Audit Readiness Emergency: UAE Companies Must Fix Internal Controls Before Heightened FTA Review Focus in Late 2025

Key Takeaways

  • New Ministerial Decision #84 (2025): Mandates audited statements and tax filings for more entities, with requirements for both local and multinational groups, plus more detailed transfer pricing reconciliation.
  • SCA’s 2025 Internal Control Opinion: All listed UAE companies must obtain an independent auditor’s opinion on the effectiveness of internal controls over financial reporting (ICOFR), with disclosure requirements becoming effective for financial years ending on or after December 31, 2025.
  • FTA Audit File (FAF) Requirement: Companies must now maintain VAT records and reconciliations in an FTA-approved electronic format, ready for prompt submission.
  • Free Zone Audit Deadlines: Many Free Zones, including DMCC, DIFC, and JAFZA, maintain strict annual audit deadlines (typically 6 months from the financial year's end). While some recent adjustments, like DMCC's extension for FY2024 audits to align with Corporate Tax filing, highlight ongoing regulatory evolution, non-compliance still risks severe sanctions—license suspension, portal access lockout, and non-renewal.

Imagine This: 

In October 2025, your company receives a notification from the UAE Federal Tax Authority (FTA)—you have just five days to provide every record supporting two years of tax returns. Could a missing invoice or a weak documentation system expose you to penalties? For some firms, it’s not hypothetical—it’s the new reality in the UAE’s tightening regulatory environment. 

This article is essential reading for UAE MNCs, large corporates, and CFOsracing against the heightened FTA audit focus in late 2025 deadlines. Here, discover the urgent steps to optimize internal controls, navigate FTA requirements, and ensure your business is audit-ready—before it’s too late. 

 

Preparing for Heightened FTA Audit Focus in Late 2025 

Why now? 
The UAE is sharply increasing its scrutiny of companies—driven by new corporate tax laws, international pressure to meet FATF anti-money laundering standards, and recurring compliance failures by major market players. In 2025, an audit that uncovers non-compliance could mean steep fines for specific violations (e.g., AED 10,000–50,000 for record-keeping or non-submission), license suspensions, reputational damage, and even business closure. 

 

Common Compliance Challenges and UAE Market Pain Points 

  1. Inadequate Internal Controls 
    Many fast-growing businesses still depend on manual record-keeping or fragmented systems. Result? Gaps in VAT documentation, reconciliation delays, and compliance loopholes. 
  2. Poor Documentation and Audit Trails 
    FTA now expects “audit-proof” digital records—missing invoice scans, lost contracts, or incomplete VAT logs are common audit failure culprits. 
  3. Weakness in UAE AML and UBO Controls 
    Emerging sectors (crypto, real estate, fintech) struggle to keep pace with sharpening AML, FATF, and UBO reporting requirements—contributing to penalty surges. 
  4. Over-reliance on Spreadsheets 
    Without integrated, FTA-accepted accounting software, companies are prone to accidental errors that the FTA flags as “red signals” for possible fraud or misstatement. 
  5. Cultural and Language Barriers 
    Many multinational teams misinterpret local rules, leading to missed deadlines and improper filings (“We didn’t know the deadline was moved forward this year!”). 

Trends and Innovations Shaping UAE Internal Controls & FTA Audit Preparation 

 

1. COSO-aligned Control Frameworks 

UAE’s Securities and Commodities Authority (SCA) and Central Bank increasingly require robust internal control systems, with COSO-aligned frameworks now serving as a critical benchmark for listed, regulated, or larger companies. 

 

2. FTA-Ready Automation and Cloud Record-Keeping 

Leading firms are switching to ERP systems that automate FTA FAF file preparation, digital invoicing, and real-time reconciliation—reducing manual risk and shortening FTA response times from days to hours. 

 

3. Integrated AML & UBO Tech 

Specialized UAE service providers now offer platforms combining transaction monitoring, AML flagging, and UBO registry filing—helping ensure compliance with both FTA and FATF obligations. 

 

4. AI Audit Tools (Still Emerging) 

While AI-based anomaly detection and blockchain-enabled transaction logs are promising, most businesses must still combine new tech with robust human controls to satisfy FTA and auditor scrutiny. 

 

Practical Guide: Achieving UAE Audit Readiness Ahead of Heightened FTA Focus in Late 2025 

 

Control Remediation Checklist (2025 Edition) 

1. Conduct a Full Internal Controls Assessment 

  • Map all business processes against COSO/FTA requirements. 
  • Identify control design and operating gaps—especially for VAT, AML, and payroll. 

2. Rapidly Remediate Gaps 

  • Prioritize fixes for “high-risk” areas: cash flows, invoice logging, and intercompany transactions. 
  • Update or deploy automated record-keeping and reconciliation tools. 

3. Prepare Audit-Proof Documentation 

  • Archive all compliance records for at least 5 years (digital, indexed, FTA-ready). 
  • Use checklist-driven archiving for tax, payroll, UBO, and AML files. 

4. Ongoing Monitoring and “Mock Audits” 

  • Schedule quarterly, unscheduled “readiness reviews”—simulate a real FTA audit’s documentation request and 5-day response window. 

5. Educate Teams and Engage Advisors 

  • Run training for finance and compliance teams on ministerial decision updates and audit changes, ideally with a UAE audit advisor or ASC Group support. 
  • Subscribe to local regulatory alerts and audit advisory bulletins. 

6. Engage with FTA and Free Zone Authorities 

  • Proactively submit queries if uncertain—FTA provides guides and a helpdesk for record-keeping and audit queries. 

 

Conclusion: Momentum for Change 

UAE businesses that delay internal controls remediation risk heavy penalties and reputational harm in the 2025 audit tidal wave. Yet, those acting now—migrating to digital documentation, conducting control assessments, and aligning with COSO or SCA frameworks—will not only avoid fines but also demonstrate market leadership, improved transparency, and greater operational resilience. 

Don’t get caught off guard—make audit readiness your competitive advantage. 
Ready to bulletproof your controls? 
Contact ASC Group for a free FTA audit readiness assessment for UAE businesses or download our [compliance checklist] today. 

Engage with us: 

  • What’s your biggest FTA audit concern for 2025? Comment below. 
  • Share this article with your compliance team—and join the discussion on LinkedIn. 
  • Have a unique scenario or compliance query? Submit your question for expert insight. 

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