UAE UBO Filing — Beneficial Ownership Registration
The UAE requires all companies to maintain a register of their Ultimate Beneficial Owners (UBOs) and file this information with the relevant authorities under Cabinet Resolution No. 58 of 2020.
What Is a UBO?
A UBO is a natural person (individual) who ultimately owns or controls a company. Under UAE law, a person is considered a UBO if they:
- Own 25% or more of the company's shares (directly or indirectly), or
- Control the company through voting rights, board rights, or other means, or
- Exercise ultimate effective control over the company
Who Must File?
All UAE onshore (mainland) companies and most free zone companies, including:
- Mainland LLCs, sole establishments, and branches
- Free zone companies (unless the free zone has its own equivalent register — e.g. ADGM and DIFC)
What Must Be Filed?
Companies must maintain:
- Beneficial Owner Register — a record of all UBOs with names, nationalities, dates of birth, passport/Emirates ID details, and ownership percentages
- Partners and Shareholders Register — list of all shareholders
- Senior Management Register — list of directors and authorised signatories
Where to File?
The UBO register is maintained at the Ministry of Economy (via its online portal). The registered agent/address in the UAE must also hold a copy.
Annual Update Obligation
UBO information must be updated within 15 business days of any change (new shareholder, ownership transfer, change in control). Failure to update attracts penalties of up to AED 50,000.
Penalties
- Failure to maintain a UBO register: up to AED 100,000
- Failure to file or update: up to AED 50,000
- Providing false information: up to AED 50,000
Kounted manages UBO filing and annual updates as part of our company secretarial service.