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A UBO (ultimate beneficial owner) declaration tells your registrar, the authority your UAE company is registered with, which real people own or control it. Under Cabinet Decision No. 109 of 2023, a beneficial owner is always a natural person who holds 25% or more of the capital or voting rights, directly or through other companies, or who controls the company by other means, such as appointing most directors. Each company the decision covers keeps a beneficial owner register and a register of partners or shareholders, gives both to its registrar within 60 days of licensing, and reports changes within 15 days. Meydan and IFZA collect the declaration during setup; our company setup packages cover setup at both zones.
Key takeaways
Every rule and figure below was read on its publisher’s own website on 16 October 2026, and each source is listed under Sources and how we checked. This page is a plain summary of those texts, not legal advice.
WhatsApp Amir: what do I file for my UBO declaration?
Which texts apply, as of October 2026. Cabinet Decision No. 109 of 2023, which the Ministry of Economy and Tourism lists as the Real Beneficiary Procedures, replaced Cabinet Decision No. 58 of 2020 (Article 22), so a form or guide built on Decision No. 58 of 2020 is out of date. Federal Decree-Law No. 10 of 2025 replaced Decree-Law No. 20 of 2018 (Article 41). Decisions made under the 2018 law, Decision 109 among them, stay in force where they do not conflict with the 2025 law, until new ones replace them (Article 41).
On this page
An ultimate beneficial owner of a UAE company is the natural person who owns or controls it, found by three tests in Article 5 of Cabinet Decision No. 109 of 2023. You apply the tests in order. You move to the second test only when the first finds no one or leaves doubt that the person found is the real owner, and to the third only when neither finds anyone.
A chain of ownership is the line of companies that sits between your company and the people who finally own it. When a company holds your shares, you follow that chain until you reach individuals. A holding company is never the beneficial owner itself.
Two more terms come up later in this guide. A nominee shareholder is a person who votes or receives dividends on someone else’s instructions, and is not the beneficial owner just because they hold the shares (Cabinet Resolution No. 134 of 2025, Article 1). A complex ownership structure is a group of entities linked together to hide who owns or controls a company (Decision 109, Article 1), and Article 5 tells the registrar to take a risk-based approach with one.
| Set-up | Who goes on the beneficial owner register | Why |
|---|---|---|
| One individual holds 100% | That individual | Well above 25% of the capital |
| Two partners, 50% each | Both partners | Each holds 25% or more |
| Four partners, 25% each | All four | The test is 25% or more, so exactly 25% counts |
| Five partners, 20% each, no special rights | Whoever controls the company by other means; if no one does, the senior manager | No one reaches 25%, so the second and third tests apply |
| A holding company owns 100%; it is owned by a father (40%), a mother (35%) and two adult children (12.5% each) | The father and the mother, with the holding company shown as the layer between | Their stakes pass through the chain at 40% and 35%; the children’s 12.5% each falls below 25%, unless they control the company another way |
| An investor holds 10% but can appoint most of the directors | The investor, plus anyone holding 25% or more | Control by other means counts under the first test |
| A nominee holds the shares for someone else | The person the nominee acts for, if the stake held for them is 25% or more or they control the company; the nominee and the person they act for are both recorded in the register of partners or shareholders | Cabinet Resolution No. 134 of 2025 (Article 1) says a nominee shareholder is not the beneficial owner by holding shares as a nominee; Decision 109 (Article 10, clauses 2 and 3) records both |
First Idea Consultant’s company setup packages cost, as of October 2026, AED 12,500 at Meydan or AED 12,900 at IFZA for Basic, AED 23,136 or AED 23,436 for Standard, and AED 28,136 or AED 28,436 for Premium. Meydan Free Zone says UBO registration is built into its setup journey, and IFZA says “UBO compliance is an integral part of the setup process”.
| Package | What it covers | Meydan | IFZA |
|---|---|---|---|
| Basic | Company with no visa: licence, MOA, flexi-office address, certificate of registration | AED 12,500 | AED 12,900 |
| Standard | Basic plus one residence visa, establishment card, medical and Emirates ID | AED 23,136 | AED 23,436 |
| Premium | Company, one residence visa and business bank account opening assistance | AED 28,136 | AED 28,436 |
The full package most buyers look for is Premium: company, one residence visa and business bank account opening assistance, AED 28,136 at Meydan free zone or AED 28,436 at IFZA free zone. KYC (know your customer) is the check a bank runs on who you are and who owns your company before it opens an account. Bank account opening is subject to each bank’s KYC, compliance review and final approval. We prepare the file, pre-check it against the bank’s requirements, and if one bank declines we apply to the next.
Every line behind these totals, and the Gold package, is on our cost of setting up a business in Dubai page. Setting up at DMCC, RAKEZ or on the mainland instead? Send your business activity and visa count on WhatsApp and you get an itemised written quote.
A UBO filing in the UAE covers two registers, one for the company’s beneficial owners and one for its partners or shareholders, and the company gives the data in both to its registrar (Cabinet Decision No. 109 of 2023, Articles 8, 10 and 11). The decision defines the registrar as the authority that supervises the trade names register (Article 1).
The beneficial owner register is your company’s record of each person who passes the Article 5 tests. The register of partners or shareholders is its record of every shareholder, person or company, with their shares and votes.
| Register | What it holds |
|---|---|
| Beneficial owner register | One entry per beneficial owner: identity and address details (the form table below lists them), the basis and the date on which the person became a beneficial owner, and the date the person stopped being one |
| Register of partners or shareholders | Shares held by each partner, their classes and voting rights, and the date each became a partner. For people: full name as on the ID or passport, nationality, address, place of birth, employer’s name and address, and a true copy of a valid ID or passport. For company shareholders: name, legal form, articles, head office address and managers. For nominees and trustees: the person each one acts for |
Each registrar runs its own form or portal step. The table shows what each registrar’s own page said when we read it on 16 October 2026.
| Licensed with | Where you file | What the registrar’s page shows | Source |
|---|---|---|---|
| Meydan Free Zone | With Meydan Free Zone, during setup | UBO registration is part of the setup journey; changes are updated within 15 days; registrar requests are answered within 14 days | Meydan Free Zone, page updated 28 July 2026 |
| IFZA | With IFZA, during setup | “UBO compliance is an integral part of the setup process.” The page does not list the fields | IFZA, page published 18 September 2024 |
| DMCC | DMCC member portal, Company Service “Declare/Update Ultimate Beneficial Owner” (where a company is a shareholder) | For a company with a corporate shareholder: an ownership chart with every holding of 25% or more. For each person: full name as on the passport, date, place and country of birth, nationality, passport details, home address and any other citizenship. For each company in the chain: legal name, country and registered address. Every layer is declared up to the individuals | DMCC UBO Declaration Guideline, version 3, updated 11 January 2024 |
| RAKEZ | RAKEZ Portal 360 | When a company joins as a shareholder: a UBO declaration with the UBO’s passport copy, and an organisational chart up to the UBO names | RAKEZ service card, no date shown |
| DIFC | With the DIFC Registrar of Companies, under DIFC’s own Ultimate Beneficial Ownership Regulations | A 25% threshold; changes entered in the company’s register within 30 days of becoming aware of them, and the Registrar told within 30 days of updating the register; UBO details in the incorporation application count as given to the Registrar | DIFC Ultimate Beneficial Ownership Regulations, consolidated version 2, in force 8 March 2024 |
| ADGM | With the ADGM Registration Authority, under ADGM’s own Beneficial Ownership and Control Regulations 2022 | Beneficial owner details are given at incorporation and kept up to date; the test is 25% or more of ownership or voting rights, or control; changes are reported to the Registrar within 15 days | ADGM, Beneficial Ownership and Control, no date shown |
| Mainland | The registrar the decision defines: the authority that supervises the trade names register for your licence | We did not read a mainland registrar’s UBO page for this guide | Cabinet Decision No. 109 of 2023, Article 1; no registrar page read |
| RAK ICC offshore | Check with RAK ICC | This guide does not summarise RAK ICC’s steps. Our RAK ICC offshore company page lists the documents a file is built from | RAK ICC’s site could not be read for this guide |
DMCC’s guideline also warns that if UBO information turns out to be “untrue, inaccurate, or misleading, DMCC shall terminate the company license and registration”. More on the zone itself is on our DMCC business setup page.
Filing a UBO declaration in the UAE comes down to six steps drawn from Cabinet Decision No. 109 of 2023: chart the ownership, apply the three tests, collect the details, name a UAE contact, submit both registers within 60 days, and keep them current.
Five points in DMCC’s guideline are easy to miss if your DMCC company has a company as a shareholder:
A UBO declaration form asks mainly for identity details: who each beneficial owner is, why they count, and which companies sit between them and your company. Registrars and banks use their own forms. These are the details the decision and the zone pages ask for.
| Part of the form | What to have ready | Source |
|---|---|---|
| The company | Name, legal form, articles of association, head office address, and each manager’s name with passport or ID number, issuer, issue and expiry dates | Decision 109, Article 4 |
| Each beneficial owner | Full name as on the passport, nationality, date and place of birth, home address or an address for notices, passport or ID number with the issuing country, issue and expiry dates; DMCC also asks for the country of birth and any other citizenship | Decision 109, Article 8; DMCC guideline |
| Why each person counts | The basis (25% of the capital, 25% of the votes, control by other means, or senior manager) and the date it began | Decision 109, Articles 5 and 8 |
| Each company in the chain | Legal name as in its company registry, country of registration and registered address | DMCC guideline |
| Each partner or shareholder who is a person | A true copy of a valid passport or ID; the register of partners above lists the other details | Decision 109, Article 10 |
| The authorised UAE contact | Name, address, contact details and a valid passport or ID copy of one UAE resident | Decision 109, Article 11 |
| A company joining as shareholder at RAKEZ | A UBO declaration with the UBO’s passport copy, and an organisational chart up to the UBO names | RAKEZ service card |
A UAE company updates its UBO register within 15 days when its ownership or control changes, under Cabinet Decision No. 109 of 2023. The decision counts from the day the company learns of the change for its own registers, and from the change itself for the registrar.
| What happens | What the decision says | Deadline |
|---|---|---|
| Shares are transferred or a new shareholder joins | The company may not register the transfer until the incoming owner gives a statement saying whether the beneficial owner changes, with the new beneficial owner’s details (Article 8) | Both registers and the registrar updated within 15 days (Articles 8, 10 and 15) |
| A beneficial owner changes, or their details change | Update the register and tell the registrar | Register: 15 days from learning of it (Article 8). Registrar: 15 days from the change itself (Article 15) |
| A new manager or director is appointed | Managers’ names and ID details are part of the company’s basic data. Your free zone’s own regulations can set a shorter deadline: at DMCC, a manager’s resignation or removal is notified to the Registrar within 5 business days (DMCCA Company Regulations 2024, Article 57.12) | Changes reported to the registrar within 15 days (Article 15) |
| Someone becomes, changes or stops being a nominee director | The nominee tells the company | 15 days (Article 9) |
| New shares are issued to named persons | Disclose the shares and the persons to the registrar | 15 days (Article 11) |
| Someone may be a beneficial owner but is not on the register | The company asks them; if 15 days pass with no answer it sends a formal notice; if 15 more days pass with no reply, it records the details it has | 15 days after the inquiry, then 15 days after the notice (Article 7) |
| The company is liquidated | The liquidator gives the registers to the registrar and keeps the records for at least 5 years | 30 days from appointment (Article 11) |
15 days or 15 working days? Decision 109 counts 15 days from learning of a change for the company’s own registers (Articles 8 and 10) and 15 days from the change itself for the registrar (Article 15). The newer anti-money laundering regulation, Cabinet Resolution No. 134 of 2025 (Article 38), gives companies 15 working days from the change to update beneficial owner information and basic company details, managers included. Counting 15 calendar days from the date of the change meets both texts.
Example: one share sale, two new beneficial owners. This is a made-up company, not a real case, to show how the rules work together. Say you own 50% of a free zone company and a business partner owns 30%. A holding company registered abroad owns the other 20%, and two sisters own that holding company, half each.
The look-through count here is a plain reading of Article 5’s “direct or indirect” ownership. With trusts, nominees or many layers, the registrar applies a risk-based approach, so ask your registrar how it counts your chain.
At renewal or amendment the company also gives the registrar its basic data again: name, legal form, articles, address and managers (Article 11). We also handle licence renewals. No professional service fee on licence renewals; government and authority fees still apply.
Adding a company as a shareholder at Meydan? Our Meydan free zone page lists the corporate shareholder documents.
Your bank asks for a UBO declaration because Cabinet Resolution No. 134 of 2025, the executive regulation of the UAE’s anti-money laundering law, tells banks to identify the people who own and control their company customers. The resolution asks banks to understand each company customer’s ownership and control structure (Article 9). Banks then identify the person who owns 25% or more, alone or jointly; failing that, whoever controls the company by other means; and failing both, the senior manager (Article 10). Article 38 asks companies to cooperate by giving banks adequate, accurate and up-to-date beneficial owner information.
Banks ask for a UBO declaration, usually on their own form, with passports of the beneficial owners. Our business bank account opening page and our guide to documents to open a UAE bank account list the rest of the file. Where another company owns yours, the bank still has to reach the natural person at the end of the chain (Article 10).
Keep the declaration you give the bank the same as the one your registrar holds. Federal Decree-Law No. 10 of 2025 (Article 35) punishes anyone who intentionally gives false or misleading beneficial owner information to an authority or a bank with imprisonment and a fine of not less than AED 20,000, or either (Ministry of Economy and Tourism English text, checked 16 October 2026).
Bank account opening is subject to each bank’s KYC, compliance review and final approval. We prepare the file, pre-check it against the bank’s requirements, and if one bank declines we apply to the next.
The penalties for UBO violations in the UAE are set by Cabinet Resolution No. 132 of 2023, which, as of October 2026, starts most violations with a written warning and sets fines of up to AED 100,000 (Ministry of Economy and Tourism English text, checked 16 October 2026). Most warnings give you 15 or 30 days to correct. For most violations, fines apply from the second time. On a third, the registrar may also suspend the commercial licence and close the business premises until the fine is paid and the breach corrected (Article 3).
| Violation | First time | Second time | Third time |
|---|---|---|---|
| Not setting up the beneficial owner register and keeping its data | Written warning, 30 days to correct | AED 50,000 and a warning | AED 100,000 |
| Not recording beneficial ownership details properly | Written warning, 15 days | AED 20,000 and a warning | AED 40,000 |
| Leaving out required details from the beneficial owner register | Written warning, 15 days | AED 20,000 and a warning | AED 40,000 |
| Not updating the beneficial owner register | Written warning, 15 days | AED 15,000 and a warning | AED 30,000 |
| Not setting up the register of partners or shareholders | None listed | AED 50,000 and a warning | AED 100,000 |
| Not updating the register of partners or shareholders within 15 days | Written warning, 30 days | AED 15,000 and a warning | AED 30,000 |
| Not giving the registrar the data of both registers | Written warning, 30 days | AED 15,000 and a warning | AED 30,000 |
| Not disclosing every ownership layer in a complex structure | Written warning, 30 days | AED 50,000 and a warning | AED 100,000 |
| Not giving the registrar the nominee director data | Written warning, 30 days | AED 40,000 and a warning | AED 80,000 |
| Not naming a UAE-resident person authorised to disclose the data | Written warning, 30 days | AED 10,000 and a warning | AED 20,000 |
| Not answering a registrar request within 14 days | Written warning, 30 days | AED 15,000 and a warning | AED 30,000 |
A fine can be contested. A grievance goes to the registrar’s Grievances Committee within 30 days of notification, and you can ask for the penalty to be stopped meanwhile; the committee decides that request within 45 working days (Cabinet Decision No. 109 of 2023, Article 19).
Cabinet Decision No. 109 of 2023 exempts three groups (Article 3):
A company owned by a company listed on a regulated market with its own disclosure rules, or a majority-owned subsidiary of such a listed company, is exempt only from Article 6(1). That clause is the duty to take reasonable measures to obtain and keep adequate, accurate and up-to-date beneficial owner data (Article 6). Ask the registrar what it still expects for the two registers.
Short answers to common UBO declaration questions follow, each with the source it comes from.
A UBO declaration in the UAE is the filing that tells your registrar, and later your bank, which natural persons own or control your company; UBO stands for ultimate beneficial owner. Under Cabinet Decision No. 109 of 2023, the company keeps a beneficial owner register and a register of partners or shareholders and gives both to its registrar within 60 days of licensing.
The ultimate beneficial owner of a UAE company is any natural person who owns 25% or more of the capital or voting rights, directly or through other companies, or who controls the company by other means, such as appointing or dismissing most directors. If no one qualifies, the person who controls it another way is recorded, and failing that, the senior manager (Cabinet Decision No. 109 of 2023, Article 5). A one-person company is covered too: a sole individual shareholder with 100% is the beneficial owner, and if the sole shareholder is a company, the individuals who own or control that company are declared.
The documents for a UBO declaration are mainly identity details and passport or ID copies. For each beneficial owner you need full name, nationality, date and place of birth, home address and passport or ID details (Cabinet Decision No. 109 of 2023, Article 8), plus a true copy of a valid passport or ID for each partner or shareholder who is a person (Article 10). For each company in the chain, have its legal name, country of registration and registered address, with an ownership chart (DMCC UBO Declaration Guideline), and name one UAE resident authorised to give the registrar the data, with a valid passport or ID copy (Article 11).
Free zone companies in the UAE’s commercial free zones have to keep both registers and give them to their registrar: Cabinet Decision No. 109 of 2023 applies to companies licensed or registered in the UAE “including the commercial free zones” and exempts the financial free zones. Meydan and IFZA say UBO filing is part of their setup process; DMCC and RAKEZ ask for a UBO declaration through their portals where a company is, or becomes, a shareholder. DIFC and ADGM apply their own beneficial ownership regulations.
A UAE company updates its UBO register within 15 days of learning of a change (Cabinet Decision No. 109 of 2023, Article 8) and tells the registrar within 15 days of the change itself (Article 15). Cabinet Resolution No. 134 of 2025 (Article 38) gives 15 working days from the change, so counting 15 calendar days from the date of the change meets both. A share transfer cannot be registered until the incoming owner states whether the beneficial owner changes (Article 8).
The UAE beneficial owner register is not public. The Ministry of Economy and Tourism and the registrar may not disclose it or the register of partners or shareholders without the written approval of the beneficial owner or the nominee, except under the decision’s own disclosure duties and the international laws and agreements in force in the UAE, especially on anti-money laundering (Cabinet Decision No. 109 of 2023, Article 16). Basic company details, such as name, legal form and address, are public (Article 13), and under Cabinet Resolution No. 134 of 2025 (Article 37) the registrar also makes nominee director or nominee shareholder information public.
Your bank asks for a UBO declaration because Cabinet Resolution No. 134 of 2025 requires banks to identify the beneficial owners of company customers, starting with anyone who owns 25% or more (Article 10), and asks companies to give banks accurate beneficial owner information (Article 38). Banks usually ask for it on their own form, with the owners’ passports.
The penalty for not filing beneficial owner information in the UAE usually starts with a written warning and 15 or 30 days to correct, under Cabinet Resolution No. 132 of 2023 (Ministry of Economy and Tourism English text, checked 16 October 2026). Repeat violations carry fines of AED 5,000 (at the liquidation stage) to AED 100,000, depending on the breach, and on a third violation the registrar may also suspend the licence and close the business until the fine is paid and the breach corrected. A penalty can be contested before the registrar’s Grievances Committee within 30 days of notification, with a request to stop it meanwhile that the committee decides within 45 working days (Cabinet Decision No. 109 of 2023, Article 19).
The sources for this guide are the official texts and registrar pages below, and each rule on this page was read on the authority’s own website on 16 October 2026. Rules change, so check the source before you file.
Two sources could not be read on 16 October 2026: the Dubai Department of Economy and Tourism’s legislation pages and RAK ICC’s rules page, so this guide does not summarise their steps. One point comes from our own published material rather than an authority: that banks usually ask for the declaration on their own form, as the checklist on our business bank account opening page lists it.
About the reviewer
Amir Aslam is the Founder of First Idea Consultant LLC, a business setup firm in Dubai since 2015. He works from Park Regis, ParkLane Tower, Office 812, Business Bay, Dubai.
Amir Aslam answers +971 56 500 6694 on WhatsApp: tell us where your company is licensed, or where you plan to set it up, and who owns it. We usually reply within a couple of hours, Monday to Friday 9:00 to 18:00 and Saturday 9:00 to 14:00.
WhatsApp Amir: setting up at Meydan or IFZA
First Idea Consultant LLC, founded 2015, Park Regis, ParkLane Tower, Office 812, Business Bay, Dubai. Call or WhatsApp +971 56 500 6694, or email info@firstideasetup.com.