A filming permit inside a UAE free zone the government texts that do not agree

Article 2(2) of Cabinet Resolution No. 41 of 2025, the federal fee instrument, is the sentence everything turns on. The fee values shown in its attached schedules do not apply to media services provided in the free zones in the State, and Cabinet Resolution No. 39 of 2016 applies instead. What is disapplied is the value of the fees. Article 2(2) does not disapply the service list, does not remove the requirement to hold the permit, and does not say the service is free. The schedule it switches off carries AED 500 per day for a filming permit.

Cabinet Resolution No. 42 of 2025 applies to media activities within the State, including its free zones. Both were issued 16 April 2025, published in Official Gazette No. 798 of 29 April 2025, effective 29 May 2025, both Active. The same Cabinet, in the same Gazette issue, took its fee values out of the zones and put its penalties into them.

That is coherent, not a drafting error. Article 26 of the statute directs the Cabinet to specify fees for licences and permits; its Article 24 separately directs the Regulation of Violations and Administrative Sanctions. Two delegations, and a carve-out in one says nothing about the other.

Article 6(2) of the statute subjects free-zone licensees to oversight by the Competent Authority, its Article 22(2) gives the Council inspection of all media activities in the country including free zones, in those words, and its Article 22(3) requires the Competent Authority and free zone authorities to give the Council every licence and permit they issue. Across its fifteen English pages free zone occurs ten times, none in Article 23, 24 or 26. The National Media Authority publishes that it licenses media outlets within media free zones as it does those elsewhere.

Nothing in one zone's arrangement generalises to another, and the two financial free zones are the proof of that, not the exception.

DIFC publishes a sequence, and a landlord's contract at the end of it

DIFC publishes the sequence in its own words. All photography or videography within the Centre requires prior approval in order to obtain the necessary security permits when shooting. For commercial requests where production is involved, such as advertisements or films, it directs applicants to the Dubai Film and TV Commission Portal first, then to submit the DIFC request on receipt of that permit, and its form asks whether the applicant has applied for the Commission permit. It asks for a minimum of one working day for a response and addresses a request arriving after GST 3pm the following day, a response time on DIFC's own step rather than a fee or a lead time. Collection is in person at The Gate Building West Wing Reception.

What arrives is not a permit from a regulator. The consenting party throughout DIFC's photoshoot terms and conditions is DIFC Investments Ltd, and clause 4 of those terms requires the production to obtain, at its own expense, all consents, approvals and licences necessary in connection with the shoot. DIFC Marketing is named on the events page as issuer of the photoshoot and filming permits.

Neither DIFC service page publishes a fee, and its fee handbooks and legal database show zero occurrences of photograph, film or shoot on 29 August 2026. This is DIFC alone.

ADGM publishes a permit of its own, and asks for nothing outside itself

ADGM works the other way round, through an instrument rather than a service card. Its Commercial Permits Regulations (Entertainment and Events) Rules 2025, published 19 December 2025, define Photography at Rule 1(3) as any professional or commercial photography, including photoshoots, filming, or large equipment setup, in any public space or Event, and Premises in the same rule as any property within the geographical boundaries of the Abu Dhabi Global Market from where the Activity will take place, the only instrument read here tying a filming permission to a zone boundary in its own words. Rule 2 reaches every person conducting an Activity at the Premises, not only licensees or tenants; Rule 4 requires the permit first; Rule 5(2) admits an applicant with a commercial licence from a Competent Body plus a Temporary Commercial Permit, the visiting-crew case.

Schedule 1, Table 6 of ADGM's Commercial Permits Regulations (Fees) Rules 2025 prices an Activity (Photography) Permit at AED 500 per day, valid one day and extendable to a month. That is the same number as the federal per-day figure; nothing retrieved explains the coincidence and no relationship is inferred. Conducting the Activity without the permit may attract a fine not exceeding level 8 on the Fines Scale, which Schedule 1 of the ADGM Administrative Regulations 2025 sets at 1,000,000 US dollars: a discretionary ceiling in dollars, not a tariff.

Across those Rules, the Fees Rules Schedule 1, the letters and permits page, the temporary permits page and the portal page, all read on 29 August 2026, no ADGM text requires an emirate filming permit, a content approval or any Film Commission step. Behind the ACCESSADGM sign-in sits the application, not the terms.

In Abu Dhabi the zone regulator and the permit issuer are one body

twofour54 is a third category. It publishes that it secures visas, location permits and rebates as production services; every occurrence of the phrase filming permit across its 861 English pages read on 29 August 2026 describes a service it performs for a production rather than a permission it grants; and nothing on its host says whether a shoot inside twofour54 or Yas Creative Hub needs a permit separate from the emirate's, with no sequence, form, lead time or fee published for filming inside the boundary.

One legal person holds both jobs. The Creative Media Authority publishes eight services in the Creative Zone with no filming permit among them, and on a differently scoped page publishes that it issues permits for filming in Abu Dhabi. In Dubai those functions sit in two bodies. Across the Abu Dhabi Film Commission's permits and FAQ pages, both rendered in a real browser on 29 August 2026, the strings free zone, freezone, twofour54, ADGM and Creative Zone appear zero times, and its framework divides permission into public and private rather than inside a zone and outside one. The emirate's fees and clocks are in the Journal's article on the Abu Dhabi filming permit.

The Development Authority zones publish locations, not permission

On the 151 English pages of the Dubai Development Authority's website fetched on 29 August 2026, the authority for ten Dubai free zones publishes no filming, photography or videography permission, no form, no lead time and no fee. Of 308 occurrences of the word film, 150 are the identical footer link to the Commission. Read that beside its limit: more than 200 corporate and government services sit behind the axs platform's sign-in, which redirects to a login even in a real browser, leaving that catalogue unread.

The zones publish a place to shoot, not permission to shoot there. No filming or photography permission page appears in Dubai Media City's, Dubai Studio City's or Dubai Production City's sitemaps, TECOM Group's corporate site publishes no filming permit across 592 English pages, and Dubai Design District's FAQ says its views may be used by obtaining the necessary permits, naming no authority, form, fee or lead time.

A priced permitting counter does exist in those zones and does not carry filming. The Development Authority's event permit is scoped to its free zone areas, delivers in 3 working days, and prices a non-commercial permit at AED 500 and a commercial one at AED 5,000; its advertising permit runs AED 500 to AED 5,000 a year by signage type. Neither is a filming permit and nothing is inferred either way. The northern zones are in the Journal's article on filming permits north of Dubai.

DIFC's published instruction is to apply to the Commission first and to submit the DIFC request on receipt of that permit, so the second step cannot begin until the first finishes.

The same terms reach past the shoot day. Clause 7 of DIFC's photoshoot terms and conditions requires the final produced photos or film and any variants to be sent to DIFC Investments Ltd for approval, and clause 13 of those terms requires a credit to the Centre as the location on the end credits, its name and web address on hard copies and alongside online versions, at no cost to DIFC Investments Ltd, if requested in writing. A brand film cut to a six-second and a fifteen-second social edit may carry no end credits at all, so that is a published contractual obligation meeting an ordinary social deliverable set.

Our own delivery runs 1 to 2 weeks under AED 20,000, 2 to 4 weeks at 25,000 to 50,000, and 3 to 12 weeks at 60,000 and above, with post about a third of a job. A third-party approval sits inside that, and we have established no turnaround for the finished-film approval the DIFC terms require.

Covered elsewhere in this Journal: the Dubai filming permit, what a UAE filming permit costs, the federal filming authority, who may hold a permit, the advertiser permit and what the client owns at the end.

Our office is in a free zone. Do we still need the emirate filming permit?

Two published texts describe different answers and this article adopts neither. Article 2(b) of Dubai's Decree No. 66 of 2024 says a Development Authority-licensed entity needs no additional Media Council permit inside those zones, and never uses the word filming. Clause 1.1 of the Dubai Film and TV Commission's permit terms claims sole authority over all filming operations in the Emirate including the free zones. Neither text mentions the other. Ask both, in writing, before a schedule rests on either.

Is filming inside a free zone cheaper, or free?

Article 2(2) of Cabinet Resolution No. 41 of 2025 disapplies the values of its fees for media services provided in the free zones, and nothing beyond the values. The 2016 instrument it sends them to prices no ground, aerial or marine filming permit. We have established no fee for a filming permit covering a shoot inside a Dubai free zone, which is a statement about what we read rather than a reason to doubt a figure an authority quotes you.

We are shooting in DIFC. What does DIFC itself ask for?

Its published sequence is the Dubai Film and TV Commission permit first, then the DIFC request, and its form asks whether you have applied for it. It asks for a minimum of one working day for a response, with requests after GST 3pm addressed the following day, and collection is in person at The Gate Building West Wing Reception. The consent itself comes from DIFC Investments Ltd, on its own terms.

Does ADGM work the same way?

No, and that is the useful thing about it. ADGM publishes its own Activity (Photography) Permit at AED 500 per day under its Commercial Permits Regulations (Entertainment and Events) Rules 2025, applying to every person conducting the Activity on its Premises, and across the five ADGM documents read for this article it asks for nothing outside itself. Neither zone's arrangement tells you anything about the other's.

Does twofour54 issue a filming permit?

It publishes that it secures visas, location permits and rebates as a production service rather than as a permission it grants. Nothing on its host states whether a shoot inside twofour54 or Yas Creative Hub needs a permit separate from the emirate's, and it publishes no sequence, form, lead time or fee for filming inside the zone boundary.

Nothing we found answers the question for our zone. What now?

Three questions are returned open here rather than answered: whether a shoot inside a zone is a media service provided within a free zone, whether a per-shoot filming permit is one of the permits Article 2(b) of Decree No. 66 of 2024 spares, and whether Article 6(1)(B) of the statute binds a visiting production or only the zone's licensee. Each would be closed by a definition, a superseding instrument or a published reconciliation. Until one arrives, put the question to both bodies in writing and keep the answer.

The carve-out in the 2025 fee resolution takes away the fee values and nothing else, while the statute's scope, the Competent Authority's supervision, the Council's inspection, the zone authority's reporting duty and the whole 2025 penalty schedule reach into the zones. The instrument the zones are handed to is seven articles long, charges 10 per cent on four broadcast and print categories, and prices one filming permit, a foreign correspondent's, capped at six months. In Dubai a Ruler's Decree and the Commission's permit terms give two different answers to who signs a zone shoot, and neither mentions the other. One zone publishes a sequence, one publishes a permit of its own, and they point opposite ways. The questions the texts leave open are named rather than answered.