Set Up an HVAC & AC Installation and Maintenance Company in Dubai, UAE: The 2026 Contractor Register & Tax

How to start an HVAC company in Dubai in 2026: why AC installation is a graded contracting activity under the new 2026 law, the separate Dubai Municipality approval for duct cleaning, the refrigerant and green-building rules, the Etihad ESCO retrofit market, and why the free-zone 0 percent tax pitch fails for on-site work.
Set Up an HVAC & AC Installation and Maintenance Company in Dubai, UAE: The 2026 Contractor Register & Tax

Expert-reviewed by BusinessDubai Business Setup Advisors. Written with guidance from licensed UAE company-formation consultants with 10+ years of experience, and fact-checked against official government sources before publishing. Last reviewed July 26, 2026.

An air conditioning company in Dubai sells something the climate makes non-negotiable, which is why the maintenance revenue is durable. But the trade licence is the entry ticket, not the business. HVAC installation and AC contracting is a regulated contracting activity, now governed by Dubai's new Contractor Register and grading regime under Dubai Law No. 7 of 2025, and your classification grade, not your licence, is what determines the size of work you can win [1][8]. A DET licence alone lets you exist, not bid a tower's chiller plant.

There is also a trap that catches AC operators specifically. AC duct cleaning is a separate Dubai Municipality approval, not something bundled into an installation or maintenance licence, so a firm that assumes its AC licence covers duct cleaning is operating an unapproved activity [1]. Add the refrigerant rules, the green-building standards and the fact that on-site work is inherently mainland, and the "just get a licence" version of this business does not exist.

This guide covers the contracting register that is the real gate, the separate duct-cleaning approval, the refrigerant and green-building rules, the retrofit market, ownership, and why the free-zone 0% pitch fails for on-site work. Since 2013, our team has set up contracting and regulated companies across the UAE, so the traps here come from real files. This is a guide, not legal or tax advice on your specific licence.

Why is an AC company a graded contractor, not a shop?

Because HVAC installation and MEP-related AC work is contracting, and Dubai now registers and grades every contractor. Dubai Law No. 7 of 2025 came into force on 8 January 2026, with a grace period to January 2027, and it created a unified Contractor Register maintained by Dubai Municipality, integrated with the Invest in Dubai platform, under which a contractor may not perform or market contracting activities without both a valid licence and registration in the register [1][8]. This is the biggest structural change in the sector and the thing most guides miss.

The part that reshapes the business is the grading. DM rates each contractor by technical expertise, financial strength and workforce, new entrants start in the lowest classification, and you must operate strictly within your grade and cannot bid work above your class [1][8]. Technical staff must be properly certified, with DM competency certificates and technician approval cards for mechanical work, and the register applies emirate-wide, including free zones. On top of the register, the conventional chain still applies: DET activity with DM external approval, MEP consultant sign-off for larger works, and DM building and completion approvals. The licence gets you in; the grade decides what you can win. Our construction guide covers the register in more depth.

Common Mistake: Treating an AC company as a trade you can start and scale on a licence alone. From January 2026 you also need registration and a classification grade in the DM Contractor Register, plus certified staff. The grade caps the value of work you can win, and new firms start at the bottom, so the licence alone does not let you market or perform contracting.

Why is duct cleaning a separate approval?

Because Dubai Municipality regulates AC duct cleaning as its own distinct activity, with its own approval. This is the trap that catches AC operators. An installation or maintenance licence does not automatically authorise duct cleaning; a firm must hold a separate Dubai Municipality approval as an approved AC duct cleaning company [1]. The requirements typically include DM technician approval cards, DM-approved cleaning and disinfectant chemicals, public-liability insurance, and, for commercial and institutional sites, Civil Defence registration where applicable.

The practical consequence is that installation, maintenance and duct cleaning sit in three different regulatory boxes. Installation is contracting under the register with DM permits and completion approvals. Maintenance is technical services, also on-site and mainland, covered by the contracting framework and technician cards. Duct cleaning is its own DM-approved activity. A firm that wants all three revenue streams needs all three approvals, and assuming one licence covers everything is how operators find themselves doing an unapproved activity. Confirm the current duct-cleaning approval thresholds and insurance minimums with Dubai Municipality.

Pro Tip: Decide your scope, installation, maintenance, and duct cleaning, before you apply, because they are separate approvals with separate requirements. A founder who wins a duct-cleaning contract on an installation licence has taken on work the licence does not authorise. Map the three activities to your business plan and secure the approvals you actually need. Get your HVAC setup scoped properly→

Technicians servicing an air conditioning unit

What are the refrigerant and green-building rules?

Federal refrigerant controls and mandatory green-building standards, both of which shape the work. On refrigerants, the UAE regulates ozone-depleting substances under the Montreal Protocol, so anyone importing or trading controlled refrigerants or equipment containing them must register with MoCCAE and obtain an import permit, import of used equipment using controlled substances is prohibited, and HCFC-22, R-22, is under phase-out, so new systems should use compliant refrigerants [2]. Hydrofluorocarbons are separately regulated under a 2023 MoCCAE decree with phase-down controls [3]. Confirm the specific technician refrigerant-handling certification recognised by MoCCAE and DM, rather than assuming a scheme name.

On green building, Dubai Municipality's Al Sa'fat green building system is mandatory for new buildings, which must meet at least the Silver tier, and it sets explicit requirements for HVAC optimisation, insulation and ventilation, so AC installers design and install to these standards on new-build work [1]. Beyond compliance, this is also where a revenue channel opens: Etihad ESCO, a DEWA subsidiary, drives the building-retrofit and energy-performance market under Dubai's demand-side strategy, targeting tens of thousands of buildings, and HVAC retrofits of chillers, air-handling units and controls are a core scope [6][7]. The rules are a constraint and, for a qualified contractor, a market.

Can a foreigner own an AC company, and does a free zone work?

You can own it fully on the mainland, but on-site work must be mainland. On ownership, 100% foreign ownership is available for AC and HVAC installation and maintenance activities on the mainland, eligibility being activity-code specific, so confirm the exact chosen code is on the 100% list at licensing [5]. Ownership is not the obstacle.

The free-zone question is firm: any on-site installation or maintenance work needs a mainland DET licence with DM external approval, because it is physical work at buildings across the mainland, and free zones are only appropriate for pure trading of AC units, import, wholesale and re-export of equipment [1][5]. A free-zone licence cannot lawfully deliver on-site installation or maintenance on the Dubai mainland. Because that split decides your whole structure, it is worth reading both routes before you commit: our mainland company setup page walks through the DET route an on-site AC contractor needs, while the free zone company setup page explains why a free-zone licence only fits pure trading of AC units and cannot authorise on-site installation, maintenance or duct cleaning. Our free zone versus mainland guide covers why on-site regulated work stays mainland, and our facility management guide covers the wider building-services market HVAC feeds into.

How is an AC company taxed?

Standard rates, and the free-zone 0% does not rescue on-site work. On corporate tax, the company pays 0% on taxable income up to AED 375,000 and 9% above, with Small Business Relief for revenue up to AED 3 million for tax periods ending on or before 31 December 2026 [4][5]. Our corporate tax filing guide covers the mechanics. On VAT, installation, maintenance and duct-cleaning services are standard-rated at 5%, with registration mandatory once turnover passes AED 375,000. Our VAT registration and compliance guide covers the detail.

The free-zone 0% is a trap for this business. A Qualifying Free Zone Person gets 0% only on qualifying income, and on-site installation, maintenance and duct cleaning performed on the Dubai mainland is non-qualifying income taxed at 9%, with no AED 375,000 cushion once QFZP status is engaged on that income [5]. A free-zone HVAC contractor servicing mainland sites cannot shelter that revenue at 0%, which reinforces that mainland licensing is the correct structure anyway, and full ownership is available on the mainland regardless.

Large industrial HVAC chiller and ductwork in a plant room

What does it cost, and is it worth it?

The licence is affordable; the staff, premises and classification are the real spend. Here is a realistic 2026 picture in AED, all figures approximate and worth confirming with DM and DET.

ItemTypical range (AED)
DET mainland trade licence (AC installation and maintenance)15,000 to 30,000 first year
Contractor Register classification (Law No. 7)New fee line, confirm current schedule with DM
Office or warehouse (Ejari, mandatory)15,000 to 40,000+ per year
Visas, per technician3,000 to 7,000 each
Tools, vehicle, recovery and charging equipment30,000 to 100,000+
Public-liability insurance5,000 to 20,000+ per year

A realistic all-in first year for a small mainland AC contracting and maintenance firm runs roughly AED 60,000 to 150,000 or more, scaling with headcount and classification ambitions. The demand case is unusually strong and climate-driven.

Quick Math: Extreme heat makes air conditioning non-discretionary year-round, the installed base is enormous and continuously needs servicing, and that converts into recurring annual-maintenance-contract income, the strongest reason maintenance beats one-off installs as a long-term play. On top of that sit a continuous construction pipeline of new HVAC installations under Al Sa'fat standards and a government-backed retrofit stream through Etihad ESCO's building-efficiency target. The demand is structural, not cyclical, which is what makes a well-run maintenance book valuable.

Is an AC company a good business in Dubai?

Yes, and the reason is the climate, not a trend. Cooling in Dubai is not a discretionary purchase a household or a landlord can defer, because for much of the year the building is unusable without it, so the demand under an AC company sits closer to a utility than to a nice-to-have service. That single fact, non-discretionary cooling in an extreme climate, is what makes the sector durable through every property cycle, and it is why a well-run AC firm holds value that a fashion-driven business does not.

Three demand streams stack on top of that base. The first is the enormous installed base of existing air conditioning across every tower, villa, warehouse and mall in the city, all of which needs servicing, cleaning and eventual replacement, and none of which switches off. The second is the recurring annual maintenance contract, the AMC, which turns that installed base into an annuity: a building signs a fixed-schedule servicing contract, pays a predictable annual fee, and renews year after year, so a maintenance book compounds instead of resetting to zero each January. The third is new work, split between the construction pipeline installing HVAC to Al Sa'fat green-building standards and the government-backed Etihad ESCO retrofit market, where a DEWA subsidiary is driving chiller, air-handling-unit and controls upgrades across tens of thousands of buildings under Dubai's demand-side strategy [6][7].

The three revenue lines are not equal, though, and the honest picture is that they differ sharply on how hard they are to enter and on how the money arrives. The table sets them side by side.

Revenue lineApproval neededRevenue shapeBarrier to entry
Installation (contracting)Contractor Register grade plus DM permitsLarge, lumpy, project-basedHigh, grade-capped for new firms
Maintenance (AMC)Contracting framework and technician cardsRecurring annuity, renews yearlyModerate, staff and reputation
Duct cleaningSeparate DM approvalRepeat service, contract-drivenSeparate approval, its own cards

Real Talk: The installation work looks the most impressive on a proposal, but it is the maintenance book that makes an AC company genuinely valuable, because recurring AMC revenue is predictable, renews on its own and does not depend on winning the next tender. New firms are capped by their Contractor Register grade for large installs anyway, so the early play that works is to build a dense maintenance and duct-cleaning book close to home while you climb the classification. Our mainland company setup page covers the on-site licence that all three revenue lines run on.

What documents and steps does it take to start an AC company?

A DET licence, DM external approval, and a Contractor Register classification, in that order, with certified technicians behind them. The paperwork is heavier than an ordinary trade licence because Dubai Municipality approves the activity and the people, not just the company, and because a new firm has to be classified before it can market or perform contracting at all [1][8]. A realistic document checklist looks like this.

  • Company documents: shareholder passport copies and photos, the reserved trade name, DET initial approval, the Memorandum of Association, and an Ejari tenancy for the office or warehouse.
  • Activity and approvals: the AC installation and maintenance activity on the DET licence, with Dubai Municipality external approval for the contracting activity.
  • Contractor Register: registration and classification in the DM Contractor Register under Dubai Law No. 7 of 2025, with the financial, technical and workforce evidence DM grades you on.
  • People: certified technicians with DM competency certificates and technician approval cards for mechanical work, plus the refrigerant-handling certification recognised by MoCCAE and DM.
  • Duct cleaning, if offered: the separate Dubai Municipality duct-cleaning approval, with its own technician cards, DM-approved chemicals and public-liability insurance.
  • Refrigerants, if importing: MoCCAE registration and an import permit for controlled refrigerants or equipment containing them.

The timeline is where founders underestimate the project, because the licence is quick and the classification and staffing are not.

StepTypical timeline
DET trade licence and initial approval1 to 3 weeks
DM external approval for the contracting activityAlongside the licence
Contractor Register registration and classificationThe main gating step, weeks
Certified technicians and DM approval cardsAlongside classification
Separate duct-cleaning approval, if offeredIts own DM process

Plan the classification and the technician cards first, because a licence with no grade cannot market or win contracting work, and a duct-cleaning contract taken on the wrong licence is unapproved work. Get your HVAC setup and timeline mapped→

What are the ongoing costs and compliance for an AC company?

Annual renewals, register upkeep, and the standard tax filings, all of which run for the life of the business. The DET licence and the Ejari renew every year, and on top of them sit the obligations specific to a contractor. The Contractor Register classification is not a one-time stamp: it carries renewal and periodic review, and climbing to a higher grade means continuing to prove financial strength, technical capacity and workforce, so the register is a running relationship with Dubai Municipality rather than a launch formality [1][8].

The technical staff carry their own recurring compliance. Technician approval cards and DM competency certificates renew, technicians who leave must be replaced with certified staff before they work, and the refrigerant-handling certification tied to MoCCAE controls must stay current. If the firm imports controlled refrigerants or equipment, the MoCCAE registration and import permits are an ongoing licence to trade, not a single approval, and if the firm offers duct cleaning, the separate Dubai Municipality duct-cleaning approval, its technician cards, approved chemicals and insurance all carry their own renewal cycle. Miss any one of them and that revenue line turns into unapproved work.

On tax, the company registers for corporate tax and files annually, paying 0% on taxable income up to AED 375,000 and 9% above, and registers for VAT once turnover passes AED 375,000, charging 5% on installation, maintenance and duct-cleaning services [4][5]. It also needs the usual establishment-card and visa renewals plus payroll under the Wages Protection System. These renewals, register reviews, permit upkeep and filings are exactly the recurring work our post-setup services handle, so the approvals stay live while you run the jobs. Budget for them from year one rather than treating them as an afterthought.

Can you open a corporate bank account for an AC company?

Yes, but expect the standard UAE onboarding, not an instant or fully remote account. A mainland AC company opens a corporate account with a local bank once the DET licence and, ideally, the Contractor Register classification are in place, and the bank runs full know-your-customer checks on the shareholders, the contracting activity and the expected turnover, usually requiring an in-person meeting with the licence and tenancy in hand [5]. There is no fully-remote account opening for a physical, on-site contracting business like this.

Practically, a clear plan helps the account move faster: the DET licence and DM approval, the register classification, a tenancy for the office or warehouse, and, where relevant, named contracts or a pipeline of maintenance work. Because a contracting and maintenance firm handles staged project payments, retentions and recurring AMC invoices, a proper payment and invoicing setup matters from the start, and getting the banking right early avoids cash-flow friction once the jobs and the technician payroll begin.

Based on our experience, the firms that clear onboarding without delay walk in with the licence, the DM approval, the register classification and a simple one-page picture of who the customers are and what the annual turnover looks like. A maintained minimum balance is normal, so treat it as working capital rather than a setup cost, and open the account early so the first invoices and payroll do not stall on a pending application.

Real Client Stories

The licence that could not bid the tower. A client set up an AC trade licence and tried to bid a large chiller-plant installation, then found that from 2026 he needed registration and a classification grade in the DM Contractor Register, and as a new firm he started in the lowest grade, which capped the work he could take. We built a plan to climb the grades. The classification, not the licence, set the ceiling.

The duct-cleaning contract on the wrong licence. A maintenance firm won a duct-cleaning contract assuming its AC licence covered it. Duct cleaning is a separate Dubai Municipality approval with its own technician cards, approved chemicals and insurance. We added the approval so the work was authorised. One licence does not cover all three activities.

The 0% that never applied. A client set up in a free zone expecting 0% corporate tax on his AC maintenance contracts. The income was on-site service at mainland buildings, non-qualifying and taxed at 9%, and a free-zone entity cannot lawfully do the on-site work anyway. We put the business on a mainland footing. The free-zone address was never going to make on-site income tax-free.

Set up your Dubai HVAC company the right way

HVAC rewards operators who treat the contractor register, the separate duct-cleaning approval and the refrigerant rules as the real business, and it traps those who stop at the trade licence. Since 2013, BusinessDubai.ae has completed 700+ company registrations across the UAE, including contracting and regulated companies. We will help you register and classify in the DM Contractor Register, secure the separate duct-cleaning approval if you need it, staff the certified technicians, plan the refrigerant and green-building compliance, structure the mainland company for on-site work, and set up the corporate tax and VAT position correctly, all with clear itemised pricing. Talk to a setup expert→ for a plan built around your scope. Our free zone versus mainland guide covers the structure choice, and post-setup services covers ongoing approvals and renewals.

Frequently Asked Questions

How do I start an HVAC company in Dubai?

Register a mainland DET licence with the AC installation and maintenance activity and DM external approval, register and classify in the DM Contractor Register under Law No. 7 of 2025, staff certified technicians, and secure a separate Dubai Municipality approval if you also want to offer duct cleaning. The grade, not the licence, decides the work you can win [1][8].

Is an AC company a contractor in Dubai?

Yes. HVAC installation and MEP-related AC work is a contracting activity, now governed by the DM Contractor Register and grading under Dubai Law No. 7 of 2025, in force 8 January 2026. A contractor may not perform or market contracting without a licence and register classification [1][8].

Does the 2026 contractor law apply to AC companies?

Yes. AC installation and maintenance falls under Dubai Law No. 7 of 2025, so an AC contractor must register in the DM Contractor Register and hold a classification grade, with new firms starting at the lowest grade, which caps the value of work they can take. The grace period runs to January 2027 [1][8].

Is AC duct cleaning a separate licence in Dubai?

Yes. Duct cleaning is a separate Dubai Municipality approval, not bundled into an installation or maintenance licence, requiring DM technician cards, DM-approved chemicals and public-liability insurance. A firm needs the specific duct-cleaning approval to offer that service [1].

What refrigerant rules apply to AC companies in Dubai?

The UAE regulates ozone-depleting substances under the Montreal Protocol, so importing or trading controlled refrigerants needs MoCCAE registration and permits, import of used equipment using controlled substances is prohibited, R-22 is under phase-out, and hydrofluorocarbons are separately regulated under a 2023 MoCCAE decree [2][3].

What is Al Sa'fat and how does it affect AC work?

Al Sa'fat is Dubai Municipality's mandatory green building system for new buildings, which must meet at least the Silver tier and set requirements for HVAC optimisation, insulation and ventilation. AC installers must design and install to these standards on new-build work [1].

What is the Etihad ESCO retrofit market?

Etihad ESCO, a DEWA subsidiary, drives Dubai's building-retrofit and energy-performance market under the demand-side strategy, targeting tens of thousands of buildings. HVAC retrofits of chillers, air-handling units and controls are a core scope, a government-backed demand stream for qualified contractors [6][7].

Can a foreigner own 100% of an AC company in Dubai?

Yes, for AC and HVAC installation and maintenance activities on the mainland under the post-2021 reforms, with no local partner. Eligibility is activity-code specific, so confirm the exact code is on the 100%-ownership list at licensing [5].

Can you run an AC company from a free zone in Dubai?

Only for pure trading of AC units, import, wholesale and re-export. On-site installation and maintenance at mainland buildings needs a mainland DET licence with DM approval, so a free-zone licence cannot lawfully deliver on-site AC work on the Dubai mainland [1][5].

Does a free-zone AC company get the 0% corporate tax rate?

No on its core work. On-site installation, maintenance and duct cleaning at mainland buildings is non-qualifying income taxed at 9%, with no AED 375,000 cushion once QFZP status applies to that income. Mainland licensing is the correct structure, and full ownership is available there anyway [5].

How much does it cost to start an AC company in Dubai?

A realistic all-in first year for a small mainland AC contracting and maintenance firm runs roughly AED 60,000 to 150,000 or more, scaling with headcount and classification ambitions, driven by the office or warehouse, visas, tools and vehicles, plus the register classification. The licence itself is a small part.

How is an AC company taxed in Dubai?

Corporate tax is 0% up to AED 375,000 of taxable income and 9% above, with Small Business Relief for revenue up to AED 3 million for tax periods ending on or before 31 December 2026. VAT on installation, maintenance and duct-cleaning services is 5% once turnover passes AED 375,000 [4][5].

What is the difference between AC installation and maintenance in Dubai?

Installation is contracting under the register with DM permits and completion approvals. Maintenance is technical services, also on-site and mainland, covered by the contracting framework and technician cards. Duct cleaning is a third, separately approved DM activity. A firm needs the approvals for each service it offers [1].

Why is AC maintenance a good business in Dubai?

Because cooling is non-discretionary in the climate, the installed base is enormous and continuously needs servicing, and that converts into recurring annual-maintenance-contract income. Maintenance is a stronger long-term play than one-off installs, on top of new construction and the retrofit market [6].

Do AC technicians need certification in Dubai?

Yes. Technical staff must be properly certified, with DM competency certificates and technician approval cards for mechanical work, under the contractor register regime. Refrigerant handling also ties to MoCCAE controls, so confirm the recognised technician certification with MoCCAE and DM [1][2].

What is an annual maintenance contract for AC?

A recurring contract under which an AC company services a building's cooling systems on a fixed schedule, giving predictable income. In Dubai's climate, with cooling essential year-round and a huge installed base, these contracts are the strongest reason maintenance beats one-off installations [6].

How long does it take to set up an AC company in Dubai?

The trade licence can be issued in weeks, but the DM external approval, the register classification and staffing certified technicians take longer and are the real timeline. Plan the classification and any duct-cleaning approval alongside the licence, since the grade governs what you can bid.

Do I need a warehouse for an AC company in Dubai?

Yes. A contracting and technical licence requires physical premises, typically an office and often a warehouse for equipment and spares, which is mandatory and a recurring cost. It is one of the main setup expenses alongside certified technicians and the classification [5].

Can I do both AC installation and duct cleaning?

Yes, if you hold both approvals. AC installation and maintenance is one activity under the contractor register, and duct cleaning is a separate Dubai Municipality approval with its own requirements. A firm that wants both revenue streams needs both, rather than assuming one licence covers the other [1].

What happens if I do contracting work above my grade?

It is prohibited and penalised. Under the DM Contractor Register a contractor must operate within its assigned classification and cannot bid or perform work above its grade, so a new firm in the lowest grade must climb by building capacity, staff and track record before taking on larger projects [1][8].

What documents do I need to start an AC company in Dubai?

Shareholder passports and photos, the reserved trade name and DET initial approval, the Memorandum of Association, an Ejari for the office or warehouse, the AC activity with Dubai Municipality external approval, Contractor Register classification under Law No. 7 of 2025, certified technicians with DM cards, and, if offered, the separate duct-cleaning approval. The classification and technician cards are the gating items [1][8].

What are the ongoing costs of running an AC company in Dubai?

Annual DET licence and Ejari renewals, Contractor Register renewal and periodic review, technician approval-card and competency-certificate renewals, MoCCAE refrigerant permits if you import, duct-cleaning approval upkeep if you offer it, corporate tax filing, VAT filing once registered, and staff visas and payroll under the Wages Protection System. These run for the life of the business, so budget for them from year one.

Can I open a corporate bank account for an AC company in Dubai?

Yes, with a local bank once the DET licence and ideally the Contractor Register classification are in place. Expect full know-your-customer checks on the shareholders and activity, an in-person meeting, the licence and tenancy in hand, and a maintained minimum balance. There is no fully-remote account opening for a physical, on-site contracting business [5].

How much recurring revenue can an AC maintenance contract generate?

An annual maintenance contract charges a building a fixed annual fee to service its cooling on a set schedule, and because it renews year after year it behaves like an annuity rather than a one-off sale. The value sits in the density and renewal of the book: a firm holding many AMCs has predictable, compounding income that does not depend on winning the next installation tender [6].

What grade does a new AC contractor start at in Dubai?

New firms start in the lowest classification in the Dubai Municipality Contractor Register, and that grade caps the value of contracting work they can bid or perform. Climbing requires building financial strength, technical capacity, workforce and a track record, which DM assesses at classification and review. This is why an early maintenance and duct-cleaning book, which is less grade-sensitive, is a practical way in [1][8].

What does the AC duct-cleaning approval require in Dubai?

The separate Dubai Municipality duct-cleaning approval typically requires DM technician approval cards, DM-approved cleaning and disinfectant chemicals, public-liability insurance, and, for commercial and institutional sites, Civil Defence registration where applicable. It is its own activity with its own requirements, so an installation or maintenance licence does not cover it. Confirm the current thresholds and insurance minimums with Dubai Municipality [1].

Do I need a MoCCAE permit to import AC units or refrigerant?

Yes, if you import or trade controlled refrigerants or equipment containing them, you must register with MoCCAE and obtain an import permit, and importing used equipment that uses controlled substances is prohibited. R-22 is under phase-out and hydrofluorocarbons are separately regulated under a 2023 MoCCAE decree, so plan around compliant refrigerants for new systems [2][3].

Should an AC company be mainland or free zone in Dubai?

Mainland, if you do any on-site installation or maintenance, because that physical work at buildings needs a DET licence with Dubai Municipality approval and cannot run on a free-zone licence. A free zone only fits pure trading of AC units, import, wholesale and re-export. On-site service billed to mainland buildings is also non-qualifying for the free-zone 0% rate, so mainland is the correct structure [1][5].

References

[1] Dubai Municipality, Al Sa'fat Dubai Green Building System: mandatory green-building requirements including HVAC, and the framework within which AC contracting and duct-cleaning approvals sit. Al Sa'fat green building system

[2] Ministry of Climate Change and Environment, permit to import ozone-depleting substances: registration and permits for controlled refrigerants and the prohibition on used equipment using controlled substances. MoCCAE ODS import permit

[3] Ministry of Climate Change and Environment, ministerial decree on the regulation of hydrofluorocarbons (2023): the HFC phase-down controls. MoCCAE HFC decree

[4] Federal Tax Authority, Small Business Relief and corporate tax. FTA Small Business Relief

[5] UAE Ministry of Finance, decision on Small Business Relief for corporate tax purposes, and the corporate-tax and free-zone framework: 0% to AED 375,000 then 9%, revenue up to AED 3 million through 31 December 2026, and on-site mainland service excluded from the free-zone 0% rate. Ministry of Finance Small Business Relief

[6] Etihad Energy Services Company, a DEWA subsidiary: building retrofit and energy-performance contracting. Etihad ESCO

[7] Emirates News Agency: Etihad ESCO completes Dubai's first energy-savings performance contract. WAM Etihad ESCO

[8] Al Tamimi and Company, new Dubai law regulating contracting activities (Law No. 7 of 2025): the DM Contractor Register and grading in force 8 January 2026. Al Tamimi contracting law

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