Advisory & Compliance
Identify your ultimate beneficial owners, maintain the UBO register and file updates with your licensing authority on time.
Under Cabinet Decision No. 109 of 2023, most UAE companies must identify the individuals who ultimately own or control them, keep a register of those people and share it with their licensing authority. We map your ownership chain, prepare the registers and keep them updated whenever something changes.
Avoid penalties
Missing or late UBO filings can lead to administrative fines from the licensing authority.
Smooth renewals
Accurate registers prevent delays at licence renewal and amendment.
Faster banking
Banks ask for the same ownership information during KYC, so it is ready when they do.
Complex structures handled
Holding companies, trusts and multi-layer chains traced to the real individuals.
In-depth guide
01What the UBO rules require
The beneficial ownership rules are part of the UAE’s wider effort to improve corporate transparency. Companies must keep three registers: the Real Beneficiary register, a register of partners or shareholders, and, where relevant, registers of nominee directors and shareholders.
The information must be kept at the company and filed with the authority that issued the trade licence, which may then share it with other government bodies when required.
02Indirect ownership and control
The 25% test looks through holding companies. If a person owns 50% of a holding company that owns 60% of your UAE company, they indirectly hold 30% and are a beneficial owner. Control can also arise from voting agreements, the right to appoint directors or other arrangements.
We work through these chains step by step and keep a short working file that explains how each beneficial owner was identified, which is useful if the authority asks questions later.
03Staying current
UBO compliance is ongoing. Share transfers, new investors, changes in a parent company and even a change of passport can trigger an update.
Clients on our corporate services or bookkeeping plans can ask us to monitor these events and handle the notifications as they arise.
- 1
Collect
Gather shareholder documents, group charts and IDs for every layer of ownership.
- 2
Map
Trace direct and indirect ownership and control to identify beneficial owners.
- 3
File
Prepare the registers and submit them to your licensing authority.
- 4
Maintain
Record changes and file notifications within the required timeframe.
Generally, an individual who ultimately owns or controls 25% or more of a company’s shares or voting rights, directly or indirectly, or who otherwise exercises ultimate control. If no one meets that test, the person in senior management control is usually treated as the beneficial owner.
Advisory & Compliance
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