UBO Declaration Services
UBO Declaration Services in UAE
Get your beneficial ownership records right the first time, before a licensing authority sends them back.
Every company registered and licensed in the UAE must identify its ultimate beneficial owners, maintain accurate ownership registers, and file the required declaration with its licensing authority. Farahat & Co. provides UBO declaration services covering ownership structure analysis, register preparation, declaration filing, and ongoing updates whenever ownership or control changes.
- Ownership analysis: identifying every individual who meets the UAE’s beneficial ownership thresholds, directly or indirectly.
- Register preparation: UBO, Directors, and Shareholders registers built to match your licensing authority’s format.
- Declaration filing: submission to the Ministry of Economy, mainland department, or free zone authority as required.
- Ongoing compliance: timely updates whenever ownership, control, or management changes occur.
Whether you are filing for the first time at incorporation or updating an existing register, our UBO declaration team works within the specific requirements of your licensing jurisdiction.
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What Is a UBO Declaration Under UAE Law?
A UBO declaration is a formal submission identifying the natural person or persons who ultimately own or control a company, regardless of what appears on the trade licence or shareholder documents. Under UAE regulations, an individual qualifies as an Ultimate Beneficial Owner if they hold 25% or more of a company’s equity or voting rights, directly or indirectly, or if they exercise control through other means, such as the power to appoint or remove a majority of the board, or dominant influence over the company’s decisions.
Where no individual meets the ownership threshold, the person exercising effective control over the company is treated as the UBO instead. Companies must file this declaration at the point of registration or incorporation for new entities, and maintain it on an ongoing basis for existing ones, updating it whenever the underlying ownership or control structure changes.
Current UAE Regulations Behind Our UBO Declaration Services
UBO declaration obligations are governed by Cabinet Resolution No. 109 of 2023 on the Regulation of Real Beneficiary Procedures, effective 16 November 2023, which repealed and replaced the earlier Cabinet Resolution No. 58 of 2020.
The updated framework applies to all entities registered and licensed on the UAE mainland and in commercial free zones, though it excludes financial free zones such as the DIFC and ADGM, along with wholly government-owned entities. Associated administrative penalties are set out in Cabinet Decision No. 132 of 2023, which replaced the earlier penalty framework under Cabinet Decision No. 53 of 2021.
Businesses that filed under the old 2020 framework should confirm their registers and declarations reflect the current 2023 requirements, since the update introduced stricter record-keeping and notification procedures.
Registers Required for UBO Compliance
UBO Register
Directors or Managers Register
Partners or Shareholders Register
Who Must File a UBO Declaration in the UAE?
UBO declaration obligations apply broadly across the UAE business landscape, covering companies registered on the mainland and in commercial free zones alike, with limited exemptions for financial free zone entities and wholly government-owned companies.
Both new and existing entities carry this obligation. New companies must identify and register their beneficial owners at the point of incorporation, before the licensing authority will proceed with registration. Existing companies must maintain their registers on an ongoing basis and provide updated information to the Registrar of Companies whenever requested, including business name, legal form, Memorandum and Articles of Association, registered address, and senior management details.
The specific filing portal and documentation requirements can differ depending on whether the entity is licensed by the Department of Economy and Tourism or a free zone authority, which is why jurisdiction-specific guidance matters at the filing stage.
Discuss Your UBO RequirementsPenalties for UBO Non-Compliance in the UAE
Failure to meet UBO obligations carries administrative and, in some cases, criminal consequences for both the company and its officers. Common violations include failing to maintain accurate beneficial owner records, late submission or failure to notify the Registrar of Companies about ownership changes, and failing to provide a declaration containing the required beneficial owner information.
Administrative penalties can accrue daily for as long as the default continues, and officers who knowingly or recklessly submit false, deceptive, or misleading information to the Registrar face liability for a criminal offence. Any change to registered UBO information must be reported within 15 days of the change taking effect. Where a company enters liquidation or dissolution, the appointed liquidator must provide an updated copy of the UBO register to the Registrar of Companies within 30 days of appointment.
Talk to Our UBO Declaration Team
We provide end-to-end UBO declaration support for UAE businesses, from ownership structure assessment and register preparation through to declaration filing and ongoing updates as regulations or ownership change.
Our team works across mainland and free zone jurisdictions and keeps client registers aligned with the current Cabinet Resolution No. 109 of 2023 framework rather than the superseded 2020 rules.
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