Saudi New Investment Law 2025: What Actually Changed | Khan Advisory
Saudi Arabia · Market Entry

The New Investment Law (2025): What Actually Changed

Saudi Arabia's 2025 Investment Law replaced the MISA licence with registration. What that shift actually changes for foreign investors — and what stays the same.

Khalid Khan Advisory·4 min read

For twenty-five years, entering Saudi Arabia as a foreigner meant obtaining a foreign investment licence — first from SAGIA, later from the Ministry of Investment (MISA). The 2025 Investment Law changes both the vocabulary and the mechanics of that first step. What it does not change is that there is a first step. Reading the reform correctly — what moved, what didn't — is the difference between a realistic entry plan and one shaped by the press release.

What the law is

The new Investment Law was issued by Royal Decree M/19 and came into force on 12 February 2025, replacing the Foreign Investment Law of 2000. It consolidates the regime, repositions MISA as the central gateway for foreign capital, and aligns the framework with Vision 2030's aim of treating Saudi Arabia as broadly open to investment rather than closed by default.

The headline change: licence becomes registration

Under the old model, a foreign investor applied for a foreign investment licence (the “SAGIA” or “MISA licence”) as a precondition to incorporating. Under the new model, the investor registers in the National Register of Investors and receives an Investment Registration Certificate. The posture shifts from permission-by-default to broadly permitted, subject to a defined list of excluded or restricted activities. In practice this has shortened MISA's review window and made entry more predictable.

Registration is not a trading licence. It lets you incorporate — it is not, by itself, authority to operate. You still need a Commercial Registration, a National Address, tax and social-insurance registration, and any sector approvals before you can actually trade.

What genuinely improved

  • Equal treatment of foreign and domestic investors is now enshrined in the law.
  • Core protections: fair treatment, protection against expropriation, and the free transfer and repatriation of funds.
  • Dispute resolution: investors may use arbitration and other alternative methods.
  • Faster, clearer procedures, with dedicated investor service channels.

What did not change

  • MISA is still the first gate — before Commercial Registration, banking or a single visa.
  • The excluded-activities (“negative”) list remains; some activities still require minimum Saudi participation or sector approval, and excluded ones may need an exceptional approval.
  • Activity-based capital expectations remain — including the high bar for trading.
  • Substance, Saudization, ZATCA compliance and annual renewals all still apply.
  • Company forms are still governed by the 2023 Companies Law.

What it means for your entry plan

Don't over-read the reform. It lowers friction at the front door; it does not remove the obligations behind it. Sequence and substance still decide whether a Saudi setup runs smoothly or stalls. The investors who benefit most treat registration as step one of a longer, deliberately designed sequence — not as the finish line.

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This article is general information, current as of 2026, and is not legal or tax advice for any specific situation. Saudi rules are changing quickly — confirm current thresholds and lists with MISA or local counsel before acting.