Lease Terms
IFRS 16 Lease Audit Working Paper Template & Checklist — free PDF
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IFRS 16.26 — At the commencement date, a lessee shall measure the lease liability at the present value of the lease payments that are not paid at that date.
IFRS 16.23–24 — At the commencement date, a lessee shall measure the right-of-use asset at cost.
ISA 500 — Sufficient appropriate audit evidence for the lease liability as independent audit evidence.
ISA 540 — Auditing accounting estimates — applies to the IBR determination and lease term judgment.
IFRS 16 in United Arab Emirates — IFRS 16 (as mandated by SCA / DFSA / ADGM)
The United Arab Emirates mandates IFRS for listed companies through the Securities and Commodities Authority (SCA) and for entities within the Dubai International Financial Centre (DIFC) through the Dubai Financial Services Authority (DFSA). Abu Dhabi Global Market (ADGM) entities also follow IFRS. IFRS 16 has been applicable since 1 January 2019. The UAE's lease landscape is characterised by short-term lease structures (particularly in Dubai, where one-year leases with annual renewal are common), limited tenant protection compared to European jurisdictions, and the absence of corporate income tax (until the introduction of federal corporate tax from June 2023).
Regulatory Context — Securities and Commodities Authority (SCA) / Dubai Financial Services Authority (DFSA)
The SCA has mandated IFRS adoption for entities listed on the Abu Dhabi Securities Exchange (ADX) and Dubai Financial Market (DFM). The DFSA requires IFRS for authorised firms within the DIFC. Regulatory focus on IFRS 16 has been less prescriptive than in European jurisdictions, but both the SCA and DFSA expect high-quality IFRS-compliant financial reporting. The UAE does not have a local accounting standard — IFRS is applied directly as issued by the IASB.
Practical Guidance for United Arab Emirates
For UAE entities, the IBR should reference AED market rates. The AED is pegged to the US dollar (1 USD = 3.6725 AED), so USD interest rates (SOFR, US Treasury yields) provide the base risk-free rate, adjusted for the AED-specific term premium and entity credit spread. For entities in Dubai, the Real Estate Regulatory Agency (RERA) governs residential leases through the Dubai Rental Law (Law No. 26 of 2007), which provides some tenant protections including rent increase limits. Commercial leases have fewer statutory protections, and one-year renewable leases are the market standard.
Audit Expectations
UAE audit firms registered with the SCA or DFSA follow ISA. Given the shorter average lease terms in the UAE compared to European markets, the IFRS 16 impact on UAE balance sheets is generally smaller. However, for entities with significant long-term leases (industrial facilities, land leases in free zones, master lease agreements), the calculations can be material. Auditors should focus on lease identification completeness and the assessment of renewal options for renewable leases.
United Arab Emirates-Specific Considerations
The introduction of UAE federal corporate income tax (effective for financial years starting on or after 1 June 2023, at a rate of 9% on taxable income exceeding AED 375,000) has created new considerations for IFRS 16. Under the corporate tax law, deductions are generally based on the accounting treatment in the financial statements. This means IFRS 16 depreciation and interest expense may form the deductible amounts rather than lease payments, though the implementing regulations may provide specific guidance. Free zone entities (which may benefit from 0% tax under qualifying conditions) should assess whether IFRS 16 treatment affects their qualifying income calculations.
Common Inspection Findings
IBR not appropriately benchmarked to AED/USD market rates
Short-term renewable lease assessment not documented — potential understatement of lease term
Free zone long-term land leases not identified in lease population
New corporate tax interaction with IFRS 16 not considered in deferred tax calculations
RERA rent cap regulations not reflected in lease payment projections