100% foreign ownership on the mainland: which activities still need a local partner

Until 2021, the rule on the UAE mainland was simple and restrictive: a UAE national or a wholly UAE-owned company had to hold at least 51% of any mainland LLC, no matter where the money or the idea came from. Federal Decree-Law No. 26 of 2020 flipped that default, and Federal Decree-Law No. 32 of 2021 on Commercial Companies consolidated the change into the law that still governs mainland entities today (UAE Legislation portal, retrieved 2026-09-05). The 51% requirement is gone for most activities. It was never removed for all of them.

That distinction is where founders get tripped up. "100% foreign ownership is now allowed on the mainland" is true as a general statement and unreliable as a specific one, because the reform works as a default that flips unless an activity sits on a short list of exceptions. Two founders can hold identical passports and still get different answers on the same afternoon, because one of them picked an activity code the other didn't.

Key Takeaways

• The 51% Emirati-ownership default was removed for most mainland activities by Federal Decree-Law No. 32 of 2021. It is no longer the general rule, but it was never abolished outright.
• A "strategic impact" list under Cabinet Resolution No. 55 of 2021 keeps sectors like security and defence, banking and insurance, currency printing, telecoms, Hajj and Umrah services, and Quran memorisation centres subject to negotiated Emirati participation, decided case by case by the relevant regulator.
• Fishing and fish-trap services are the one category on that list closed to foreign ownership entirely, not negotiable, not case by case.
• Oil and gas exploration and production sits on a separate negative list tied to concession law, not the Commercial Companies Law exemption regime, and stays effectively closed to foreign equity ownership.
• A local service agent is still required for professional sole establishments and civil companies owned by non-GCC nationals, even though the agent holds no equity and no management role.

What the 2021 reform actually changed

Before the reform, the 51% rule applied uniformly: mainland companies needed majority Emirati ownership regardless of activity, and branches of foreign companies additionally needed a UAE national service agent just to operate. Federal Decree-Law No. 26 of 2020, effective from 1 January 2021 and folded into Federal Decree-Law No. 32 of 2021, removed both defaults for the large majority of commercial and industrial activities and eliminated the service-agent requirement for foreign branches as a general matter (Pinsent Masons, retrieved 2026-09-05).

The mechanism matters more than the headline. The law did not publish one master list of "activities now open to 100% ownership." Instead, it inverted the burden: every activity is presumed open to full foreign ownership unless it appears on a specific exclusion list, and it's each emirate's Department of Economic Development (or Department of Economy and Tourism, depending on the emirate) that then confirms, activity by activity, whether a given licence qualifies. Abu Dhabi's DED has cleared more than 1,100 activities for full foreign ownership; Dubai's has cleared more than 1,000 (search-aggregated reporting on DED positive lists, retrieved 2026-09-05). That's reassuring in scale, but it also means the confirmation step is not optional. It happens at the licensing counter, against your specific activity code, not against the law in the abstract.

The "strategic impact" list: what's actually excluded

Cabinet Resolution No. 55 of 2021 names the activities carved out of the default. Reporting on the resolution groups them into seven categories: security, defence, and military-related activities; banking, money exchange, finance companies, and insurance; currency printing; telecommunications; Hajj and Umrah services; Quran memorisation centres; and fishing and fish-trap services (Lexology, retrieved 2026-09-05).

Being on this list doesn't mean foreign investors are locked out. For six of the seven categories, the relevant sector regulator: the Central Bank for banking, insurance, and finance; the Telecommunications and Digital Government Regulatory Authority for telecoms; the Ministry of Interior or Ministry of Defence for security-related activities, and so on: reviews each application and sets the Emirati and foreign ownership split, board composition, and any operating conditions on a case-by-case basis. Nothing here is automatically majority-Emirati; it's regulator-approved, which is a materially different (and slower) process than a standard DED licence.

The one true exception is fishing and fish-trap services, which the resolution reserves entirely for UAE nationals, no foreign participation, negotiated or otherwise. If your activity touches commercial fishing, this isn't a negotiation; it's a closed door under the current framework.

Oil and gas sits on a different list entirely

Exploration and production of oil and other petroleum products doesn't appear on the Cabinet Resolution 55 strategic-impact list. It's governed separately, through each emirate's petroleum and concession framework, and functions as a negative list where foreign equity ownership stays closed (Kayrouz & Associates, retrieved 2026-09-05). In practice, upstream oil and gas activity in the UAE runs through concession agreements between the relevant government (Abu Dhabi's ADNOC being the dominant example) and international operators, with the state entity holding the controlling interest rather than the operating company being foreign-owned outright. Foreign companies have participated in UAE oil and gas for decades through that concession structure. It's a different legal route from applying for a 100%-owned mainland trading licence, and it isn't one a standard company-formation filing can get you into.

Where a local service agent still applies

The 2021 reform removed the local service agent requirement for foreign branches and for LLCs licensed under an activity that qualifies for full foreign ownership. It did not remove it everywhere. A non-GCC national setting up a professional sole establishment: solo consultancies, engineering practices, and similar activities licensed under a professional (rather than commercial) category: still needs a UAE national or wholly UAE-owned company appointed as local service agent, as does a wholly foreign-owned civil company. The agent holds no equity, takes no profit share, and carries no operating liability; the role is limited to liaising with government departments on licensing and permits, typically for a fixed annual fee (e.zone, retrieved 2026-09-05). If you're structuring as an LLC under a commercial activity that's already on your emirate's open list, this requirement doesn't apply to you at all. It's specific to the professional/civil-company licence category, not a general condition of foreign ownership.

How to check your specific activity

None of the above substitutes for confirming your own activity code. The practical sequence is: identify the exact activity you intend to licence (not a general description of your business, but the specific code your emirate's DED uses), then check that code against your emirate's published list of activities eligible for full foreign ownership before you commit to a formation path. Dubai and Abu Dhabi run separate lists, and an activity cleared in one emirate isn't automatically cleared in another, so the check has to be emirate-specific, not general.

If your activity clears, the ownership question is settled and the decision moves to the ones that actually vary by founder: mainland versus free zone market access, office and visa costs, and corporate tax treatment: covered in the UAE business setup guide. If your activity sits on the strategic-impact list, budget for a longer, regulator-driven approval timeline rather than a standard licensing one, and get the ownership split confirmed in writing before you sign a lease or make a hire. Either way, work the company formation route in the launch accelerator and run your visa and office assumptions through the business setup cost calculator once ownership is confirmed, not before: the cost model only holds once you know which licence category you're actually getting.

Frequently asked questions

Is 100% foreign ownership automatic on the UAE mainland now?

Not automatically for every activity. It's the default for the large majority of commercial and industrial activities since the 2021 reform, but it still has to be confirmed against your emirate's specific list, and a short set of exclusions (the strategic-impact list, oil and gas exploration and production, and fishing) sit outside that default.

What happens if my activity is on the strategic impact list?

You apply through the relevant sector regulator rather than a standard DED filing, and the regulator decides the Emirati and foreign ownership split, board conditions, and any other operating requirements case by case. Except for fishing and fish-trap services, which stays fully reserved for UAE nationals, foreign participation is possible but not guaranteed at any fixed percentage.

Do I need a local service agent if I'm setting up an LLC under a fully open activity?

No. The local service agent requirement applies to professional sole establishments and civil companies owned by non-GCC nationals, not to LLCs licensed under an activity that already qualifies for full foreign ownership. Confirm your licence category, not just your nationality, before assuming either way.

Can the same activity be open in one emirate and restricted in another?

Yes. Each emirate's Department of Economic Development (or equivalent) maintains its own list of activities cleared for full foreign ownership, and the lists aren't identical across emirates. Check the specific emirate you intend to licence in rather than assuming a clearance carries over.

The bottom line

The 2021 reform reversed the default, not the rulebook. Most mainland activities are open to 100% foreign ownership without a local partner, but a defined set of exclusions: a strategic-impact list reviewed by sector regulators, a separately governed oil and gas negative list, and a narrower local-service-agent requirement for professional sole establishments: still sits outside that default. The only reliable way to know where your business falls is to check the exact activity code against your emirate's current list before you build a launch budget or a partnership structure around an assumption.

This guide was reviewed and verified on September 5, 2026.