated within 15 days (Article 10).

Article 3(2) excludes the financial free zones — DIFC and ADGM — and entities wholly owned by federal or local government. Commercial free zones, including DDA and DKP, are within the regime.

DDA Circular 670 of 3 June 2026 sets out the mechanics through the AXS portal: New Request → Company Services → UBO Submission. Licensees must review and confirm existing UBO information in the AXS portal; complete any missing ownership details; upload supporting documents where applicable; and confirm the ownership structure for individual and corporate shareholders.

The circular states no filing deadline and prescribes no penalty. The leverage is interruption of service — licence renewal and portal transactions — rather than a monetary sanction. It is a compliance obligation with a soft trigger, which is precisely why it is routinely deferred.

Anti-money laundering: a DKP company is not a DNFBP

Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing was issued 30 September 2025 and came into force 14 October 2025. Its Article 41 repeals Federal Decree-Law No. 20 of 2018; Article 42 provides for entry into force two weeks after publication.

Federal Decree-Law No. 20 of 2018 and its earlier amendments cannot be cited as law in force.

The executive regulation is Cabinet Resolution No. 134 of 2025. Its Article 3 specifies the DNFBP categories: commercial gaming operators (a single transaction above AED 11,000); real estate brokers and agents; dealers in precious metals and stones (a single cash transaction above AED 55,000); lawyers, notaries, other independent legal professionals and independent accountants for specified transactions; company and trust service providers for specified activities; and any further business determined by resolution of a Supervisory Authority.

HR consultancy, executive search, corporate training and professional development appear nowhere in Article 3. A DKP company with that profile is not a DNFBP, does not register on goAML, and carries no customer due diligence or suspicious transaction reporting obligations of its own.

Two caveats to keep in view. First, the residual limb allows a Supervisory Authority to designate further businesses by resolution, so the position is not permanently fixed. Second, and practically more significant: if the licence extends into corporate services, nominee work, or trust or company administration, the “company and trust service provider” head bites and the whole DNFBP regime engages. For an executive search firm this is a live risk wherever the mandate shades into corporate structuring.

Economic substance: reporting has been cancelled

Cabinet Decision No. 98 of 2024, amending Cabinet Decision No. 57 of 2020, cancelled economic substance reporting for financial years ending after 31 December 2022. In the Ministry of Finance’s own words, companies are no longer required to submit economic substance notifications or reports for those financial years.

Residual obligations survive and are worth accounting for: compliance for prior periods ending on or before 31 December 2022; responses to information or amendment requests from regulatory authorities and the Federal Tax Authority; and payment of penalties already imposed. A DKP company incorporated before 2023 may carry historic ESR exposure despite filing nothing prospectively.

Corporate tax registration and filing

Registration timelines are set by FTA Decision No. 3 of 2024, issued 22 February 2024 and in force 1 March 2024.For resident juridical persons incorporated before 1 March 2024 the deadline was determined by the month of licence issuance irrespective of the year; for those incorporated on or after 1 March 2024 it is three months from incorporation.

A trap worth stepping around expressly: FTA Decision No. 12 of 2026, issued 16 July 2026, concerns registration and deregistration for Top-Up Tax under Cabinet Decision No. 142 of 2024 and neither repeals nor touches Decision No. 3 of 2024. Its title invites misreading, and it must not be substituted for the corporate tax registration instrument.

The return is filed and corporate tax paid no later than nine months from the end of the relevant Tax Period. For a DKP company on a calendar financial year, the FY2025 return and payment fall due on 30 September 2026.

The penalty for late registration is AED 10,000. The instrument is Cabinet Decision No. 75 of 2023 on administrative penalties as amended by Cabinet Decision No. 10 of 2024, which introduced this violation with effect from 1 March 2024. A citation to Decision No. 75 of 2023 alone, without the amendment, is incomplete.

Adjacent penalties from the same table: late filing of a return — AED 500 per month or part month for the first twelve months and AED 1,000 per month from the thirteenth; late payment — 14% per annum, applied monthly, on unsettled payable tax.

The FTA’s initiative waiving the late-registration penalty remains open as at its most recent published update of 14 May 2026, and no closing date has been announced. The condition: the taxable person files its tax return or annual declaration within seven months of the end of its first Tax Period rather than the usual nine; a penalty already paid is refunded as a credit to the tax account. This article states the position as at 14 May 2026 rather than asserting it on the date of publication.

Corporate tax rates, the QFZP regime and Small Business Relief are covered in general terms separately: UAE corporate tax in 2026.

Comparison: DKP Against the Alternatives for an HR and Training Business

The choice between DKP, DIAC, Dubai Outsource City and a mainland DET licence is driven not by licence cost but by three things: the client mix, the nature of the activity, and whether a sector regulator sits above it.

Parameter	Dubai Knowledge Park	Dubai International Academic City	Dubai Outsource City	Mainland Dubai (DET)
Licensing regulator	DDA	DDA	DDA	Department of Economy and Tourism
Training and professional development	Yes, segments 21.1–21.7	Educational support (22.3) and schools (22.4) only	No	Yes, under DET categories
Conferring degrees	No	Yes, segment 22.1	No	Through federal licensure
HR consultancy	Yes, segment 21.8, no external approvals	No	No	Yes
Executive search	Yes, segment 21.12 + AED 100,000 guarantee	No	No	Yes, with a MOHRE mediation licence
Manpower supply	No	No	Yes, activity 17.1.8, only with a live DED licence and only within the free zone	Yes, with a MOHRE temporary employment licence
KHDA requirement	NOC before licence issuance for 21.1–21.7	Academic Authorization for 22.1	Not applicable	KHDA Authorisation under ECR No. 50 of 2015
Minimum FZ-LLC capital	AED 10,000	AED 50,000	AED 300,000 (Outsource)	Per DET category
Annual licence	AED 15,000	AED 15,000	By segment	Per DET category
Working with mainland clients	Through the routes in ECR No. 11 of 2025	Through the same routes	Through the same routes	Without restriction
Corporate tax rate on training for a mainland client	9% — not a Qualifying Activity	9%	9%	9%
Rate on a service to a Free Zone Person that is the Beneficial Recipient	0% with QFZP status	0% with QFZP status	0% with QFZP status	9% — the mainland is not a Free Zone Person
VAT Designated Zone status	No	No	No	No

Three conclusions follow.

First: the only substantive tax advantage a free zone offers this profile arises on work for free zone residents that are the Beneficial Recipients. Serving mainland clients, a DKP company pays the same nine per cent as a mainland one — while carrying a restriction on where it may operate and the cost of formalising mainland access.

Second: DKP’s greatest practical value here is not tax but sector infrastructure and the bare ability to license the activity. HR consultancy in segment 21.8 requires no NOC, no guarantee and no sector regulator — a cleaner route than the mainland one.

Third: if the model involves supplying personnel to a client, DKP falls away at the first step and the question moves to DOC plus a mainland DED licence, or to a mainland MOHRE licence. This is not an optimisation but an incompatibility: the activity does not exist in DKP, and supplying one’s own sponsored employees to third parties is expressly fined under Decision No. 3 of 2008.

Comparison with the neighbouring TECOM districts

Within the TECOM group the choice of district is driven by the segment, not by the convenience of the address. A company running training alongside, say, software development will need to add a segment from another cluster under Article 11.1, which is at the Authority’s sole discretion and costs a further AED 10,000 a year under Article 10.1.

The profiles of the neighbouring TECOM districts are covered separately: Dubai Media City, Dubai Internet City, Dubai Design District (d3) and Dubai Science Park.

A Step-by-Step Algorithm: Opening and Running a DKP Company

Stage 1. Fix the perimeter — before applying

Step 1. Identify the segment under Part Six of Decision No. 1 of 2021. Training is 21.1 or 21.7; HR consultancy 21.8; executive search 21.12; assessment 21.11; e-learning and content 21.10; research 21.9. Coaching has no segment of its own at company level and sits under 21.1; at freelancer level it is expressly named in category 21.13.

Step 2. Check whether the segment triggers the KHDA NOC requirement. Segments 21.1 to 21.7 do; 21.8 to 21.12 do not.

Step 3. Check whether the activity is in substance manpower supply. If the model involves placing employees with a client, DKP is the wrong jurisdiction and the structure needs rebuilding.

Step 4. Assess the client mix for the tax outcome. The share of revenue from Free Zone Persons that are the Beneficial Recipients determines whether QFZP status is worth considering at all.

Step 5. Compare the revenue forecast against the AED 3,000,000 Small Business Relief threshold, remembering that crossing it once closes the regime permanently.

Stage 2. Obtain the permissions

Step 6. For training segments, apply to KHDA for Initial Approval with a feasibility study: vision, mission, staffing criteria, training activities, admission standards, quality systems and the list of programmes. Initial Approval is valid for no more than six months.

Step 7. File the FZ-LLC registration application through the AXS portal. The registration fee is AED 3,500 plus activity fees; minimum paid-up capital is AED 10,000. A power of attorney for a representative must be attested up to the level of the UAE Embassy.

Step 8. For segment 21.12, put the AED 100,000 deposit or bank guarantee in place before the licence is issued.

Step 9. Obtain the KHDA Authorisation (Educational Services Permit) once the commercial licence has issued. The fee under the operative tariff runs from AED 15,000 to AED 25,000 by number of activities, turnaround is 8 working days, and validity is one year.

Step 10. Sign the lease with the visa quota in mind: one visa per 80 square feet. The required area follows from planned headcount, not the other way round.

Stage 3. Start operating

Step 11. Obtain the establishment card from GDRFA (AED 200 issuance, AED 50 service fee, AED 100 annual renewal) and put employee sponsorship in place through the zone authority, including the bank guarantee under Regulation 5.1 of the Employment Regulations 2004.

Step 12. Register for corporate tax and fix the Tax Period; the return and payment fall due within nine months of its end.

Step 13. Test the AED 375,000 VAT registration threshold and register on reaching it, remembering that training is standard-rated at 5% and that input tax is recoverable.

Step 14. Confirm beneficial ownership data through the AXS portal in the manner set out in Circular 670 of 3 June 2026.

Step 15. Put e-invoicing preparation into the 2026 plan: select an Accredited Service Provider by 31 March 2027 where revenue is below AED 50,000,000, and begin issuing from 1 July 2027.

Step 16. When working on the mainland, formalise a route under Executive Council Resolution No. 11 of 2025 and keep separate financial records under Article 3(b)(2), while computing Domestic PE income on a separate-entity basis under Article 5(2) of Decision No. 100 of 2023.

Step 17. For training segments, submit every new course and every new programme to KHDA for approval (AED 100 and AED 2,500 respectively) and clear advertising before publication (AED 100).

Common Mistakes and What Each One Costs

Mistake 1. Assuming a DKP training licence replaces the KHDA Authorisation. Article 4 of Executive Council Resolution No. 50 of 2015 requires both permissions at once, and Article 5.5 of Decision No. 1 of 2021 makes the KHDA NOC a condition precedent to the DDA licence. The cost: the fine for operating without an Authorisation is AED 50,000, more than three times the AED 15,000 annual DDA licence; operating on an expired Authorisation costs AED 15,000 a month capped at AED 100,000, and KHDA may additionally suspend the activity and bar enrolment.

Mistake 2. Building a staffing model on a DKP licence. Manpower Supply is activity 17.1.8 in Dubai Outsource City, available only to organisations holding a live Department of Economic Development licence and only for supply within the free zone. The cost: supplying one’s own sponsored employees to third parties is fined under Decision No. 3 of 2008 at AED 5,000 per person with simultaneous visa cancellation. On a headcount of twenty that is AED 100,000 and the loss of the entire visa base at once — which stops operations.

Mistake 3. Expecting a zero corporate tax rate because the company sits in a free zone. Training, HR consultancy and recruitment do not appear in the list of Qualifying Activities in Article 2(1) of Ministerial Decision No. 229 of 2025. The cost: on an ordinary client mix, non-qualifying revenue approaches 100% of turnover, the de minimis threshold of 5% or AED 5,000,000 is breached in the first year, and under Article 5(2) the company loses its status from the beginning of the Tax Period and for the four that follow. Nine per cent applies not to the excess but to the whole of taxable income, for five years.

Mistake 4. Serving mainland clients without formalising under Resolution No. 11 of 2025. The Article 4 routes are a branch in the Emirate, a branch operating out of the free zone, or a permit for specific activities capped at six months. The cost is twofold. In regulatory terms: activity outside the licensed perimeter, with the base one-year transition in Article 13 having expired in March 2026. In tax terms: the revenue is treated as non-qualifying under paragraph (b) of Article 3(1) of Decision No. 100 of 2023 and consumes the de minimis — whereas with a properly recognised Domestic PE the same revenue is excluded from the de minimis calculation and taxed separately at nine per cent. Formalising protects the status here; failing to formalise destroys it.

Mistake 5. Leaving the executive search guarantee out of the budget. Article 3.7 requires a deposit or bank guarantee of AED 100,000 for segment 21.12 — ten times the minimum capital, and it is not mentioned in Article 15. The cost: the licence does not issue until the guarantee is in place, and the project stalls at a stage where the lease is already paid and staff recruited.

Mistake 6. Planning headcount before floor area rather than after it. The DKP visa quota is one visa per 80 square feet of leased space. The cost: a company that takes an office sized to current needs hits the quota when hiring and must either renegotiate the lease mid-term or delay start dates; neither is free.

Mistake 7. Treating training as exempt or zero-rated for VAT. Article 40(1) of the Executive Regulation requires both a recognised curriculum and a recognised educational institution, and for higher education also government ownership or more than 50% government funding. A commercial corporate-training provider meets none of them. The cost: VAT at 5% that was never charged remains the company’s liability to the budget, with penalties accruing — whereas the correct treatment gives full recovery of input tax.

Mistake 8. Confusing the VAT Designated Zones list with the Free Zone concept for corporate tax. These are two different regimes with different lists. The cost: effort spent pursuing Designated Zone status is doubly wasted — DKP is not on the list, and the Designated Zone fiction under Article 51(6) of the Executive Regulation applies only to goods, so for services the place of supply is inside the State in any event.

Mistake 9. Splitting a training company to stay under the Small Business Relief threshold. Article 6 of Ministerial Decision No. 73 of 2023 contains an anti-avoidance rule against artificially separating a business to keep revenue below AED 3,000,000. The cost: besides the challenge to the relief itself, Article 2(3) closes the regime irreversibly for all later periods once the threshold has been exceeded — so an attempt to preserve the relief can cost the relief.

Mistake 10. Citing repealed instruments as current. The most frequent: Dubai Law No. 30 of 2006 on KHDA (repealed by Law No. 2 of 2021); Cabinet Decision No. 55 of 2023 and Ministerial Decision No. 265 of 2023 on QFZP (repealed by Decision No. 100 of 2023 and Ministerial Decision No. 229 of 2025); Federal Decree-Law No. 20 of 2018 on AML (repealed by Federal Decree-Law No. 10 of 2025); Cabinet Resolution No. 58 of 2020 on beneficial owners (cancelled by Article 22 of Decision No. 109 of 2023); Cabinet Resolution No. 95 of 2022 on Emiratisation (repealed by Article 7 of Resolution No. 43 of 2025). The cost: an opinion built on a repealed provision protects neither in a dispute with a regulator nor on a tax audit, and an internal policy written from such an opinion reproduces the error systematically.

Mistake 11. Assuming in-house training requires a KHDA Authorisation. Article 2(b) of Resolution No. 50 of 2015 expressly excludes private entities providing training to their own employees. The cost here runs the other way — excess compliance: a group that obtains a KHDA Authorisation for an internal corporate university pays from AED 15,000 a year and takes on the obligation to clear every course and every advertisement without any legal need. The exclusion falls away, however, the moment a programme is first sold to an external client.

Mistake 12. Believing Small Business Relief and QFZP status are compatible. Article 3 of Ministerial Decision No. 73 of 2023 expressly excludes a Qualifying Free Zone Person from electing Small Business Relief. The cost: trying to preserve both positions yields neither — and in making the choice it is worth remembering that for a DKP training company QFZP status is usually unattainable in substance, while Small Business Relief is available and has been extended by Ministerial Decision No. 131 of 2026 to Tax Periods ending on or before 31 December 2029.

Mistake 13. Assuming that paying for a segment opens up every activity inside it. The annual fee for segment 21.8 covers three activities while the segment itself contains nine; segments 21.1 and 21.7 follow the same pattern — three activities included out of nine and thirteen respectively. The cost: actually supplying a service outside the three paid activities is caught by paragraph 3 of Schedule 4 to Decision No. 1 of 2021 as carrying on a business of a different activity from that on the licence, attracting AED 10,000, and under Regulation 10.1.7 of the Licensing Regulations 2003 it is a ground for revoking the licence.

Mistake 14. Running recruitment under the “Assessment Centre” activity. The description of activity 21.11.1 in Decision No. 1 of 2021 itself ends with an express proviso: recruitment and placement services are neither included in nor permitted under that activity. The cost: the same AED 10,000 under paragraph 3 of Schedule 4, plus exposure to a claim under Article 6(3) of Federal Decree-Law No. 33 of 2021 for mediation to recruit without a MOHRE licence. Assessment and testing is a service in its own right, not the first stage of a placement.

Mistake 15. Assuming a late renewal can be cleared with a partial payment. Schedule 4 to Decision No. 1 of 2021 directs that monies received from the licensee are applied first against the penalty and only then against the licence fee. The cost: a payment of one licence fee made after 60 days of delay clears the AED 5,000 penalty and leaves the fee short, the delay keeps running and crosses into the over-90-day band at AED 10,000 — while the Authority may in parallel refuse the sponsorship services under Article 4 of the Employment Regulations, halting employee visa renewals.

Who DKP Suits, Who It Does Not, and When Professional Review Is Essential

Who it suits

Corporate training and professional development companies prepared for a two-key regime. Segments 21.1 and 21.7 cover almost the whole spectrum of corporate programmes, the annual licence is AED 15,000, and the district’s infrastructure is built for this sector.

HR consultants. Segment 21.8 is the cleanest DKP category: three activities within the licence fee, no KHDA NOC, no bank guarantee and no sector regulator sitting above the activity.

Assessment and testing businesses, learning-content developers and research operations. Segments 21.11, 21.10 and 21.9 exist in their own right and require no external approvals.

Individual consultants and coaches. The segment 21.13 freelancer permit costs AED 7,500 a year, covers education advising, e-learning advisory, executive coaching, research and training, and under clause 9.3 a freelancer is not an employee for the purposes of the Employment Regulations.

Groups training their own staff in the UAE. The exclusion in Article 2(b) of Resolution No. 50 of 2015 takes in-house training out of the KHDA regime entirely.

Companies whose clients are predominantly free zone residents. That is the one configuration in which QFZP status delivers a real zero result, under paragraph (a) of Article 3(1) of Decision No. 100 of 2023.

Who it does not suit

Staffing and outstaffing companies. Manpower supply cannot be licensed in DKP at all, and supplying one’s own employees to third parties is expressly fined.

Institutions planning to confer degrees. Higher Education Provider is segment 22.1 of Part Seven, which belongs to DIAC, and since 1 January 2026 such institutions additionally go through federal licensure under Federal Decree-Law No. 31 of 2025, whose Article 14(2) requires a local permit before applying for institutional licensure.

Companies whose model depends on a continuous presence at mainland clients without formalising it. The district’s FAQ answers the question in one word: you can only operate within the free zone. The routes in Resolution No. 11 of 2025 exist, but they cost money, are time-limited and require separate books.

Anyone choosing a free zone for a zero corporate tax rate on services to mainland clients. That outcome does not exist for this profile, and a financial model cannot be built on it.

When professional review is essential

• Before choosing a segment — the line between HR consultancy, executive search and manpower supply determines not only the licence category but whether the federal prohibition in Article 6(3) of Federal Decree-Law No. 33 of 2021 applies.

• Before signing a lease — the visa quota is calculated from floor area, and recalculating backwards after signature costs more.

• Before the first mainland contract — the Resolution No. 11 of 2025 route and the recognition of a Domestic PE must be in place before work begins, not after.

• As revenue approaches AED 3,000,000 — crossing the Small Business Relief threshold is irreversible under Article 2(3).

• When a mandate shades into corporate structuring — the “company and trust service provider” head in Article 3 of Resolution No. 134 of 2025 engages, and with it the whole DNFBP regime.

• When planning recruitment for mainland employers — whether a free zone entity may hold a MOHRE mediation licence is unresolved on public primary sources, and written confirmation should be sought from MOHRE on the specific structure.

For support with UAE company registration and the tax administration that follows, that is what UPPERSETUP does.

Frequently Asked Questions

How much does a Dubai Knowledge Park licence cost?

The annual licence for any of the fourteen DKP segments is AED 15,000, and a freelancer permit is AED 7,500 a year. A registration fee of AED 3,500 applies on incorporating an FZ-LLC, plus AED 20 in Knowledge & Innovation Dirhams per transaction. A second segment costs AED 10,000 a year on top of the base fee.

Does a training company in a Dubai free zone need a KHDA Authorisation?

Yes. Article 4 of Executive Council Resolution No. 50 of 2015 requires both a KHDA Authorisation and a licence from the licensing authority, and its Article 2 expressly extends the Resolution to free zones. From DDA’s side, Article 5.5 of Decision No. 1 of 2021 makes a KHDA NOC a condition precedent to licence issuance for segments 21.1 to 21.7.

What minimum capital does a Dubai Knowledge Park company need?

AED 10,000 of paid-up capital. That is the default in Article 15 of Decision No. 1 of 2021; no DKP segment appears in the list of uplifted requirements. The Executive Search segment additionally requires a deposit or bank guarantee of AED 100,000 under Article 3.7 — not capital, but a real financial requirement.

How many visas does a Dubai Knowledge Park office carry?

One employee visa per 80 square feet of leased space — approximately 7.43 square metres per visa. A shared Open Quarters desk carries one permit, a Desk Quarters private desk two, and an Office Quarters private office two or more.

Can a Dubai Knowledge Park company work with clients in mainland Dubai?

Only through one of the three routes in Article 4 of Executive Council Resolution No. 11 of 2025: a licence for a branch in the Emirate, a licence for a branch operating out of the free zone, or a permit for specific activities capped at six months. Separate financial records are required under Article 3(b)(2). The district’s own FAQ answers the question about operating outside the zone in the negative.

Does a free zone training company pay UAE corporate tax?

Yes, at nine per cent on taxable income above AED 375,000, where it does not hold Qualifying Free Zone Person status or where its income is not Qualifying Income. Training and HR consultancy are not among the Qualifying Activities in Article 2(1) of Ministerial Decision No. 229 of 2025, so income from mainland and overseas clients is not Qualifying Income.

Is corporate training subject to VAT in the UAE?

Yes, at the standard rate of five per cent. The zero rate in Article 45(13) of Federal Decree-Law No. 8 of 2017 and Article 40 of the Executive Regulation requires both a recognised curriculum and a recognised educational institution, and a commercial corporate-training provider meets neither. There is no exemption for education in the law at all.

Can recruitment be carried on under a Dubai Knowledge Park licence?

Executive search advisory, yes — under segment 21.12, with a deposit or bank guarantee of AED 100,000. Manpower supply, no: that activity belongs to Dubai Outsource City and is available only to organisations holding a live Department of Economic Development licence. Whether a free zone entity may hold a MOHRE mediation licence for placement is unresolved on public primary sources, and MOHRE should be asked about the specific structure.

How long does it take to register a company in Dubai Knowledge Park?

The official publications diverge: DDA’s service pages give 10 working days for provisional approval and 2 for registration, that is 12 working days; the Dubai Knowledge Park FAQ gives 4 and 3, that is 7. For planning purposes the longer figure is the prudent assumption.

Does Emiratisation apply to a Dubai Knowledge Park company?

The targets apply to employers registered with MOHRE that employ 50 or more workers. A free zone company is not registered with MOHRE — its employees are sponsored by the zone authority — so the targets do not reach it. The exclusion is structural rather than express: no instrument exempts free zones in terms, and the administrative gate could be closed by resolution.

Is Dubai Knowledge Park a Designated Zone for VAT?

No. The FTA’s list for Dubai names JAFZA, DUCAMZ, Dubai Textile City, Al Quoz, Al Qusais, Dubai Aviation City, Dubai Airport Free Zone, International Humanitarian City – Jebel Ali and Dubai CommerCity. For a training business it makes no difference in any event: under Article 51(6) of the Executive Regulation the place of supply of services in a Designated Zone is inside the State.

Is a KHDA Authorisation needed to train a company’s own employees?

No. Article 2(b) of Executive Council Resolution No. 50 of 2015 expressly excludes private entities providing training to their own employees. The exclusion falls away the moment a programme is sold to an external client.

Can a Dubai Knowledge Park company award higher education degrees?

No. Higher Education Provider is segment 22.1 of Part Seven of Decision No. 1 of 2021, which belongs to Dubai International Academic City, and requires a KHDA Academic Authorization. Since 1 January 2026 Federal Decree-Law No. 31 of 2025 also applies — issued 1 October 2025 and replacing Federal Decree-Law No. 48 of 2021: its Article 6(1) prohibits establishing or operating a higher education institution without institutional licensure, Article 10(1) prohibits offering an academic programme without programme accreditation, and Article 14(2) requires institutions in free zones to obtain a local permit before applying for institutional licensure.

What is the penalty for renewing a DDA licence late?

Under paragraph 1 of Schedule 4 to Decision No. 1 of 2021: AED 2,500 where the licence is renewed more than 30 but not more than 60 days after the expiry date; AED 5,000 where it is renewed more than 60 but not more than 90 days after; AED 10,000 where it is renewed more than 90 days after. Renewal within the first 30 days carries no tariff under Schedule 4. The penalty is payable at the same time as or before the licence fee, and monies received are applied first against the penalty. Over and above that, the Authority may refuse to renew the licence and refuse governmental services, including the sponsorship services under Article 4 of the Employment Regulations.

How many activities does a Dubai Knowledge Park licence include?

The AED 15,000 annual fee covers three activities for segments 21.1, 21.7 and 21.8 and one activity for every other DKP segment. The segments themselves contain more: nine activities in 21.1, thirteen in 21.7, nine in 21.8. The company selects the included number from the segment’s list; operating beyond them attracts AED 10,000 under paragraph 3 of Schedule 4 to Decision No. 1 of 2021.

Key Takeaways

• Dubai Knowledge Park is a commercial district of a free zone, not a free zone created by an instrument of its own. The zone was established by Dubai Law No. 1 of 2000 of 31 January 2000; neither DKP nor Knowledge Village is established by any instrument — the district is only mentioned incidentally in later ones, such as Decree No. 32 of 2020 — and the renaming around 2016 was not effected by any instrument.

• The regulator is the Dubai Development Authority and the operator is TECOM Group PJSC, listed on the Dubai Financial Market since 5 July 2022. TECOM manages ten districts; DKP is one of them.

• The chain of Dubai laws: No. 1 of 2000 → No. 15 of 2014 (renaming the zone and its authority) → No. 10 of 2018 (renaming the authority to DDA) → No. 8 of 2023, which replaced Article 3 of Law No. 15 of 2014 in full. The last link is missing from most published chains.

• DKP is Part Six of Decision No. 1 of 2021, with fourteen segments numbered 21.1 to 21.14. The annual licence for any segment is AED 15,000 and a freelancer permit AED 7,500; the difference between segments lies not in price but in the number of activities included — three for 21.1, 21.7 and 21.8, one for the rest.

• The minimum paid-up capital of an FZ-LLC is AED 10,000, and no DKP segment appears in the uplifted list in Article 15. The same list gives AED 50,000 for DIAC.

• Seven of the fourteen segments — every training segment, 21.1 to 21.7 — require a KHDA NOC before licence issuance under Article 5.5. Segments 21.8 to 21.12 do not.

• The Executive Search segment 21.12 requires a deposit or bank guarantee of AED 100,000 under Article 3.7— ten times the minimum capital, and outside Article 15.

• Training requires two permissions: a KHDA Authorisation under Article 4 of Executive Council Resolution No. 50 of 2015, and a DDA licence. The Resolution expressly reaches free zones, as does Article 3(a)(2) of Dubai Law No. 2 of 2021, which repealed Law No. 30 of 2006.

• In-house training of a company’s own employees is excluded from the KHDA regime by Article 2(b) of Resolution No. 50 of 2015.

• The fine for training without a KHDA Authorisation is AED 50,000; for operating on an expired one, AED 15,000 a month capped at AED 100,000; for an unauthorised programme and for misleading advertising, AED 25,000 each.

• Manpower supply cannot be licensed in DKP: it is activity 17.1.8 in Dubai Outsource City, available only to organisations with a live DED licence and only within the free zone. Supplying one’s own sponsored employees to third parties is fined AED 5,000 per person with visa cancellation.

• Training, HR consultancy and recruitment do not appear in the list of Qualifying Activities in Article 2(1) of Ministerial Decision No. 229 of 2025. The Excluded Activities sit in Article 2(2), not in Article 3, which deals with de minimis.

• The counterparty is decisive: under paragraph (a) of Article 3(1) of Decision No. 100 of 2023, income from transactions with a Free Zone Person qualifies irrespective of the activity, and the Qualifying Activity filter operates only in paragraph (b), on transactions with Non-Free Zone Persons.

• The de minimis threshold is 5% of revenue or AED 5,000,000, whichever is lower; breaching it forfeits QFZP status itself from the beginning of the Tax Period and for the four that follow, with nine per cent applying to the whole of taxable income.

• Small Business Relief on revenue up to AED 3,000,000 is more practical than QFZP for a typical DKP company and has been extended by Ministerial Decision No. 131 of 2026 of 29 July 2026 to Tax Periods ending on or before 31 December 2029. The two regimes are mutually exclusive under Article 3 of Ministerial Decision No. 73 of 2023.

• Formalising mainland activity through a DET branch or permit protects QFZP status: Domestic Permanent Establishment revenue is excluded from the de minimis calculation and taxed separately at nine per cent.Unformalised mainland revenue, by contrast, counts against de minimis and breaches the threshold.

• Corporate training is standard-rated for VAT at 5%: the Article 40(1) conditions for zero-rating — a recognised curriculum and a recognised institution — are not met by a commercial provider, and there is no exemption for education in the law.

• DKP is not a VAT Designated Zone, and for services that is immaterial in any event — under Article 51(6) of the Executive Regulation the place of supply of services in a Designated Zone is inside the State.

• The visa quota is one visa per 80 square feet of leased space, roughly 7.43 square metres per visa.

• The registration timelines in the two official publications do not agree: 12 working days on DDA’s service pages against 7 in the district’s FAQ.

• A DKP company is not a DNFBP under Article 3 of Cabinet Resolution No. 134 of 2025 — subject to the caveat that the residual limb of Article 3 allows a Supervisory Authority to designate further businesses by resolution — but must confirm its beneficial ownership data through AXS under DDA Circular 670 of 3 June 2026 and falls within e-invoicing: appoint an Accredited Service Provider by 31 March 2027 where revenue is below AED 50,000,000, and issue from 1 July 2027.

• Schedule 4 to Decision No. 1 of 2021 sets a published tariff of sanctions: late renewal at AED 2,500, AED 5,000 or AED 10,000 depending on how long the delay runs; operating without a licence at AED 10,000, and AED 25,000 on repetition; operating outside the licensed segment or activity at AED 10,000; inaccurate information, obstructing inspectors and failing to provide beneficial ownership at AED 5,000 each. Over and above the penalty the Authority may refuse the sponsorship services under Article 4 of the Employment Regulations. The one unverifiable instrument in the corpus is Decision No. 2 of 2017 on PCR 2016 fines: DDA posts it as a four-page scan with no text layer, and its amounts are not stated in this article.

Summary

Dubai Knowledge Park (DKP) is a district of the Dubai Development Authority free zone in Dubai specialising in human resources, recruitment, corporate training and professional development. The free zone itself was created by Dubai Law No. 1 of 2000; the operative chain of emirate instruments comprises Law No. 15 of 2014 (27 October 2014), Law No. 10 of 2018 (19 September 2018) and Law No. 8 of 2023 (6 February 2023), which replaced Article 3 of Law No. 15 of 2014 in full. The regulator and licensing authority is DDA and the commercial operator is TECOM Group PJSC, listed on the Dubai Financial Market since 5 July 2022 and managing ten districts. DKP forms Part Six of DDA Decision No. 1 of 2021 and contains fourteen segments numbered 21.1 to 21.14: professional and management development training, computer training, language training, fine arts training, child skills development training, tutoring services, technical and occupations skills, human resources consultancy, research and development, content development, assessment and testing, executive search, freelancers and non-profit associations. The annual licence fee for any segment is AED 15,000, a freelancer permit is AED 7,500 a year, FZ-LLC registration is AED 3,500, minimum paid-up capital is AED 10,000, and adding a second standard segment costs AED 10,000 a year. The seven training segments 21.1 to 21.7 require a No Objection Certificate from KHDA before licence issuance under Article 5.5 of Decision No. 1 of 2021, and the Executive Search segment 21.12 requires a deposit or bank guarantee of AED 100,000 under Article 3.7. Training activity additionally requires a KHDA Authorisation under Article 4 of Executive Council Resolution No. 50 of 2015, which by its Article 2 expressly reaches free zones and by its Article 2(b) does not apply to private entities training their own employees; the fine for operating without an Authorisation is AED 50,000. Manpower supply cannot be licensed in DKP and belongs to activity 17.1.8 in Dubai Outsource City, available only to organisations holding a Department of Economic Development licence. For corporate tax purposes, training, HR consultancy and recruitment do not appear among the Qualifying Activities in Article 2(1) of Ministerial Decision No. 229 of 2025 (issued 28 August 2025, effective from 1 June 2023, repealing Ministerial Decision No. 265 of 2023), so income from mainland and overseas clients is not Qualifying Income and is taxed at nine per cent above AED 375,000; income from transactions with a Free Zone Person that is the Beneficial Recipient qualifies under paragraph (a) of Article 3(1) of Cabinet Decision No. 100 of 2023 and is taxed at zero per cent. The de minimis threshold is 5% of revenue or AED 5,000,000, whichever is lower, and breaching it forfeits Qualifying Free Zone Person status from the beginning of the Tax Period and for the four subsequent periods under Article 5(2). Small Business Relief under Ministerial Decision No. 73 of 2023, on revenue up to AED 3,000,000, has been extended by Ministerial Decision No. 131 of 2026 to Tax Periods ending on or before 31 December 2029. Corporate training is standard-rated for VAT at 5% because the zero-rating conditions in Article 40(1) of the Executive Regulation are not met; DKP is not on the VAT Designated Zones list, which is immaterial for services under Article 51(6). Across its fourteen segments the Decision defines forty-seven activities, the annual fee covering three activities for segments 21.1, 21.7 and 21.8 and one for the rest, while the description of activity 21.11.1 Assessment Centre expressly excludes recruitment and placement services. Schedule 4 to Decision No. 1 of 2021 sets the penalties: AED 2,500, AED 5,000 and AED 10,000 for renewal more than 30, 60 and 90 days after expiry respectively, AED 10,000 for carrying on business without a licence rising to AED 25,000 on a subsequent offence, AED 10,000 for operating outside the licensed segment, and AED 5,000 each for inaccurate information, obstructing inspectors and failing to provide ultimate beneficial ownership. The visa quota is one visa per 80 square feet of leased space. Work with mainland clients is possible only through the routes in Article 4 of Executive Council Resolution No. 11 of 2025 of 3 March 2025, with separate financial records under Article 3(b)(2).

Sources

Primary texts are cited from the official portals: Dubai Legislation (dlp.dubai.gov.ae), UAE Legislation (uaelegislation.gov.ae), the UAE Ministry of Finance, the Federal Tax Authority, the Dubai Development Authority and KHDA.

A methodological note on sources. Every statutory formulation in this article has been checked against the primary texts on the official portals listed above. Where an official source contradicts itself, the divergence is shown rather than smoothed over: this applies to DDA’s registration timelines against the district’s FAQ, to KHDA’s fees under the schedules to Resolution No. 50 of 2015 against its live service page, to the mediation licence term in MOHRE’s FAQ against MOHRE’s service pages, and to the coexistence of the Employment Regulations 2004 citing the repealed Federal Law No. 8 of 1980 with DDA’s standard employment terms applying Federal Decree-Law No. 33 of 2021. All four schedules to Decision No. 1 of 2021, Schedule 4 on penalties included, have been read from the file DDA publishes and are reproduced here from the primary text. The one document in the corpus that could not be obtained is Decision No. 2 of 2017 on PCR 2016 fines: DDA posts it as a four-page scan with no text layer, and its amounts are not given here. Nor could the instrument approving KHDA’s operative tariff be found: neither the Dubai legislation portal nor the authority’s own site carries anything amending the schedules to Resolution No. 50 of 2015. DDA visa fees, the establishment card under the administration department’s schedule, and DKP rents per square foot are not officially published, and the figures circulating for those items come from sources inadmissible under the editorial standard applied here.

Disclaimer

This material is informational in nature and does not constitute legal, tax, financial, investment or consulting advice. Before taking decisions, individual professional advice must be obtained, taking into account the specific situation, jurisdiction, status of the company and the regulators’ current requirements.

Date of publication: August 2026.

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