The United Arab Emirates has introduced comprehensive updates to its corporate law framework concerning Ultimate Beneficial Ownership (UBO), primarily through Cabinet Resolution No. 109 of 2023 and Cabinet Decision No. 132 of 2023.
22 May, 2025
Ultimate Beneficial Ownership in the UAE: New Compliance Requirements for 2024–2025
As part of its broader strategy to increase corporate transparency and align with international anti-money laundering standards, the UAE introduced new Ultimate Beneficial Ownership (UBO) regulations under Cabinet Resolution No. 109 of 2023 and Cabinet Decision No. 132 of 2023. These regulations impose detailed disclosure and compliance obligations on mainland and non-financial free zone companies operating in the UAE.
What Is a UBO and Who Must Comply?
An Ultimate Beneficial Owner is a natural person who ultimately owns or controls 25% or more of a company’s capital or voting rights. Companies must identify and disclose their UBO to the licensing authority through:
A Real Beneficiary Register (RBR)
A Partners or Shareholders Register (PSR)
Entities must report changes within 15 days, and failure to comply may lead to penalties, license suspension, or blacklisting. Exemptions apply to:
Government-owned companies
Financial free zones such as DIFC and ADGM
Risk-Based Approach and Registrar's Authority
The Registrar may apply a risk-based evaluation if ownership structures involve:
Offshore holding entities
Nominee shareholders
Family-owned trusts
In such cases, the Registrar can demand further disclosure, ensuring enhanced regulatory oversight in complex corporate setups.
Confidentiality and Data Protection
UBO information remains confidential and cannot be shared without the UBO’s consent, unless legally required by a judicial or regulatory authority.
Consequences of Non-Compliance
Administrative penalties may include:
Written warnings
Monetary fines
Temporary suspension or cancellation of trade licenses
Conclusion
With these enhanced UBO obligations, the UAE demonstrates its commitment to financial transparency and responsible governance. Businesses must ensure timely and accurate reporting to avoid disruption and maintain credibility with stakeholders.
Ultimate Beneficial Ownership in the UAE: New Compliance Requirements for 2024–2025
As part of its broader strategy to increase corporate transparency and align with international anti-money laundering standards, the UAE introduced new Ultimate Beneficial Ownership (UBO) regulations under Cabinet Resolution No. 109 of 2023 and Cabinet Decision No. 132 of 2023. These regulations impose detailed disclosure and compliance obligations on mainland and non-financial free zone companies operating in the UAE.
What Is a UBO and Who Must Comply?
An Ultimate Beneficial Owner is a natural person who ultimately owns or controls 25% or more of a company’s capital or voting rights. Companies must identify and disclose their UBO to the licensing authority through:
A Real Beneficiary Register (RBR)
A Partners or Shareholders Register (PSR)
Entities must report changes within 15 days, and failure to comply may lead to penalties, license suspension, or blacklisting. Exemptions apply to:
Government-owned companies
Financial free zones such as DIFC and ADGM
Risk-Based Approach and Registrar's Authority
The Registrar may apply a risk-based evaluation if ownership structures involve:
Offshore holding entities
Nominee shareholders
Family-owned trusts
In such cases, the Registrar can demand further disclosure, ensuring enhanced regulatory oversight in complex corporate setups.
Confidentiality and Data Protection
UBO information remains confidential and cannot be shared without the UBO’s consent, unless legally required by a judicial or regulatory authority.
Consequences of Non-Compliance
Administrative penalties may include:
Written warnings
Monetary fines
Temporary suspension or cancellation of trade licenses
Conclusion
With these enhanced UBO obligations, the UAE demonstrates its commitment to financial transparency and responsible governance. Businesses must ensure timely and accurate reporting to avoid disruption and maintain credibility with stakeholders.
Ultimate Beneficial Ownership in the UAE: New Compliance Requirements for 2024–2025
As part of its broader strategy to increase corporate transparency and align with international anti-money laundering standards, the UAE introduced new Ultimate Beneficial Ownership (UBO) regulations under Cabinet Resolution No. 109 of 2023 and Cabinet Decision No. 132 of 2023. These regulations impose detailed disclosure and compliance obligations on mainland and non-financial free zone companies operating in the UAE.
What Is a UBO and Who Must Comply?
An Ultimate Beneficial Owner is a natural person who ultimately owns or controls 25% or more of a company’s capital or voting rights. Companies must identify and disclose their UBO to the licensing authority through:
A Real Beneficiary Register (RBR)
A Partners or Shareholders Register (PSR)
Entities must report changes within 15 days, and failure to comply may lead to penalties, license suspension, or blacklisting. Exemptions apply to:
Government-owned companies
Financial free zones such as DIFC and ADGM
Risk-Based Approach and Registrar's Authority
The Registrar may apply a risk-based evaluation if ownership structures involve:
Offshore holding entities
Nominee shareholders
Family-owned trusts
In such cases, the Registrar can demand further disclosure, ensuring enhanced regulatory oversight in complex corporate setups.
Confidentiality and Data Protection
UBO information remains confidential and cannot be shared without the UBO’s consent, unless legally required by a judicial or regulatory authority.
Consequences of Non-Compliance
Administrative penalties may include:
Written warnings
Monetary fines
Temporary suspension or cancellation of trade licenses
Conclusion
With these enhanced UBO obligations, the UAE demonstrates its commitment to financial transparency and responsible governance. Businesses must ensure timely and accurate reporting to avoid disruption and maintain credibility with stakeholders.
Ultimate Beneficial Ownership in the UAE: New Compliance Requirements for 2024–2025
As part of its broader strategy to increase corporate transparency and align with international anti-money laundering standards, the UAE introduced new Ultimate Beneficial Ownership (UBO) regulations under Cabinet Resolution No. 109 of 2023 and Cabinet Decision No. 132 of 2023. These regulations impose detailed disclosure and compliance obligations on mainland and non-financial free zone companies operating in the UAE.
What Is a UBO and Who Must Comply?
An Ultimate Beneficial Owner is a natural person who ultimately owns or controls 25% or more of a company’s capital or voting rights. Companies must identify and disclose their UBO to the licensing authority through:
A Real Beneficiary Register (RBR)
A Partners or Shareholders Register (PSR)
Entities must report changes within 15 days, and failure to comply may lead to penalties, license suspension, or blacklisting. Exemptions apply to:
Government-owned companies
Financial free zones such as DIFC and ADGM
Risk-Based Approach and Registrar's Authority
The Registrar may apply a risk-based evaluation if ownership structures involve:
Offshore holding entities
Nominee shareholders
Family-owned trusts
In such cases, the Registrar can demand further disclosure, ensuring enhanced regulatory oversight in complex corporate setups.
Confidentiality and Data Protection
UBO information remains confidential and cannot be shared without the UBO’s consent, unless legally required by a judicial or regulatory authority.
Consequences of Non-Compliance
Administrative penalties may include:
Written warnings
Monetary fines
Temporary suspension or cancellation of trade licenses
Conclusion
With these enhanced UBO obligations, the UAE demonstrates its commitment to financial transparency and responsible governance. Businesses must ensure timely and accurate reporting to avoid disruption and maintain credibility with stakeholders.
