By Dr. Abdultaiyab Bahrainwala, Partner, Head of Corporate, and Jouslin Khairallah, Founder & Managing Director, Head of Litigation.
What businesses should review before the temporary relief periods close
Dubai has adopted a broad package of 37 temporary economic and social incentive facilities through Executive Council Resolution No. 40 of 2026. The measures reach across licensing, tourism, customs, education, transport, construction and civil aviation. For businesses, however, the headline number is less important than the calendar: each facility has its own eligibility conditions, responsible authority and expiry date, and several relief periods had already ended by the time the Resolution was published on 11 September 2026.
A targeted response with a practical legal framework
The Resolution was issued on 7 September 2026 and published in Dubai’s Official Gazette on 11 September 2026. Article 8 provides that it takes effect from 1 April 2026. Its stated aims include supporting business continuity, reducing costs for affected establishments, protecting living standards, encouraging investment, improving regulatory efficiency and enabling government entities to introduce temporary relief quickly when economic conditions require it.
The structure is significant. Articles 1 to 4 adopt the facilities listed in the attached schedule, fix their implementation periods and require the responsible government entities to report monthly on their impact. Article 5 also permits Dubai government entities, within their competence and with Executive Council approval, to launch further economic or social incentives. The Resolution therefore combines a defined package of present relief with a mechanism for future, time-bound measures.
That flexibility has limits. Any additional facilities launched under Article 5 must have defined objectives and identified beneficiaries, remain temporary, respect approved public allocations and avoid prejudice to rights and obligations under existing legislation. Article 5 also states that the illustrative future initiatives, including monthly residential rent payments, expansion of housing programmes linked to ownership and flexible work packages for UAE national entrepreneurs, are encouragement-based and do not themselves create legal rights or obligations. They should not be treated as immediately enforceable entitlements without an implementing circular, programme or decision from the competent authority.
The measures most relevant to businesses
Commercial licensing relief is among the most immediately useful parts of the package. Establishments were permitted to renew commercial licences without producing a lease contract, provided the lease renewal was completed within three months, and fines for late commercial-licence renewal were waived. Both measures run from 1 April to 30 September 2026. A business seeking to rely on either relief should act promptly and retain proof of the application date, the authority’s acceptance and, where relevant, completion of the lease renewal within the prescribed three-month period.
The tourism, hospitality and events sectors receive several forms of support. The package includes temporary Tourism Dirham and municipality-fee relief for specified hotel and restaurant categories, although the later phase excludes certain beachside hotel establishments and nightclubs. Event permit fees, including postponement and cancellation fees, are waived for qualifying events held or planned during 2026 until 31 December 2026. Permit fees for discounts and commercial offers are also waived until year-end, subject to the stated exclusion for fees connected with Dubai’s summer or annual retail calendar. Holiday-home permit fees are waived from 1 May 2026 to 30 April 2027.
Customs measures address both time and liability. The package extended the grace period for export or transit customs declarations from 30 to 90 days, subject to an overall maximum of six months and compliance with tax and customs laws, although that facility ends on 30 September 2026. It also provides an 80 per cent reduction in fines relating to customs cases until 31 December 2026 where the decision imposing the fine was issued before 28 February 2026, 20 per cent of the fine is paid, and the customs duties are paid in full, whether immediately or by instalments. These conditions are cumulative and should be confirmed against the particular customs file before payment or settlement steps are taken.
Government suppliers benefit from reduced security requirements. For goods and services supply contracts, the final security is reduced from 10 per cent to 2 per cent, while the contract-value threshold requiring final security increases from AED 5 million to AED 10 million. The schedule also protects suppliers and contractors under government works contracts from an increase in final security caused by variation orders issued during the implementation period. These facilities apply until 31 December 2026 and may materially affect tender pricing, working-capital planning and the wording of security instruments.
Other sectors receive focused relief. Education measures include rental concessions, rescheduling, security-deposit relief, temporary suspension of specified contractual penalties and fee relief for early-childhood centres and private educational institutions. Cultural and creative establishments may benefit from deferred or rescheduled rent and financial obligations, along with a 30 per cent reduction in temporary-space rent until 30 September 2026. Building permits receive validity extensions without extension fees until 31 December 2026, while civil-aviation businesses receive a 50 per cent reduction in permit-renewal fees and a suspension of late-renewal fines until the same date.
A deadline map as at 15 September 2026
The Resolution’s retrospective commencement does not reopen every relief period. As at 15 September 2026, businesses should distinguish between facilities that remain open and those whose scheduled periods have already closed. The dates below are a practical guide only; the exact scope and conditions in the schedule remain controlling.
| Deadline | Examples of relief | Immediate business action |
|---|---|---|
| 30 September 2026 | Commercial-licence renewal relief; customs declaration extensions; selected cultural, creative and transport measures | Submit complete applications now and preserve filing and eligibility evidence |
| 31 December 2026 | Event and promotion permits; customs-fine reductions; government-contract security; building permits; civil aviation | Check sector-specific conditions and obtain written authority confirmation |
| 30 April or 31 May 2027 | Holiday-home permits; selected early-childhood-centre measures | Confirm the relevant permit or lease falls within the stated category |
| Already ended | Various fee deferrals, instalment measures and administrative-fine deferrals ending in June 2026 | Do not assume retrospective publication revives an expired application window |
Relief is not automatic
The Resolution should be read as an enabling legal instrument, not as a blanket waiver. Each facility applies only to the categories, liabilities and periods stated in the schedule. Several measures also require compliance with a separate mechanism, authority procedure or agreed control. A qualifying business should therefore identify the exact numbered facility, verify that its licence, permit, contract, fine or payment falls within scope, and submit the required application to the named responsible entity before the deadline.
Businesses should also avoid treating temporary relief as a permanent amendment to their contracts or statutory duties. Article 3 allows an implementation period to be extended only with the prior approval of the Chairman of the Executive Council. Article 7 repeals inconsistent provisions only to the extent of the conflict, while the remainder of the applicable legal and contractual framework continues to operate. Unless an extension or implementing direction is formally issued, the date stated in the schedule should be treated as final.
What businesses should do now
A focused legal and operational review should begin with all government fees, licence renewals, customs matters, permit applications, government contracts, leases with participating public entities and administrative fines arising during 2026. Finance and legal teams should reconcile those items against the 37 facilities, calculate the potential saving, identify the responsible authority and confirm the last filing date. Applications should be supported by the relevant licence, contract, invoice, customs decision, permit record or lease, together with a concise explanation of eligibility.
Where an amount has already been paid, the Resolution does not expressly create a general right to reimbursement. Any refund, credit or adjustment should be confirmed with the competent authority under its implementing procedure. Likewise, businesses that missed an earlier deadline should not rely solely on the Resolution’s 1 April effective date. They should seek written clarification on whether a retrospective application, adjustment or authority-led correction remains available.
The wider legal significance
Resolution No. 40 of 2026 is notable for the breadth of its sector coverage and for the reporting discipline built into the framework. Responsible entities must measure results and submit proposals to amend, develop or extend the facilities. This creates a structured route for temporary relief to be assessed against its economic effect, rather than remaining open-ended. For investors and operators, the practical benefit is a clearer framework for targeted intervention, but access depends on careful attention to legal scope, supporting documents and deadlines.
The immediate message is straightforward: relief may be available, but time is part of the entitlement. Businesses that review their 2026 regulatory and contractual payments now may identify meaningful savings, especially where the relevant facility expires on 30 September or 31 December 2026. Delay may convert a valuable concession into a missed opportunity.