UAE companies must maintain an Ultimate Beneficial Owner (UBO) register and file UBO information with the relevant authority. Here is a complete guide to UAE UBO requirements in 2025.
What Is a UAE UBO?
An Ultimate Beneficial Owner (UBO) is the individual who ultimately owns or controls a UAE company. UAE UBO rules: Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and the associated Cabinet Decision No. 58 of 2020 require all UAE companies to: maintain an internal UBO register (listing all individuals who own 25%+ of the company, or who exercise effective control), and file the UBO register with the relevant licensing authority (DED for mainland companies, the free zone authority for free zone companies, DIFC/ADGM Registrar for DIFC/ADGM companies). Threshold: 25% ownership or control. If no single individual owns 25%+: the UBO is the person exercising senior management control (CEO, managing director).
UAE UBO Register Filing Requirements
What must be filed: full name of each UBO, date of birth, nationality, passport or ID number, country of residence, and nature of their ownership or control interest. Filing deadline: within 60 days of company formation. Updates: any change in UBO must be reported within 15 days of the change. Penalties for non-compliance: AED 1,000-10,000 fine for failure to maintain or update the UBO register. More serious penalties (up to AED 1,000,000) for falsifying UBO information.
UAE UBO for Free Zone Companies
Each UAE free zone has implemented UBO collection slightly differently. IFZA: UBO form submitted during company registration and at annual renewal. DMCC: UBO submitted via the DMCC portal (myDMCC). DIFC/ADGM: UBO filed with the respective Registrar via their online portal. Most free zones now require UBO information as part of the annual licence renewal process (not just at setup). Failure to provide accurate UBO at renewal: can result in licence renewal being blocked.