Ministry of Commerce: Unlicensed Activities Will Be Struck Off the Commercial Register After 90 Days
On 1 November 2026, Saudi Arabia’s Ministry of Commerce reminded business owners of a deadline that is easy to miss: every activity listed on an establishment’s commercial register that needs a licence must be licensed within 90 days of the date it was added to the register. If the deadline passes without a licence, the activity is struck off the register.
Some headlines have described this as “licence cancellation”. That overstates it. The rule does not cancel the company or its whole commercial register. It removes the individual activity that was never licensed. For a company that has added several activities to its register, that can still mean losing activities it planned to rely on.
1. What the Rule Says
The Ministry’s reminder is based on Article 4 of the Implementing Regulations of the Commercial Register Law, part of the new commercial register framework that took effect on 3 April 2025. In summary:
| Situation | What Is Required Within 90 Days | If Nothing Is Provided |
|---|---|---|
| Activity that requires a licence (e.g. from a municipality or a sector regulator) | Obtain the licence to practise the activity | The activity is struck off the commercial register |
| Activity that does not require a licence | Provide evidence that the activity is actually being practised | The activity is struck off the commercial register |
The 90 days run from the date the activity was entered on the commercial register, not from the date the company was first established. An activity added to an existing register today starts its own 90-day clock.
Published versions of the Regulations also allow the registrar to extend the period, on its own initiative or at the trader’s request. The Ministry’s statement did not mention extensions, so they should not be assumed. If a licence is genuinely delayed with the licensing authority, raise it before the 90 days run out.
2. Why It Matters
Under the new framework, the commercial register is meant to reflect what a business actually does. Activities that are listed but never licensed or practised are now being cleaned out. In practice:
- Companies that listed many activities “just in case” at setup are most exposed. Any that were never licensed or practised can be removed.
- Foreign-owned companies often wait on more than one approval before they can start operating. The 90-day window can close while they are still waiting on another authority.
- Losing an activity has knock-on effects. Contracts, tenders, bank onboarding and other licences may assume that activity is still on your register.
3. Not to Be Confused With: the Annual Confirmation Deadline
The new Commercial Register Law also has a separate 90-day rule. Every commercial register has to be confirmed once a year, and a register whose annual confirmation is not filed within 90 days of its due date can be suspended. The two rules are independent:
| Activity Licensing (Implementing Regulations, Art. 4) | Annual Confirmation | |
|---|---|---|
| What it covers | Each individual activity on the register | The commercial register as a whole |
| Clock starts | Date the activity was added | Annual due date of the register |
| Consequence | That activity is struck off | The register can be suspended |
Both should be on your compliance calendar.
What Businesses Should Do Now
- List every activity on your commercial register and note the date each one was added.
- Mark each activity as licensed, licence-exempt or unlicensed, and check whether it needs a licence from a municipality or a sector regulator.
- Apply now for any missing licences, starting with activities added in the last 90 days.
- For licence-exempt activities, keep evidence that you actually practise them, such as invoices, contracts or other operational records.
- Remove activities you have no plan to use. A short register that you keep up to date is easier to manage than a long one full of activities you never use.
- Add both 90-day deadlines to your compliance calendar: the one for each new activity and the one for the annual confirmation.
For companies with several activities, or foreign-owned companies waiting on approvals from more than one authority, these deadlines are easy to lose track of. Beyond Borders’ PRO and compliance services include keeping track of commercial register and licensing deadlines, so you know where each activity stands before the 90 days run out.
Sources: Ministry of Commerce statement of 1 November 2026, as reported by Saudi Gazette, Okaz and Ajel; Commercial Register Law, official English translation. This article is for informational purposes only and does not constitute legal advice. Check the current text of the Regulations with the Ministry of Commerce before acting on it.