Confused about UAE’s UBO rules? You’re not alone! Understanding Ultimate Beneficial Ownership (UBO) is essential for your company to be compliant, transparent, and secure.
With strict AML laws and new Cabinet Decisions reshaping compliance, every business owner in the UAE needs to know exactly who their real owner is and how to report it correctly. Here’s your complete guide to staying compliant, transparent, and penalty-free.
“A UBO in UAE, is the natural person who ultimately owns or controls a company, whether directly or indirectly, even if their name isn’t listed on official records.”
Under UAE regulations, a UBO is anyone:
Who owns 25% or more shares.
Holds 25% or more voting rights.
Has authority over board appointments.
Exercises significant control or influence over the company.
All businesses, including those in Mainland Companies and Free Zones, must identify and report their UBOs to promote transparency and prevent money laundering, terrorism & proliferation financing, and financial crimes hidden behind corporate structures.
A Shareholder is anyone who owns a certain percentage of shares in a company. This can be either a natural person (an individual) or a legal entity (like another company).
Whereas a UBO in UAE is always a natural person who ultimately owns, controls, or benefits the company even if they are not listed as a shareholder. A Beneficial Owner is an individual who has real decision-making power or enjoys the profits behind the business.
The UAE has strengthened its rules on UBO in UAE to promote transparency, prevent financial crimes, and align with global AML standards.
1. Legal Framework:
The UAE has introduced a new legal framework to make company ownership more transparent and accountable.
The Cabinet Decision No. (109) of 2023 regulates the Beneficial Owner Procedures, establishing updated regulations for ownership transparency.
This new resolution requires all UAE companies to:
* Maintain an updated register of their UBOs.
* Submit this register to the Registrar to ensure accurate and transparent disclosure.
It also outlines the duties of the Registrar for identifying UBOs, maintaining databases, and ensuring proper documentation.
2. Penalties for Non-Compliance:
The UAE has enforced a structured penalty system under Cabinet Resolution No. (132) of 2023 for companies that fail to meet UBO disclosure and maintenance obligations.
First Violation: Written warning with notice to correct within 15–30 days (violation-specific).
Second Violation: Fine of AED 5,000–50,000 + further notice to correct (15–30 days).
Repeated Violations (3rd Instance): Fine of AED 10,000–100,000 + final notice; possible license suspension or business closure until compliance is achieved.
Failure to properly register UBO details: Starts with warning; AED 20,000 (2nd), AED 40,000 (3rd).
Failure to establish UBO Register & it’s Data: Starts with warning; AED 50,000 (2nd), AED 100,000 (3rd).
Non-compliance may also attract additional penalties under Federal Decree-Law No. 10 of 2025 on AML/CFT.
3. UBO in UAE Under AML, KYC, and CDD Requirements:
To strengthen financial transparency, the UAE links UBO disclosure with AML and KYC regulations
Under the Federal Decree-Law No. 10 of 2025[AC2] , companies must identify and verify their UBOs to meet AML and KYC requirements.
(Designated Non-Financial Businesses and Professions)
(Virtual Asset Service Providers)
Financial Institutions
All UAE-registered companies (even non-operational)
4. Who Must Follow These Rules:
All Mainland and Free Zone companies must follow UBO laws except:
Companies owned by the UAE government.
Public joint-stock companies (PJSCs).
Companies in financial Free Zones like DIFC and ADGM have their own rules.
To ensure full compliance with the UAE’s UBO regulations and avoid potential penalties, businesses should seek expert legal guidance. Professional advice not only ensures transparency but also protects your business reputation in the long run.
The first step in identifying the Beneficial Owner in UAE is to collect key company documents that show who owns or controls the business. Which includes:
Memorandum of Association (MOA)
Shareholder or partner register
Organizational structure chart.
Additional supporting documents may also be needed depending on the company’s structure. After reviewing these documents, identify the individual with real control that person is the UBO
After reviewing the main documents, check if any individual owns 25% or more of the company’s shares or has 25% or more voting rights.
If such a person is found, they are considered the UBO under UAE law. The company must then apply the required AML checks and verification procedures for that person.
Once the UBO in UAE is identified, the next step is to collect and verify their personal details.
You need to collect the following information from the UBO:
Full name (as shown on their ID or passport, including any nickname or alias)
Date of birth and nationality
Country of residence
Current residential address
Place of birth
Percentage of shareholding or role in the company
After collecting these details, the business must verify them using valid identification documents, such as:
Original or digital copy of a passport or national ID card
Any official government-issued document with a clear photograph
Travel document or UAE Pass (for verifying the address of UAE residents)
Verifying these details helps ensure the UBO’s identity is genuine and keeps the company fully compliant with UAE’s AML and KYC regulations.
After verifying the UBO in UAE, businesses like DNFBPs and VASPs must perform sanctions and background checks to ensure compliance.
They need to check if the UBO is:
Listed on local or international sanctions or terrorist lists
A Politically Exposed Person (PEP)
Reported in negative media or linked to money laundering or other crimes
Having any criminal record
Dealing in Dual- Used Goods.
Once screening is complete, the business should:
Assess the risk level of the UBO
Assign a risk rating based on AML/CFT policies
Apply appropriate CDD measures
Onboard the customer according to internal compliance and acceptance policies
These steps help ensure that only genuine and verified UBOs are linked to the company. The Ministry of Economy (MOE) and the UAE AML/CFT Executive Office oversee UBO compliance as part of the country’s National Risk Assessment framework, reinforcing transparency and regulatory authority.
Complying with UBO in UAE regulations is essential for maintaining transparency and meeting AML standards. Identifying the true owner of a company strengthens trust, enhances accountability, and helps prevent financial crimes.
Missing a UBO update? That could cost your company thousands of penalties. For complete assurance, it is advisable to seek professional legal guidance to ensure full compliance with UAE laws.
Managing UBO in UAE requirements can be challenging, especially for companies with complex or foreign ownership. AMCA’s Compliance Team ensures a smooth process by assisting with:
UBO identification and documentation
Maintaining the Real Beneficiary Register
Submitting UBO data to authorities
Reviewing corporate compliance and control
With AMCA, your business stays compliant, transparent, and penalty-free under UAE regulations
Call Us: +971 4 321 1204
Email Us: info@amca.ae
Q1: How often should UBO information be updated in the UAE?
Companies must review and update their UBO in UAE records on an ongoing basis whenever there’s a change in ownership or control or at the request of the Concerned Authorities to stay compliant with AML rules.
Q2: Who is exempt from UBO disclosure in the UAE?
Public joint-stock companies (PJSCs) listed on UAE exchanges, companies wholly owned by Federal or Local Government (including their wholly-owned subsidiaries), and entities registered in Financial Free Zones such as DIFC and ADGM are exempt from mainland UBO register obligations and follow their own dedicated UBO frameworks as per Cabinet Resolution No. (109) of 2023.
Q3: What happens if a company fails to disclose its UBO in UAE?
Non-compliance with UBO in UAE regulations can lead to administrative fines, business restrictions, and even license suspension until accurate ownership details are provided.
08 Dec 2025
