The Foreign Capital Investment Law, Royal Decree 50/2019, did something more significant than raise a ceiling. It inverted the legal default. Before it, foreign ownership was capped unless you obtained an exemption. Since January 2020, foreign ownership is permitted unless your specific activity is prohibited.
The list has moved three times — plan for it to move again
Most articles present the negative list as a fixed thing established once and amended once. It is not. As best we can reconstruct from the ministerial decisions and contemporary reporting:
| Instrument | When | What it did |
|---|---|---|
| Ministerial Decision 209/2020 | December 2020 | Established the list. Reported at the time as 70 activities. |
| Ministerial Decision 364/2023 | June 2023 | Amended it — removed some activities, added others, mostly agriculture and food |
| Ministerial Decision 435/2024 | Aug/Sept 2024 | Added 28 activities, bringing the total to 123 |
The intermediate total after the 2023 amendment is reported as both 95 and 96 by different outlets, and the arithmetic does not cleanly reconcile with the additions and removals we could identify. The current total of 123 is well corroborated across many independent sources; the historical steps are less certain.
Sources also disagree on whether MD 435/2024 took effect on 28 August or 1 September 2024 — likely a conflation of issuance, gazette publication and effective dates.
The practical lesson is not to memorise a number. It is to check your specific activity code on the Oman Business Platform on the day you file.
What is actually on the list
The restricted activities cluster around traditional crafts, small-scale retail, and personal services — the parts of the economy where the policy intent is clearly to protect Omani small business rather than to control strategic sectors.
Recurring categories
- Traditional crafts and heritage products — Omani halwa, khanjar daggers, the kummah cap, traditional textiles and tailoring including abayas and military uniforms, silver, copper and pottery handicrafts
- Vehicle services — electrical repair, battery charging, tyre and radiator repair, car washing, oil changing, air-conditioning repair, towing
- Retail and wholesale — grocery stores, fruit and vegetable shops, fuel stations and LPG retail, mobile phone accessories, flower shops, honey and dates trading, animal feed, scrap metal
- Transport and logistics — Hajj pilgrim transport, gas cylinder trucking, cargo loading and unloading, customs clearance, vehicle recycling
- Personal and professional services — labour recruitment agencies, real estate brokerage, valuation and property management, driving schools, hairdressing, laundry (except within licensed tourist establishments), elderly care, public scribe services
- Agriculture and fisheries — poultry hatcheries and slaughtering except at industrial scale, beekeeping, marine fishing, freshwater aquaculture, plant nurseries
The 28 added in 2024
This group is the most reliably documented, reported consistently across three independent outlets: distilled flower and herb handicrafts, frankincense water and oil production, leather, palm-leaf, wood and bone handicrafts, traditional cosmetics and perfume production, pottery and ceramics, stone and gypsum handicrafts, silver, copper and aluminium handicrafts, incense production, skin-care services, event and furniture rental, construction scrap materials retail, drinking water retail excluding production and transport, plant cultivation and nurseries, used vehicle sales, mobile cafés, freshwater aquaculture, mailbox rental, public scribe services, sand service centres, LPG filling station operation, used battery and oil collection, and grocery stores.
The sector regulators that sit on top
This is the part that catches sophisticated investors out. Clearing the negative list means MOCIIP will register you. It does not mean the sector regulator will license you.
Article 2 of the Foreign Capital Investment Law explicitly preserves other legal regimes, so banking, insurance, telecommunications and hydrocarbons each operate a parallel layer of licensing conditions administered by their own authority — the Central Bank of Oman, the Financial Services Authority, the Telecommunications Regulatory Authority. A business can be 100% eligible under the FCIL and still be capped or conditioned by its regulator.
What is well established: banks in Oman must be structured as public joint stock companies, and licensing sits with the Central Bank under the new Banking Law, Royal Decree 2/2025.
We could not verify specific foreign-ownership percentage caps for banking, insurance or telecoms. One consultancy site quotes 15%, 25% and 35% tiers for banking under Royal Decree 2/2025, but neither Trowers & Hamlins nor CMS mention ownership caps at all in their detailed analyses of that decree. For insurance and telecoms we found no percentage cap in any source.
If you are entering a regulated sector, the ownership question has to be put to the regulator directly. Do not assume the FCIL answer is the whole answer.
GCC nationals are on a different track entirely
Article 2 of the Foreign Capital Investment Law carves out and preserves Royal Decree 57/93, the Provisions Governing Gulf Investment. GCC nationals' company ownership rights in Oman are therefore not governed by the FCIL negative-list framework at all, but by that separate, older decree implementing Oman's obligations under the GCC Unified Economic Agreement.
Historically this has meant GCC nationals are treated substantially as Omanis for commercial ownership purposes, including access to sectors closed to other foreign investors — a distinction that long predates the 2019 reform. We were not able to obtain the substantive text of RD 57/93, so we will not assert exactly how far the equivalence runs. If you hold GCC nationality, this is worth establishing precisely, because it may make the entire negative list irrelevant to you.
Free zones and special economic zones
Article 2 of the FCIL also states that its provisions do not prejudice the royal decrees governing the Duqm special economic zone, the industrial estates, and the free zones. Those zones operate under their own legal regimes, and Royal Decree 38/2025 now gives 100% foreign ownership in them the status of a statutory right rather than a policy concession.
What we could not establish is whether a specific negative-list activity — a grocery store, say — remains barred to a foreign investor *inside* a free zone, or whether the zones are wholesale carve-outs. Every source we found addresses this at the headline level only. If your activity is on the list and you are considering a zone as a workaround, get that confirmed by OPAZ before committing.
Grandfathering, and the trap on the way out
If you were lawfully operating in an activity before it became restricted, you may continue. Both MD 209/2020 and MD 435/2024 carry that protection.
But read the second half of the clause. Ownership in that business cannot be transferred without written approval from the Minister. The protection attaches to you as the existing operator, not to the asset.
It means your exit is discretionary. A share sale, a restructuring, or bringing in a new foreign investor all require a ministerial approval that is not guaranteed. If your business is in a grandfathered restricted activity, factor that into your valuation and your exit planning now, rather than discovering it when a buyer appears.
This is rarely mentioned in company-formation marketing, for obvious reasons.
The penalty for getting it wrong
Article 33 of the Foreign Capital Investment Law is unambiguous: a fine of not less than OMR 20,000 and not more than OMR 150,000 for any foreigner undertaking investment activity in violation of the law.
Note that the same penalty extends explicitly to an Omani national who unlawfully fronts for a foreigner. The informal arrangement where an Omani holds a licence on paper while a foreigner runs the business is not a grey area — it exposes both parties to the same fine.
Capital: the OMR 150,000 that no longer exists
There is no minimum capital for an LLC or an SPC. The figure of OMR 150,000 that still circulates comes from the 1994 Foreign Capital Investment Law, where it was the general company capital minimum, with OMR 500,000 required for projects seeking full foreign ownership. Royal Decree 50/2019 repealed that law outright.
Sources disagree on the exact ownership ceiling under the old regime — 49% rising to 70% after Oman's 2002 WTO accession in most accounts, but at least one credible legal digest describes a minimum 55% local participation. Both figures may have applied at different times or to different company types. What matters today is that none of them apply.
One Omani employee — a 2025 rule that is not an ownership rule
Ministerial Decision 411/2025, issued around late October 2025, added Article 12 bis to the Executive Regulations of the Foreign Capital Investment Law. Every foreign-owned company must employ at least one Omani citizen, registered with the Social Protection Fund, within its first year of commercial activity. Companies already trading for a year or more must comply within six months of whichever comes first: CR renewal, first work permit issuance, or work permit renewal.
This is an employment requirement, not an equity requirement, and the distinction matters. You do not need an Omani shareholder. You do need an Omani on the payroll, properly registered. The two get conflated constantly, including by people selling company formation services.
Can a foreigner own 100% of a company in Oman?
Which business activities are closed to foreign investment in Oman?
Can a foreigner own a grocery shop in Oman?
Do you need an Omani partner to set up a company in Oman?
Is there a minimum capital requirement for a foreign-owned company in Oman?
Can I sell a business that operates in a restricted activity in Oman?
Reported consequences of non-compliance are administrative rather than monetary — blocked transactions on the Oman Business Platform, inability to renew the CR or work permits. The Labour Law separately provides a fine of not less than OMR 500 per unfilled Omani position, though we could not confirm that this is the specific enforcement mechanism for Article 12 bis.