UAE Free Zone — Beneficial Ownership and UBO Register Reference 2026
UAE free zone companies must maintain accurate Ultimate Beneficial Owner (UBO) records. Here is the complete 2026 reference on UBO requirements.
In this guide:
UAE UBO Legal Framework
- Law: Cabinet Resolution No. 58/2020 on Beneficial Owner Procedures
- Scope: Applies to ALL UAE companies including free zone companies
- Exemptions: Listed companies on UAE stock exchanges; government-related entities
Definition of Ultimate Beneficial Owner
- 25% threshold: Any individual owning 25% or more of the company shares
- Control: Any individual who exercises effective control over the company even if below 25%
- Director: If no shareholder meets the UBO criteria, the senior managing official is recorded as UBO
UBO Register Requirements
- Internal register: Maintain a UBO register at the company registered office
- Free zone submission: Submit UBO data to the relevant free zone authority
- Annual update: Review and update UBO register annually or whenever UBO changes
- Data: Full name; nationality; date of birth; passport number; country of residence; nature and extent of interest/control
International Reporting — AEOI
- CRS/AEOI: UAE participates in OECD Common Reporting Standard (CRS) automatic exchange of financial information
- UAE free zone companies holding financial assets: May have reportable accounts under CRS
- Reporting entity: UAE financial institutions (banks) report UAE accounts of non-UAE tax residents to FTA for exchange
Penalties for Non-Compliance
- Administrative penalties: Up to AED 100,000 for failure to maintain UBO register
- Criminal referral: In cases of deliberate concealment