The UAE Ultimate Beneficial Owner (UBO) Register requirement (Cabinet Decision No. 58 of 2020) compels all UAE companies to identify and register their UBOs with the relevant authority. Non-compliance is a criminal offence. Here is the complete compliance guide.
What Is a UAE UBO?
A UBO is any individual who ultimately owns or controls 25% or more of the company’s shares or voting rights, or who otherwise exercises ultimate control over the company’s management. For a simple 100% foreign-owned company: the sole shareholder is the UBO. For a company with two 50% shareholders: both are UBOs. For complex structures: trace through ALL layers of ownership to reach the individual human beings who ultimately own or control 25%+.
UBO Register Filing Requirements
All UAE mainland and free zone companies must maintain: a UBO Register (containing all individuals qualifying as UBOs), a Register of Nominees (if any nominee directors or shareholders are used — you must disclose the ultimate principals), and a Partners/Shareholders Register.
Where to File UAE UBO Information
The UBO Register must be filed with the relevant authority: Mainland companies: file with the UAE Ministry of Economy via the Ministry’s UBO portal. Dubai free zone companies (DMCC, DIC, JAFZA, etc.): file with the respective free zone authority through their client portal. DIFC and ADGM companies: file with the relevant authority in those jurisdictions. Deadline for initial registration: 60 days from incorporation (for new companies) or from any change in UBO status.
UBO Change Notifications
Notify the relevant authority within 15 days of any change in UBO information: new shareholder acquisition, existing shareholder selling shares, change of address or nationality of a UBO, death of a UBO. Failure to notify: AED 100,000 fine per violation.
Penalties for Non-Compliance
Failure to register UBO information: AED 100,000 fine. Failure to maintain a UBO Register: AED 100,000 fine. Providing false UBO information: criminal prosecution. The UAE takes UBO compliance very seriously as part of its FATF action plan commitments.