The MISA Licence Is Now Investment Registration

Most manufacturers ask about MISA too early. The first question is whether you need a Saudi entity at all, or whether an agent, a distributor or your existing route covers the work. Aramco Europe, for example, says you do not need a representative in Saudi Arabia to become an approved Aramco supplier. Work that out first. Then register if the answer is yes.

What changed

The Investment Law, issued by Royal Decree M/19 in August 2024, replaced the Foreign Investment Law of 2000 and came into force 180 days after publication, in February 2025. MISA says it replaced the licensing procedures with registration. Clyde & Co sets out what that means in practice: no MISA licence and no licence fees, one registration that can cover activities across several sectors instead of a separate licence for each, a National Investor Register that is now live, and an annual update of your registration details. MISA says existing investors have no additional requirements to comply with.

How you register today

• Register with MISA first. A foreign investor registers with the ministry before engaging in any investment. MISA's guide estimates 10 working days for registration.
• Pay the fee when asked. The current guide gives no fixed figure. The fee is set by the ministry on approval and must be paid within 15 business days of notice, or the registration is void. Ignore old fee figures from earlier editions of the guide.
• Issue your commercial registration. Once MISA notifies you that registration is complete, you issue the commercial registration.
• Get the licences your activity needs. Then you obtain licences from the other authorities that cover your activity. For a factory that includes an industrial licence.

The documents

For a regular registration, MISA's guide asks a foreign company for its commercial registration certified by the Saudi Embassy, with the parent company's registration attached if its nationality differs, its financial statements for the last fiscal year authenticated by the Saudi Embassy, and any requirements specific to the activity. Embassy certification takes time in your home country, so start it before you need it.

Which registration fits

MISA's guide lists several registration types. Three matter most to an equipment manufacturer:

• Regular registration. For an established Saudi entity.
• Temporary registration for a government contract. For a foreign company that has won a government or semi government contract and needs to deliver it. It ends when the contract ends.
• Regional Headquarters. A licence for a company running its regional headquarters from the Kingdom.

The guide also covers scientific and technical offices, economic and technical liaison offices, and entrepreneurial establishments.

Capital: manufacturing and trading are different

MISA's guide states no minimum capital for industrial activity. Trading is different. A fully foreign owned trading company needs SAR 30,000,000 of capital and a presence in at least three regional or global markets. With a Saudi partner holding at least 25%, the figure is SAR 26,666,667. Clyde & Co notes the capital minimums from the old regime still apply where relevant. So if your plan is to import and distribute your own range, price that in before you choose a structure. Many manufacturers are better served by a strong distributor.

The RHQ rule for government contracts

Since 1 January 2024, Saudi government agencies may not contract with companies that have no regional headquarters in the Kingdom, or with their related parties such as agents and distributors, except under set controls. Deloitte lists the exceptions: contracts below SAR 1 million, purchases carried out outside the Kingdom, tenders where yours is the only technically acceptable bid or the best technical bid at least 25% below the next, sole source or emergency cases, and approved exemptions. If government work is your target, this rule shapes your structure more than the registration does.

How it connects to Aramco and local content

Aramco's 2024 supplier booklet lists an investment licence from the Ministry of Investment among the documents for Saudi based suppliers owned fully or partly by a foreign investor. That wording predates the switch to registration. A manufacturer outside the Kingdom registers with Aramco through its regional affiliate instead, as the Aramco vendor registration guide explains. A Saudi entity also counts towards your local content, which feeds both government tenders and IKTVA. The Saudi local content guide covers that.

Registration is the easy part now. Deciding whether you need a Saudi entity, and what it should do, is the real decision.

Where I help, and where I do not

I am not a lawyer and I do not form companies. For the registration and the structure you need Saudi counsel. What I do is the commercial question that comes first: which buyers and contracts make a Saudi entity worth it for your product, whether a distributor or agent would serve you better, and how to get specified with Aramco, SABIC and the EPC contractors either way. Read Saudi Arabia and Aramco for the market itself.