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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.
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UBO Declaration and Real Beneficiary Register, UAE | Entityz