Beneficial owners
Full name, nationality, date and place of birth, residential address, passport or ID details, date of becoming a beneficial owner and the basis (ownership, votes or control).
Ultimate Beneficial Ownership (UBO) in the UAE: Registers, Filing and Updates Under Cabinet Decision 109 of 2023
Under Cabinet Decision No. 109 of 2023, UAE mainland and commercial free zone companies must identify their ultimate beneficial owners (anyone owning or controlling 25% or more, or otherwise controlling the company), keep registers of beneficial owners, shareholders and nominee directors, file them with the registrar and record changes within 15 days. SGA World prepares, files and maintains UBO records.
- Ministry of Economy and Tourism approved auditor
- 500+ clients
- Dubai & Abu Dhabi
UBO rules at a glance
- Law
- Cabinet Decision No. 109 of 2023
- Threshold
- 25% ownership or voting rights, or control
- Registers
- Beneficial owners, shareholders, nominees
- Changes
- Recorded within 15 days
- Penalties
- Cabinet Decision No. 132 of 2023
Every UAE company must know, record and disclose who ultimately owns or controls it. These ultimate beneficial owner (UBO) rules support the UAE's anti-money laundering framework, and banks, licensing authorities and auditors all check them.
The current rules are in Cabinet Decision No. 109 of 2023 on the procedures for the real beneficiary, which replaced Cabinet Decision No. 58 of 2020, with penalties in Cabinet Decision No. 132 of 2023. SGA World helps companies identify their beneficial owners, prepare the registers, file them with the registrar and keep them up to date.
- Ownership or voting threshold
- 25%
- Beneficial owners, shareholders, nominees
- 3 registers
- To record changes
- 15 days
- Licensing authority receives the data
- Registrar
At a glance
UBO in the UAE: Key Points
- Who: companies licensed on the mainland and in commercial free zones; financial free zones (DIFC, ADGM) have their own regimes.
- Beneficial owner: a natural person who owns or controls 25% or more of shares or voting rights, directly or indirectly, or controls the company by other means.
- Fallback: if no one meets the test, the person who exercises control, and failing that the senior manager, is recorded.
- Registers: a register of beneficial owners, a register of partners or shareholders and details of nominee directors.
- Changes: changes must be recorded and reported within 15 days.
- Penalties: escalating fines and possible licence suspension under Cabinet Decision No. 132 of 2023.
Who is a beneficial owner?
Who Counts as an Ultimate Beneficial Owner in the UAE?
A beneficial owner is always a natural person, never another company. To find them, you look through every layer of ownership until you reach individuals.
A person is a beneficial owner if they:
- own 25% or more of the company's shares, directly or through other companies or trusts;
- hold 25% or more of the voting rights;
- have the right to appoint or remove the majority of directors; or
- control the company by any other means, such as an agreement or family arrangement.
If no individual meets these tests, the company records the person who exercises control, and if there is none, its senior manager. More than one person can be a beneficial owner, and a person can qualify through a combination of direct and indirect holdings.
Worked example
How Do You Find the Beneficial Owner Through a Group Structure?
| Layer | Who owns it | Indirect share of the UAE company |
|---|---|---|
| UAE company (FZ-LLC) | Holding Co A 60%, Mr Khan 40% | Mr Khan: 40% direct |
| Holding Co A (overseas) | Ms Lee 50%, Mr Ross 50% | Ms Lee: 50% x 60% = 30%; Mr Ross: 30% |
| Result | Beneficial owners recorded | Mr Khan, Ms Lee and Mr Ross (each 25% or more) |
Illustrative names and figures. Control rights, trusts and nominee arrangements can change the result even where percentages fall below 25%.
What must be recorded
What Information Goes Into the UBO Registers?
Shareholders or partners
Names, nationality, address, number and class of shares or ownership percentage, and voting rights.
Nominee directors
Details of any nominee board member and the person they act for; nominees must tell the company within 15 days.
Authorised contact
A person resident in the UAE authorised to provide the information to the registrar.
Supporting documents
Identity documents, group charts and evidence of how each beneficial owner was identified.
Change log
A record of every change and the date it was reported.
How we work
How Do We Handle Your UBO Compliance?
Step01
Map the structure
Trace ownership and control through every holding company, trust and agreement.
Step02
Identify UBOs
Apply the 25% and control tests and document the conclusion.
Step03
Prepare registers
Complete the beneficial owner, shareholder and nominee registers.
Step04
File
Submit to your registrar, such as Dubai Economy and Tourism or your free zone authority.
Step05
Maintain
Record and report changes within 15 days and refresh the file every year.
Why SGA World
Why Choose SGA World for Ultimate Beneficial Ownership (UBO) Services?
Tax and compliance in one team
Tax, audit and compliance specialists work together, so nothing falls between advisers.
Ministry-approved audit firm
SGA World is a Ministry of Economy and Tourism approved audit firm, so our reports are accepted where it matters.
Audit and tax in one team
Auditors, VAT, corporate tax and transfer pricing specialists work together, so nothing falls between advisers.
Qualified chartered accountants
A team of chartered accountants qualified in India and the UK, focused on UAE rules.
500+ clients
Mainland and free zone companies, from start-ups and SMEs to regional groups.
Listed with major UAE banks
Our audit work is recognised by major UAE banks for facilities and account reviews.
Why it matters
Why Do Banks, Auditors and Tax Authorities Care About UBO?
UBO information is used well beyond the licensing authority:
- Banks need it to open and keep corporate accounts and will freeze or close accounts where ownership is unclear.
- AML-regulated businesses, such as real estate brokers and corporate service providers, must verify the beneficial owners of their customers. See our AML compliance services.
- Corporate tax rules on connected persons and related parties depend on knowing who owns and controls the company. See our transfer pricing services.
- Auditors check related-party disclosures against ownership records.
Fees and timing
What Affects the Cost and Time of UBO Work?
For a single company owned directly by individuals, UBO registers can usually be prepared quickly. The cost and time increase with:
- the number of holding layers and jurisdictions in the structure;
- trusts, foundations or nominee arrangements;
- missing or out-of-date identity documents;
- the number of entities in the group that need registers;
- whether you want ongoing maintenance for future changes.
We agree a fixed fee once we have seen the ownership chart.
Avoid problems
Common UBO Mistakes
Recording a holding company as the UBO
A beneficial owner must be a natural person
Stopping at the first layer of ownership
Indirect owners above 25% are missed
Ignoring control without shares
Control by agreement still counts
Not updating after a share transfer
Breach of the 15-day rule
No UAE-resident authorised contact
Registrar requirement not met
Different ownership in bank and licence records
Account reviews and delays
UBO desk
Get Your Beneficial Ownership Records Right
Send us your ownership chart and licence details. We will identify the beneficial owners, prepare the registers and file them.
We handle
- Ownership mapping
- UBO identification
- Register preparation
- Registrar filing
- Ongoing updates
Location: Dubai & Abu Dhabi
Talk to Our Team
Our offices in Business Bay, Dubai and Al Bateen, Abu Dhabi support clients across the UAE.
Dubai
Office 1923, The Exchange Tower, Business Bay, Dubai
Abu Dhabi
Khalidiya Towers M-B6, W10, Al Bateen, Al Khalidiyah, Abu Dhabi
Talk to an auditor
Tell us your company type, jurisdiction and deadline. We will confirm the scope, timeline and fee.
- WhatsApp us+971 50 627 3556
- Call us+971 4 570 1795
- Email us[email protected]
- Book an appointmentChoose a time that suits you
Prefer a form? Send us a detailed enquiry.
Who prepared this page
Written and reviewed by SGA World's audit and tax team
This guide is prepared by chartered accountants at SGA World Auditing Accounting L.L.C S.P.C in Business Bay, Dubai, a Ministry of Economy and Tourism approved audit firm, and checked against Federal Tax Authority legislation and guidance. It is reviewed whenever the rules change.
- Last reviewed 14 October 2026
- Chartered accountants from India and the UK
- FTA representation through Saif Chartered Accountants
Have a question about your company?
Tell us your activity, jurisdiction and deadline. A chartered accountant will reply.
Ask an expertFrequently asked questions
UBO Compliance in the UAE – FAQs
Short answers to the questions UAE businesses ask us most. Still unsure?
Talk to our team01.Which law governs UBO in the UAE?
Cabinet Decision No. 109 of 2023 on regulating the procedures of the real beneficiary, with administrative penalties in Cabinet Decision No. 132 of 2023. It replaced Cabinet Decision No. 58 of 2020.
02.Who is an ultimate beneficial owner?
A natural person who ultimately owns or controls 25% or more of a company's shares or voting rights, directly or indirectly, or who can appoint or remove the majority of directors, or otherwise controls the company.
03.What if no one owns 25% or more?
The company records the natural person who exercises control by other means, and if there is none, its senior manager.
04.Do free zone companies need UBO registers?
Yes, companies in commercial free zones are covered. Financial free zones such as DIFC and ADGM have their own beneficial ownership rules.
05.How quickly must changes be reported?
Changes to beneficial owners, shareholders or nominee details must be recorded and reported within 15 days.
06.Where are UBO registers filed?
With the company's registrar, which is usually its licensing authority, such as Dubai Economy and Tourism, the Abu Dhabi Department of Economic Development or the relevant free zone authority.
07.Is UBO information public?
No. The information is kept confidential by the registrar and the Ministry and shared with competent authorities as permitted by law.
08.What are the penalties for UBO breaches?
Cabinet Decision No. 132 of 2023 sets escalating administrative penalties, from warnings to fines and possible licence suspension, depending on the breach and whether it is repeated.
09.Can a company be the beneficial owner?
No. You must look through companies and trusts until you reach the individuals who ultimately own or control the business.
10.How does UBO relate to corporate tax?
Knowing who owns and controls the company is needed to identify related parties and connected persons for corporate tax and transfer pricing.
11.Do sole establishments need UBO registers?
Ownership of sole establishments is clear from the licence, but confirm the current registrar requirements for your entity type.
12.Who files UBO details with the registrar?
The company, through a UAE-resident person it has authorised to provide the information.
References:Ministry of Economy and Tourism: Cabinet Resolution on real beneficiary procedures · UAE Legislation portal · Ministry of Economy and Tourism: AML guidance — reviewed 14 October 2026
