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.



