How to Open a Gold Trading Company in Dubai: Activity Selection + Compliance 

Walk through the Gold Souk in Deira on any Friday evening and you’ll see it: tourists haggling over 22-karat bangles, wholesalers loading bars into armoured vans, and shop owners checking live gold rates on three screens at once. Dubai didn’t earn the “City of Gold” nickname by accident. About 15% of the world’s physical gold passes through here every year, and in 2024, the UAE’s foreign trade in precious metals crossed AED 625 billion. That’s a 27% jump from the year before. 

So naturally, you’re thinking about getting in on it. But here’s where most people trip up: “gold trading company” means six completely different things depending on who you ask. A wholesale bullion dealer importing bars from South Africa has almost nothing in common with a jewellery retailer in Mall of the Emirates, a refinery producing Dubai Good Delivery bars, or a consultant advising investors on gold allocations. Each model needs different activity codes on the licence, different compliance systems, and different approvals. Pick the wrong activity codes at incorporation and your licence won’t actually cover what you want to do. 

This article walks you through the models, the jurisdictions, the compliance layers, and the approvals that most founders discover too late. 

All figures in this article are approximate. Service charges, consultation fees, legal advisory, document preparation, notary, attestation, PRO services, and government processing fees are additional and quoted separately. 

What this article covers: 

1. Choose your model before you choose your jurisdiction 

2. Where to register: DMCC, mainland, and other options 

3. Activity codes and why they matter more than you think 

4. Compliance: AML, responsible sourcing, and hallmarking 

5. VAT treatment for gold: it’s not as simple as 5% 

6. What you need before you apply 

7. How Consultycs helps 

1. Choose Your Model Before You Choose Your Jurisdiction 

Think of it like opening a restaurant. You wouldn’t sign a lease before deciding whether you’re running a fine-dining spot, a fast-casual chain, or a cloud kitchen. Same logic applies here. Most founders jump straight to “should I register in DMCC or on the mainland?” when the real first question is “what exactly will I be doing with gold?” That answer shapes everything: your jurisdiction, your activity codes, your compliance burden, your capital needs, and your team. 

Here are the main business models in the UAE gold sector, and they’re not interchangeable: 

Wholesale Bullion Trading 

You buy gold bars, ingots, and coins in bulk from miners, refineries, or other dealers, and sell to jewellers, manufacturers, banks, or other wholesale buyers. This is Dubai’s bread and butter, the activity that makes the city the world’s second-largest physical gold hub after Switzerland. You’ll need import/export capabilities, trade finance relationships, secure logistics, and strong AML controls because your transaction values are high and your supply chain likely touches conflict-affected regions. 

Jewellery Retail 

You sell gold jewellery to consumers: tourists, residents, wedding shoppers. This is the Gold Souk model. The compliance focus shifts toward hallmarking, consumer protection, accurate karatage labelling, and Dubai Municipality approvals. Your location matters enormously. Being in the Gold Souk or a high-traffic mall is a competitive advantage that a JLT office simply can’t replicate. 

Jewellery Manufacturing 

You design and produce gold jewellery, whether for your own retail or for wholesale distribution. This requires industrial facilities, not just an office. The Gold & Diamond Park, DMCC, and SAIF Zone all have manufacturing infrastructure. You’ll need additional approvals related to industrial operations, waste management, and potentially Dubai Municipality oversight for hallmarking your finished products. 

Gold Refining 

You take raw gold ore, scrap, or recycled gold and produce refined bars, ideally to Dubai Good Delivery or UAE Good Delivery standards. This is the most capital-intensive model, with the highest compliance requirements. UAE-based refineries like Emirates Gold and Al Etihad Gold operate under DMCC’s Responsible Sourcing Review Protocol, aligned with OECD due diligence guidance. There are currently around ten active gold refineries in the UAE, with three holding Dubai Good Delivery accreditation. 

Import/Export and Logistics 

You move gold across borders, sourcing from producing countries in Africa, South America, or Central Asia and routing through Dubai for refining, trading, or re-export. This model lives on customs documentation, trade finance, and supply chain due diligence. Dubai’s position between producer nations and consumer markets (India, China, Turkey) is what makes it work. 

Advisory and Consultancy 

You advise on gold investments, market trends, risk management, or supply chain compliance without physically handling gold. Lower capital, simpler licensing, but you still need to understand the regulatory perimeter because the line between “advisory” and “arranging deals” matters. 

The reason this matters so much at the start: your chosen model determines your activity codes on the licence, and those codes define what you can legally do. A wholesale trading licence won’t let you refine. A retail licence won’t let you export in bulk. And adding or changing activities later costs time and money. 

2. Where to Register: DMCC, Mainland, and Other Options 

Now that you know what you’re building, the jurisdiction question usually answers itself. It’s a bit like choosing between a shopping mall and a warehouse district. Each has its purpose, and putting the wrong business in the wrong spot creates friction you don’t need. Four main options exist for gold businesses in Dubai, each with distinct strengths. 

DMCC (Dubai Multi Commodities Centre) 

If the gold industry had a campus, DMCC would be it. Purpose-built for commodity trading with precious metals at its core, DMCC hosts over 2,500 member companies in the precious metals sector. They cover every link in the chain, from mining and assaying to trading, logistics, and jewellery manufacturing. 

DMCC offers customised licence activities covering bullion trading, precious metals trading, gold scrap and waste dealing, gold coins and medallions, semi-finished products, jewellery wholesale and retail, manufacturing, refining, advisory, and more. The ecosystem includes the DMCC Vault (operated by Brink’s, five levels below ground at Almas Tower), the Dubai Gold & Commodities Exchange (DGCX), and DMCC Tradeflow for digital trade finance and commodity registration. 

Entity structures available include FZE (single shareholder), FZCO (multiple shareholders), and branches of existing companies. Full foreign ownership is standard with no local sponsor required. DMCC also operates a dual licensing arrangement that allows free zone companies to establish a mainland branch through the Department of Economy and Tourism, bridging the gap between free zone benefits and local market access. 

On tax: DMCC entities may qualify for Qualifying Free Zone Person status, potentially providing 0% corporate tax on qualifying income. Standard 9% UAE corporate tax applies on profits above AED 375,000 for non-qualifying income. 

Dubai Mainland (DET/DED) 

Want to sell jewellery directly to customers walking past your shop window? Then mainland is where you need to be. If your model is retail-facing, particularly jewellery sales in the Gold Souk, shopping malls, or any physical storefront accessible to the public, a mainland licence from the Department of Economy and Tourism is the standard route. Mainland companies can trade anywhere in the UAE without geographic restrictions and can bid on government contracts. 

Since the amendments to the Commercial Companies Law (Federal Decree-Law No. 32 of 2021), 100% foreign ownership is permitted across most business activities on the mainland. The old requirement for a 51% local sponsor has been removed for trading activities including gold. Some older online sources still reference the local sponsor requirement, but it is largely no longer applicable for gold trading. 

Mainland gold trading licences require a physical office (not a flexi-desk), and gold retailers need SIRA (Security Industry Regulatory Agency) approval. SIRA inspects the premises for security compliance: CCTV, surveillance systems, and in some cases, trained security personnel. 

Gold & Diamond Park (GDP) 

If you want to make jewellery and sell it from the same location, GDP is worth a close look. Governed by the Jebel Ali Free Zone Authority, it’s a hybrid retail-plus-manufacturing ecosystem on Sheikh Zayed Road, designed specifically for the jewellery and precious metals industry. It comes with equipped manufacturing units, a retail centre, and warehousing. The real kicker is the on-site Dubai Municipality hallmarking facility, which is a serious operational advantage for manufacturers and retailers who need purity certification. You get your pieces hallmarked without shipping them across town. 

SAIF Zone (Sharjah Airport International Free Zone) 

SAIF Zone is the budget-friendly option that still packs a punch. It hosts around 20 gold refineries and processing units, with proximity to Sharjah International Airport for logistics. Lower setup costs and affordable warehousing make it attractive for traders who prioritise operational efficiency over the DMCC brand ecosystem. 

Quick Comparison 

In short: DMCC suits wholesale bullion traders, international trading houses, refineries seeking Dubai Good Delivery, and businesses wanting access to the DGCX and Tradeflow ecosystem. Mainland suits retail jewellers targeting local consumers, Gold Souk operators, and anyone needing unrestricted UAE market access. Gold & Diamond Park suits manufacturers with retail ambitions. SAIF Zone suits refining and cost-conscious trading operations. 

3. Activity Codes and Why They Matter More Than You Think 

Here’s an analogy that might save you a headache. Activity codes on your trade licence are like the menu on a restaurant licence. Just because you’re licensed to serve food doesn’t mean you can also serve alcohol. Similarly, just because you have a “gold trading” licence doesn’t mean you can manufacture jewellery, run a refinery, or retail to consumers. Every activity needs to be explicitly listed. 

Your trade licence carries specific activity codes that define what your company can legally do. Gold-related activities are not one-size-fits-all, and the wrong selection limits your operations, sometimes in ways that only become obvious after you’ve signed supplier contracts or customs declarations. 

In DMCC, the main gold-related activity categories include trading in gold and precious metals (wholesale), gold bullion trading, gold coins and medallions, gold scrap and waste, semi-finished gold products, jewellery wholesale and retail, jewellery manufacturing and designing, refining and assaying, precious stones and metals trading (broader scope including silver, platinum, and diamonds), and advisory and consultancy on gold markets. 

On the mainland, the DET activity list includes gold trading (physical forms: ingots, bullion, biscuit, any shape), jewellery retail trading, jewellery manufacturing, precious metals trading, gold import and export, and various supporting activities. 

The critical distinctions that trip up founders are worth spelling out. Trading does not cover manufacturing. If you want to produce jewellery, you need a manufacturing or industrial activity code, not just trading. Wholesale does not cover retail. Selling to end consumers requires retail-specific activities. Import/export may need to be explicitly listed, because depending on your jurisdiction, international trade may require separate activity codes or approvals. Adding activities later is possible but not free. Amendment fees range from AED 1,000 to AED 3,000 per addition in most jurisdictions, and some changes require additional approvals that take weeks. 

The practical advice: map out your full value chain at the outset. Not just what you plan to do in month one, but where the business is heading in twelve to eighteen months. Include adjacent activities you might need. It’s cheaper and faster to register broad upfront than to amend narrow later. 

4. Compliance: AML, Responsible Sourcing, and Hallmarking 

Let’s talk about the part that separates serious gold businesses from the ones that get shut down. Gold is one of the highest-risk commodities for money laundering and terrorism financing. It’s portable, high-value, easy to melt down, and hard to trace once it changes form. The UAE takes this very seriously. The regulatory framework is dense, the penalties are real, and enforcement has tightened significantly since the UAE’s FATF Mutual Evaluation. 

AML/CFT Obligations 

Gold traders are classified as Dealers in Precious Metals and Precious Stones (DPMS), which are Designated Non-Financial Businesses and Professions (DNFBP) under the UAE’s AML/CFT framework. The Ministry of Economy supervises DPMS across the country, including those in commercial free zones. 

Under Federal Decree-Law No. 20 of 2018 (as amended by Federal Decree-Law No. 26 of 2021), gold trading companies must implement customer due diligence policies and procedures, conduct ongoing monitoring of business relationships and transactions, file Suspicious Transaction Reports with the UAE Financial Intelligence Unit, maintain transaction records for at least five years, appoint a compliance officer responsible for AML/CFT implementation, and conduct regular staff training on AML/CFT obligations. 

The AED 55,000 threshold is critical: DPMS are subject to DNFBP requirements for any single cash transaction, or several apparently related transactions, equal to or exceeding AED 55,000. Above this threshold, full customer identification and verification apply. 

Administrative penalties for non-compliance range from AED 50,000 to AED 5,000,000 per violation. In serious cases, authorities can ban individuals from the sector and pursue criminal proceedings. 

Responsible Sourcing and Supply Chain Due Diligence 

This is where Dubai’s gold compliance goes well beyond standard AML. Think of it this way: AML asks “is this money clean?” Responsible sourcing asks “where did this gold actually come from, and did anyone get hurt along the way?” 

The UAE has implemented a responsible sourcing regime aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. 

At the DMCC level, the Rules for Risk Based Due Diligence in the Gold and Precious Metals Supply Chain apply to all DMCC members dealing in gold. For refineries, compliance is even stricter. The Dubai Good Delivery (DGD) standard, now being superseded by the UAE Good Delivery (UAEGD) standard and requires accredited refineries to undergo independent third-party audits confirming compliance with DMCC’s Practical Guidance and Review Protocol for responsible sourcing. 

At the federal level, Ministerial Decree No. 68 of 2024 on responsible sourcing of gold expanded these obligations beyond refineries to all precious metals dealers. The decree follows the OECD’s five-step due diligence framework: establish strong company management systems, identify and assess supply chain risks, design and implement a strategy to respond to identified risks, carry out independent third-party audits, and report annually on supply chain due diligence. 

This is not optional. It is mandatory for all gold trading businesses operating in the UAE, in both mainland and free zones. The Ministry of Economy requires annual audit reports and has enforcement powers under the AML/CFT legislation. 

If your supply chain touches Africa, Central Asia, or South America, and most Dubai-based gold supply chains do, expect enhanced due diligence requirements. Conflict-affected and high-risk area sourcing triggers the full OECD framework, including red-flag identification, risk mitigation plans, and detailed record-keeping of origin documentation. 

Hallmarking and Purity Standards 

Ever notice the tiny stamp on the inside of a gold ring from Dubai? That’s a hallmark, and it’s not decorative. It’s your proof that the gold is genuine, correctly labelled, and meets UAE purity standards. Every piece of gold jewellery sold in Dubai must carry one. 

Hallmarking is overseen by the Dubai Central Laboratory Department (DCLD), part of Dubai Municipality, and operates under Federal Law No. 11 of 2015 concerning monitoring trade in precious metals and precious stones. 

The hallmark contains the fineness mark indicating purity (999 for 24-karat, 916 for 22-karat, 875 for 21-karat, 750 for 18-karat), the manufacturer’s stamp, and the assay mark proving government testing. Gold in Dubai is typically traded at 18, 21, 22, and 24 karats. 

The Bareeq Certification system ensures purity standards for gold sold in the UAE. Dubai Municipality conducts unannounced inspections of retail outlets, calibrates weighing scales to milligram accuracy, and checks compliance with labelling requirements. The compliance rate across inspections is reported at approximately 98%. 

For bullion and bars: the Dubai Good Delivery and UAE Good Delivery standards set the benchmark for quality and technical specifications in refining and production. Accredited refineries include Emirates Gold DMCC, Al Etihad Gold Refinery DMCC, and Sam Precious Metals, among others. 

If you’re a retailer or manufacturer, don’t treat hallmarking as a bureaucratic afterthought. It is your product’s quality guarantee and your legal protection. Selling unhallmarked gold jewellery in Dubai is a violation that attracts fines and reputational damage. 

SIRA Approval (Mainland Businesses) 

For mainland gold trading companies, SIRA (Security Industry Regulatory Agency) approval is required, particularly for businesses handling physical gold. SIRA inspects premises for security compliance, which typically includes advanced CCTV and surveillance systems, secure storage facilities, and in some cases, trained security personnel. This approval is obtained before the licence is issued and is a prerequisite for any gold business operating on the mainland with a physical presence. 

5. VAT Treatment for Gold: It’s Not as Simple as 5% 

Here’s where a lot of gold businesses get caught off guard. You’d think VAT on gold is just 5% across the board. It’s not. The treatment depends on what kind of gold you’re selling, who you’re selling it to, and whether both parties are VAT-registered. Get this wrong and you’re looking at FTA audits and denied VAT recovery. 

Investment Gold: Zero-Rated 

Gold of at least 99% purity (typically 24-karat bars and coins) in a form tradable on international bullion markets is zero-rated for VAT purposes. This means no VAT is charged at the point of sale in qualifying business-to-business transactions. However, businesses can still claim input tax on related costs such as transport, storage, and security. 

Zero-rating is conditional: the gold must meet purity requirements, must be in a tradable form, and the transaction must be between VAT-registered businesses. Individual consumers buying investment bars from a retail counter generally pay 5% VAT unless the dealer structures the transaction correctly. 

Jewellery and Non-Investment Gold: 5% VAT 

All gold jewellery (18K, 21K, 22K) and non-investment gold items are subject to the standard 5% VAT on the full invoice value, including gold weight, making charges, and design fees. There is no exemption for jewellery, regardless of purity or value. 

Reverse Charge Mechanism: February 2025 Onwards 

From 25 February 2025, Cabinet Decision No. 127 of 2024 expanded the reverse charge mechanism to qualifying business-to-business transactions in precious metals, including gold, silver, platinum, palladium, and jewellery where the precious metal is the dominant value component. 

Under reverse charge, the supplier does not charge VAT on the invoice. Instead, the buyer accounts for VAT in their own VAT return. This improves cash flow significantly for wholesale gold traders handling high-value transactions. Instead of funding VAT upfront and waiting for a refund, the tax is self-assessed. 

Conditions for reverse charge: both buyer and seller must be VAT-registered, the buyer must provide a written declaration confirming the purchase is for resale or manufacturing, both parties must verify and retain each other’s Tax Registration Numbers, and if conditions are not met, the supplier must charge and remit VAT normally. 

VAT Credit Time Limit: January 2026 

From 1 January 2026, VAT credits arising from zero-rated and reverse-charged transactions must be refunded or used within five years from the end of the relevant tax period. Gold traders and exporters who regularly operate in VAT refund positions should monitor VAT credit ageing and submit refund applications on time to avoid permanent loss of recoverable VAT. 

Practical Implications 

Get your VAT registration right from day one. Even if your transactions are zero-rated or reverse-charged, they count as taxable supplies for registration purposes. Your invoicing system must distinguish between investment-grade gold, jewellery, and retail sales, because different VAT rules apply to each. Records must comply with Article 59 of the VAT Executive Regulations, and you’ll need to show clear audit trails for every transaction. 

6. What You Need Before You Apply 

This is the checklist that saves you from the “I wish someone had told me” moment three months into the process. Every item here should be sorted, or at least in motion, before you submit your application. 

Business Model and Activity Selection 

Document your intended activities in detail. Map them to specific activity codes in your chosen jurisdiction. Include adjacent activities you’ll need within the first eighteen months. This exercise shapes your entire application. 

Entity Structure 

Choose between FZE, FZCO, branch, or LLC depending on your shareholder structure and jurisdiction. For DMCC, single shareholders typically use FZE; multiple shareholders use FZCO. For mainland, LLC is the standard structure, now available with 100% foreign ownership for gold trading activities. 

Physical Office 

All gold trading jurisdictions require a physical office. Flexi-desks may work for some DMCC advisory activities, but trading, manufacturing, and retail all require dedicated premises. For mainland businesses, your office must pass SIRA security inspection before licence issuance. Budget for CCTV, secure storage, and potentially a safe or vault depending on your business model. 

AML/CFT Framework 

You need documented AML/CFT policies and procedures before you start operating, not after. This includes customer due diligence procedures, transaction monitoring protocols, suspicious transaction reporting mechanisms, record-keeping systems, a designated compliance officer, and staff training plans. Most jurisdictions expect to see your AML framework as part of the application or immediately after licence issuance. 

Responsible Sourcing Policies 

If your business involves physically handling gold (trading, importing, refining, or manufacturing), you’ll need responsible sourcing policies aligned with the OECD five-step framework and DMCC’s Practical Guidance (for DMCC members) or the Ministry of Economy’s Due Diligence Regulations (for all UAE gold businesses). 

Banking 

Open conversations with banks early. Gold trading companies face enhanced due diligence from banks because precious metals are classified as a high-risk sector. Banks will want to see your business plan, AML/CFT framework, source of funds documentation, supplier and customer profiles, and evidence of regulatory licence or in-principle approval. Banks frequently used by DMCC gold trading companies include Emirates NBD, Mashreq, ADCB, and newer digital options like Wio and Zand. 

Key Personnel 

For DMCC, you’ll need a Secretary/Authorised Signatory. For larger operations, a Compliance Officer is effectively mandatory given AML/CFT requirements. For mainland operations, your compliance officer and any staff handling customer-facing transactions need to understand AML obligations and the AED 55,000 cash transaction threshold. 

Customs and Trade Documentation 

If you’ll be importing or exporting gold, familiarise yourself with customs declaration requirements, Dubai Customs processes, and any additional permits needed for cross-border precious metals trade. DMCC offers a single-window clearance system that simplifies this for free zone members. 

7. How Consultycs Helps 

Gold trading setup has more moving parts than most founders expect. Activity codes, jurisdiction selection, SIRA approvals, AML frameworks, responsible sourcing policies, banking, VAT registration. Consultycs works with gold trading founders at the planning stage, before the wrong activity code gets locked into a licence or the AML framework becomes an afterthought. 

Activity mapping and jurisdiction selection. We match your business model to the right activity codes and jurisdiction. Whether you’re a wholesale bullion dealer best suited to DMCC, a retailer heading to the mainland, or a manufacturer evaluating Gold & Diamond Park versus SAIF Zone, we lay out the options with realistic cost and timeline expectations. 

Entity structuring and incorporation. FZE, FZCO, LLC, or branch. We handle the paperwork, shareholder documentation, trade name approval, and registration with the relevant authority. 

Licence application and approvals. From DET initial approvals and SIRA security clearances to DMCC registration and activity code selection, we manage the application process and coordinate with regulatory authorities. 

AML/CFT and responsible sourcing compliance. We help build your compliance framework: policies, procedures, record-keeping systems, and staff training, all aligned with UAE AML/CFT legislation and OECD responsible sourcing standards. 

Banking introductions. We connect you with banks experienced in onboarding gold trading companies and help prepare the documentation package that gets accounts opened. 

Ongoing compliance support. Annual audit coordination, VAT compliance guidance, regulatory updates, and licence renewals, so your compliance doesn’t fall behind after incorporation. 

Frequently Asked Questions