UAE businesses can no longer afford to delay their Pillar Two registration.
With the FTA now providing clarity on when businesses are required to register, deregister and notify changes to their Pillar Two status, in scope businesses should assess their obligations and prepare to meet the prescribed deadlines.
The key compliance timelines are set out below:
| Requirements | Scenario | Deadline |
|---|---|---|
| Registration | Standard Timeline | Within 7 months from the end of the first Financial Year in which the entity becomes in scope |
| Businesses subject to Pillar Two whose Fiscal Year ended before 30 April 2026 | By 30 November 2026 | |
| De-registration | Standard Timeline | Within 6 months from the earliest of: •The date it ceases to exist; or, •The end of the Fiscal Year in which it leaves the MNE Group and is no longer in scope. |
| Business subject to Pillar Two ceases to exist before 30 June 2026 | 31 December 2026 | |
| Businesses out of scope for 5 consecutives Fiscal Years | Within 6 months from the end of the fifth Financial Year | |
| Notification | Out of Scope Notification (valid for four consecutive Fiscal Years) | Within 6 months from the end of the Financial Year |
| In Scope Notification | Within 7 months from the end of the Financial Year |
Note:
Effective January 2025, UAE businesses that are members of the Multinational Enterprise (“MNE”) Groups are subject to the UAE Pillar Two regime. The regime generally applies where the MNE Group has consolidated global revenue exceeding EUR 750 million in at least two of the four preceding Financial Years.
The key compliance timelines are set out below:
- Assess whether the group falls within the scope of Pillar Two: Assessment is recommended to conclude whether the UAE entity is in scope and registration is required.
- Register within the prescribed timelines, where applicable: Given the prescribed timelines, it would be prudent to initiate registration to avoid any penalties due to delayed registration
How can we help?
Our Pillar Two specialists can assist businesses throughout the registration and ongoing compliance lifecycle, including:
- Scoping & Impact Assessment: Assessing whether your group falls within scope and identifying key Pillar Two exposure areas.
- Registration Assistance: Advising on the appropriate registration approach and assisting with the EmaraTax registration process.
- Ongoing Compliance: Supporting the preparation and review of Pillar Two calculations, filings, and related reporting obligations, including assessment of available reliefs and transitional measures.
- Documentation:Helping establish appropriate documentation, governance, and audit readiness frameworks for future FTA review.
Final Thoughts
The FTA has now provided much needed procedural clarity for Pillar Two compliance. Businesses should use this opportunity to confirm their Pillar Two position, meet the prescribed registration and notification deadlines, and establish appropriate governance processes for ongoing compliance.
Meet the Experts
Who we are
Re/think is an award-winning regional multi-service business advisory and outsourced services firm providing accounting, regulatory and compliance, tax and VAT advisory, audit, HR consultancy and recruitment services to regulated firms, multi- and single-family offices, and other operating businesses.
Established in the UAE in 2013, the firm has 80+ staff across three offices in Dubai and Abu Dhabi providing clients with timely, proactive and customized business solutions – from set-up and early development to the latest stages of a business lifecycle.