@UAE_help + 971 50 399 5135 (Phone|WhatsApp)

Registration of the Ultimate Beneficial Owner in the UAE

Registration of the Ultimate Beneficial Owner in the UAE

Our guide will show the way to acquire a Beneficial Owner status in the land of Burj Khalifa and dune bashing.

The Ultimate Beneficial Owner, also known as UBO, can be defined the following way: 

A person or a legal entity that is in charge of a certain enterprise — like an oil refinery or a travel agency — and receives profits and other material benefits from it. 

This status has been essential ever since two major initiatives have been introduced: Know Your Client and Know Your Business (KYC & KYB). Ultimate Beneficial Owner UAE registration is imposed and standardized by the monarchy’s special law.

In consonance with this decree, a UBO is someone who:

  • Either retains 25% of the entity’s entire capital and can vote. 
  • Or has the power to appoint or dismiss the majority of the corporation’s board of directors.

If nobody seems to be fit for the duty, then a company’s officer with the highest authority among the managing ranks may apply to be the Ultimate Beneficial Owner. (Unless someone else is acknowledged as a genuine UBO at some point in the future.)

Beneficial Owners & UBOs — Any Difference Between Them?


The Ultimate Beneficial Owner can be a ‘natural’ — e.g. a living-breathing human being — or a legal person. They enjoy the biggest slice of the revenue, despite the hierarchy inside the venture, and have a carte blanche at steering the course of a business. Besides, they retain 25% of the enterprise’s capital, earnings, and other assets. 

There can be multiple Beneficial Owners: while these folks receive some kind of financial reward from a venture, they barely have any legal control over its life. BOs mostly cannot influence corporate decisions or can do so in a limited manner. The main ‘privilege’ they can boast of is usually just receiving dividends. 

Top 9 Details to Know About the UBO Status in the UAE

A whole constellation of factors must be considered before you can obtain the entrepreneurial status that will be legit from Sharjah to Abu Dhabi.

Do I qualify?

As we have said, any person/entity holding at least 25% of a United Arab Emirates-licensed firm is free to seek that status. It’s mandatory to obtain it from the legal perspective: it boosts Anti-Money Laundering (AML) mechanisms and improves the monarchy’s investment climate, as well as overall reputation.


Here’s the list of companies pardoned from filling for the status:

  • Governmental organizations, both national and municipal, and their subsidiaries.  
  • Enterprises registered in the Financial Free Zones (FFZ): DIFC and ADGM: 

So, Beneficial Owner registration in Dubai — a gorgeous city with a whole cluster of such areas — might be a favorable idea for entrepreneurs seeking to expand their operation to the Arab world. 

Note: Do not mistake Financial Free Zones with the Commercial Free Zones where reporting the UBO data is still mandatory. (Check all 40 free zones here.)

General demands

Businessman at the laptop

The application must be submitted on the very first day the business registers in the Emirates federation. If the directorate in the company gets reshuffled affecting someone’s UBO status, you have 15 days to warn the state.  If this condition is ignored more than once, a punishment is going to ensue.

The admissible data must be placed in the Register of Beneficial Owner. Details to be provided will include a Beneficial Owner’s place of residence, full name, citizenship, birthplace, and so forth. Besides, some extra documents might be required: passport’s scan or physical copy, stock certificate, and other papers.

Real Beneficiary explained

Basically, UBO and Real Beneficiary (RB) are synonyms. The RB is expected to own at least one-fourth of all venture’s shares, be able to appoint and fire directors, make pivotal decisions that predefine the future of the enterprise, etc. 

What to mention in the Register of Real Beneficiary?

Here are the details you must share with the government:

  • Address or other residential information.
  • Travel papers: personal ID, passport, visas.
  • Name, national origin, citizenship, birth details, and other personal info.
  • Grounds, on which he or she were granted the RB status, as well as the day when this appointment took effect.

In addition, you should include the date when a person lost their RB status if that actually had happened.

What to put in the Register of Partners or Shareholders?

  • Residential info.
  • Full name, nationality, birth details.
  • Amount of shares owned and voting powers clarified.
  • Travel documents or ID card issued in the applicant’s country.
  • Exact date when they were officially acknowledged as the Shareholder or Partner.

Things take a different turn if a Partner/Shareholder is classified as a legal entity. Then you should provide a broader dossier: the headquarters address, their name, legal status, and others mentioned by the law. Plus the names of the high-ranking executives and their valid identity documents. If a Shareholder/Partner comes from abroad, you’ll have to specify personal details pertaining to their legal representative in the Emirates: alias, address, etc.

When you must register

When you must register

New legislation came into force on August 28th, 2020: all ventures operating in the country had a 2-month grace period to reveal the respective UBO data. All new firms that begin operating on the Emirates soil after June 30th, 2021, must immediately give the information associated with the Ultimate Beneficial Owner. Any alterations to this status must be disclosed within a 15-day period. Again, rejection to abide is administratively punishable.  

How to submit the info

A natural person in the Emirates needs to have permission from a legally recognized entity in order to provide the Registrar with the appropriate information. In plain English, it can be a firm or a foundation representing the UBO. Be aware that any personal information provided to the authorities will be kept confidential.

Failures & punishment

If a company fails to create the Register of Beneficial Owner, as well as provide and keep its data intact and properly updated, this will be an administrative offense. According to the following document, a one-time failure will be reprimanded with just a warning. However, subsequent failures will be subject to fines and trade license suspension. For example, the third failure in a row will cost a company both a license suspension and a fine of 100,000 Emirati dirhams ($27,227). 

UBO Compliance in the UAE: Criteria & Demands

A step-by-step algorithm looks like this:

  • Details. Collect necessary personal data regarding Beneficial Owners. It must be exhaustively true, accurate, as well as up-to-date. Plus, it should be kept and maintained for as long as your entity is going to function on the Emirates’ territory.
  • Preparations. Secretarial records of the company, as well as all necessary Registers, should be prepared in advance.
  • Submission. Report the required documents to the authorities (Registrar, Ministry of Economy). But don’t forget: Free Zones and the rest of the country may have different approaches concerning the UBO procedures. See more info on business license verification in the country.
  • Checks.  To complete Ultimate Beneficial Owner register in the UAE, every applicant is tasked to undergo bona fide KYC and AML examination.  
  • Know Your Partners. Besides, it’s prescribed to gather legally available data about your potential clientele and business partners to avoid harmful partnerships or unwanted inspections. There are specific platforms designed to solve the Know Your Business Partner (KYBP) problem and make digital onboarding risk-free.

Finally, we recommend updating the UBO, Directors, Shareholder, and other similar data on a regular basis to avoid any misunderstanding in the future.  

The Top Questions

The Top Questions

And now we present some of the popular questions about the UBO status.

Who has a right to represent your BO status?

According to Abu Dhabi Department of Economic Development (ADDED), the data in question must be provided by an enterprise’s legal person. For example, it can be one of the directors or any other signatory.  

Is the registration of the legal partner’s Beneficial Owner in the license obligatory?

Yes, this procedure is demanded by the Emirates law. Until the Beneficial Owner is established, the same rule applies to the partners or shareholders in the legal person’s entity.

Is registering the BO for all legal documents really required?

All enterprises that are licensed/registered to operate in the Emirates kingdom — including its free zones — should report the Beneficial Owner details. Exceptions are made for the government-owned companies, commercial entities affiliated with the state companies, and public shareholding enterprises. 

Should the BO status be obtained for all types of businesses?

Yes. All industries — from pharmaceuticals to recreational activities — are equally affected by the Resolution. Therefore, it’s vital for every company’s Beneficial Owner to be in the commercial registry. 

Should the BO status be obtained for all types of licenses?

Yes. As in the case of commercial industries, the same principle applies to the commercial licenses, making the BO registry procedure unavoidable.


Can a natural person who is not related to the license’s parties serve as a BO?

Yes. Besides, the general notion states that a BO should always be a natural person, no matter what type of enterprise they belong to. (Unlike an Ultimate Beneficial Owner who can be a legal entity).

Does a foreigner still have to get registered as a BO?

Yes. This status is obligatory for any person who enjoys financial or other benefits from a company registered in the United Arab Emirates. Their original nationality or citizenship barely play any role in this case. And even if the BO spends most of their time overseas, they still should be put in the registry. 

Is it required to provide documents that confirm a BO’s identity?

It depends on which status the Beneficial Owner in question retains.

  1. Natural person. If it’s a natural, living person, then they must provide a copy of their passport (and maybe some other travel documents) or an Emirates ID that the country’s citizens have.
  1. Legal person. If it’s a legal person, then it’s mandatory to submit articles of association. And for a foreign legal person, it’s obligatory to provide the name and contact information of its legal representative and all necessary proofs demanded. Besides, a business should have the Beneficial Owner register containing exhaustive personal details. (See above.)  

Should a BO hold stock or contribute funds to the company?

This is not imperative. Owning shares or contributing to the corporate capital can be omitted if the Beneficial Owner has a position in the company’s management. But only in those cases when a Beneficial Owner cannot be identified properly due to some reasons.

Is it allowed to alter the license data of a BO?

Yes. This can be achieved through filling out an electronic form provided by the respective authorities.

Can a new BO be appointed?

Yes. Yet again, all changes that have occurred should be registered in the e-government’s electronic form.


Should a BO reach a certain age to get this status?

The UAE laws do not provide any specifications on the Beneficial Owner’s age. At the same time, a guardian for minors can be acknowledged as an UBO.

Can two different BOs be appointed for the branches and the main license of a company?

No. This can’t be done as the Beneficial Owner is, basically, in charge of a company or a conglomerate (group of various entities) in question. 

Where should the BO of a foreign corporate branch be selected: Emirates or their home country?

Actually, it doesn’t matter where the appointment took place. Neither ultimate Beneficial Owner UAE registration, nor foreign registration affect their control over a business.

arrow-icon Back
Vladimir Sviridov
Vladimir Sviridov
General Manager RLC Consulting
With a Postgraduate Masters in Finance from The, Moscow State University, Russia. Vladimir started his professional career as an auditor of the financial sector of EY. After that, he worked for several years in senior positions in corporate banking. In 2018-2021, he managed the finances of a large agricultural holding, and is currently responsible for strategic planning, corporate partnership and financial management in the role of General Manager of RLC Consulting GROUP in the UAE.

Fill out the application and we will contact you

What service are you interested in?
Company setup
Obtaining a residence permit
Buying real estate
Opening a bank account
Auditor or accountant services
Trademark registration
Tax support
Notarial Power of Attorney (PoA)
Launching a business

Your application has been submitted. The manager will contact you soon

ООО «Передовые решения» +7 (495) 966-49-52 info@relocate-uae.com
Россия 115191 Москва Малая Тульская 25с38