Law No. 18 of 2026 replaces the 1961 order that established Dubai Municipality. It introduces no new obligations, fees or penalties today; the point to watch is the implementing regulations, which could add Municipality permits and inspections to those already required by each free zone authority.
What happened
On 12 November 2026 Sheikh Mohammed bin Rashid, Ruler of Dubai, issued Law No. 18 of 2026 concerning Dubai Municipality. The new law replaces the 1961 order that originally established the Municipality. According to the announcement by the Dubai Media Office, the Dubai Government's official press office, the Municipality will exercise its powers across the whole emirate, "including special development zones and free zones, such as the DIFC" (Dubai International Financial Centre), unless specific legislation exempts a particular zone. The law takes effect on publication in the Dubai Official Gazette. What is known so far comes from the official announcement; the full text as published in the Gazette has yet to be reviewed.
What changes in practice
The scope changes: free zones are no longer excluded from the Municipality's remit as a matter of principle. The areas named are urban planning, waste management, building and construction, public health and safety, and food safety, together with powers of oversight and inspection. All parties, private businesses included, are required to cooperate and to provide the Municipality with the data and documents it requests. What does not change for now: the announcement sets out no new obligations, fees, penalties or transition period, and existing regulations and resolutions remain in force until replaced, provided they do not conflict with the new law.
Who it applies to
The activities most likely to be affected are physical operations falling within the Municipality's areas of competence. There are four: food service and food trading; construction sites, building work and office fit-out (the interior works that make premises usable); warehousing and logistics; and ownership of commercial property within the special zones.
The exposure
The exposure today is low. It becomes concrete once implementing regulations are issued: Municipality permits, inspections and health and safety requirements could be layered on top of those already imposed by the relevant free zone authority (such as DMCC, the Dubai Multi Commodities Centre, IFZA, the International Free Zone Authority, the DIFC or Meydan). The mistake to avoid is assuming that a free zone licence by itself rules out any other oversight: under the new law, free zones are no longer excluded by default, and an exclusion applies only where specific legislation exempts the zone.
What to do now
No immediate action is required. Three checks are worthwhile: confirm whether the free zone company's activity falls into one of the four categories above; keep the permits and documents already issued by the free zone in order, as the Municipality may ask for them; and follow the publication of the full text in the Gazette, along with any exemptions for individual free zones, before changing anything in how the business is organised.
Sources
Published 13 November 2026 on the basis of public sources and official United Arab Emirates instruments. This is not legal or tax advice. Verify your position with a qualified professional before acting.