UBO Declaration and Register

Every mainland and non financial free zone company must keep a real beneficiary register and keep it current. Most keep it once and never touch it again.

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Cabinet Decision 109 of 2023 on the regulation of the real beneficiary procedures came into force on 16 November 2023, replacing Cabinet Decision 58 of 2020, and it reaches corporate entities on the UAE mainland and in the non financial free zones. It requires each of them to keep a register of its real beneficiaries and a register of its partners or shareholders, to file the information with its licensing authority, and to keep both current. Companies usually do this once at incorporation and then stop. The obligation is continuing, so a share transfer, a new shareholder, a change of manager or a restructure upstream all have to flow into the register. Where ownership sits behind a holding company in another country, working out who the real beneficiary is takes more than reading the local licence.

Abstract geometric line drawing: an ownership tree of three tiers narrowing to a single node at the top, that node in teal, gold hairlines on dark navy.

Key Features

The real beneficiary identified properly through the ownership chain, which is the whole of the work when a shareholder is itself a company or sits in another jurisdiction
The register of real beneficiaries and the register of partners or shareholders both prepared, since the decision requires the company to keep both
Filed with your licensing authority in the form that authority accepts, because a free zone registrar and a Department of Economy do not ask for the same thing
Updated on a change rather than at renewal, since the obligation runs continuously and a stale register is the failure most companies do not know they have
You supply the shareholding structure to its top, the passports of the individuals at the end of it, and any shareholder agreements that affect control, which is what identifies the beneficiary

Benefits for Your Business

A register that is actually correct, including where ownership runs through a foreign holding company.
Changes reflected when they happen, not discovered at licence renewal.
Filed in the form your own authority accepts, first time.
One consistent answer across your licence, your bank and your auditor, who will all ask the same question.

General information, not legal advice. Real beneficiary obligations sit in Cabinet Decision 109 of 2023, in force since 16 November 2023 and supervised by the Ministry of Economy and Tourism, read on 16 September 2026. Financial free zones operate their own regimes. What your company must file depends on its licensing authority, and we confirm that before filing.

Who is a UBO (real beneficiary) in the UAE?

Under Cabinet Decision 109 of 2023, a real beneficiary is a natural person who ultimately:

owns or controls 25% or more of the company's shares or voting rights, directly or through other companies, or
has the right to appoint or remove the majority of its directors, or otherwise controls it.

If no one meets the test, the person in charge of management is recorded instead.

UBO filing deadlines and penalties

Obligation	What applies
Keep two registers	The real beneficiary register and the shareholder or partner register
File with your licensing authority	At incorporation, and again on any change
Update after a change	Within 15 days of the company becoming aware of it
Penalties	Fines that rise with repeat violations, up to about AED 100,000, and possible license suspension

Banks and auditors ask for the same information, so one correct register serves all of them. Related: AML policy and goAML.

Frequently Asked Questions

What is a UBO declaration in the UAE?

A filing that identifies the natural persons who ultimately own or control a company, kept in a register and submitted to the licensing authority under Cabinet Decision 109 of 2023.

Who counts as a UBO in the UAE?

A natural person who owns or controls 25% or more of the shares or voting rights, directly or indirectly, or who controls the company in another way, such as appointing most of its directors.

When must a UBO register be updated?

Within 15 days of the company becoming aware of a change, such as a share transfer or a new shareholder.

What is the penalty for not filing a UBO declaration?

Fines that rise with repeat violations, up to about AED 100,000, and possible suspension of the license.

Do free zone companies need a UBO declaration?

Yes, companies on the mainland and in the non financial free zones. The financial free zones, DIFC and ADGM, run their own regimes.