UAE Cabinet Decision No. 58 of 2020 requires all UAE companies (mainland and free zone) to maintain a Beneficial Owner Register and disclose their Ultimate Beneficial Owners (UBOs) to the relevant authority. This is a non-public register used by UAE authorities for AML purposes.
Who Is an Ultimate Beneficial Owner?
A UBO is any natural person who: owns or controls more than 25% of the company’s shares or voting rights (directly or indirectly), exercises significant influence or control over the company’s management, or is the senior managing official of the company (if no natural person meets the above criteria).
What Information Must Be Disclosed?
- Full name, nationality, and date of birth of each UBO
- Place of residence and contact details
- Percentage of ownership or nature of control
- Date on which they became a UBO
- Passport number or national ID
How to File the UBO Register
Filing is done with the relevant free zone or mainland authority: DED (mainland), DMCC Portal, IFZA Portal, RAKEZ Portal, and other free zone client portals all have UBO declaration sections. File the initial UBO register when the company is incorporated. Update within 15 days of any change in UBO information.
Penalties for Non-Compliance
Failure to file or update the UBO register: AED 100,000 for first offence, AED 500,000 for repeat offences. Some free zones also reserve the right to suspend the company’s licence for persistent non-compliance.
UBO vs. FATCA/CRS Reporting
The UBO register is internal to UAE authorities and is not automatically shared with foreign governments. FATCA and CRS are separate international reporting frameworks for financial accounts. An entity may have UBO obligations AND FATCA/CRS obligations concurrently.