UBO Filing & Beneficial Ownership Registers in Dubai

Broadly, any natural person who ultimately owns or controls 25% or more of the company’s shares or voting rights, directly or through other entities, or who controls it by other means — for example through the right to appoint most of the directors. If no one meets either test, the senior managing official is recorded instead. We document how each conclusion was reached.

A register of beneficial owners, a register of partners or shareholders and, where the company has them, a register of nominee directors. Each records the identity details the UBO rules require and when people became or ceased to be owners. The registers are kept by the company and filed with its licensing authority, such as DET on the Dubai mainland or the relevant free zone.

Yes. Any change to ownership or control — a share transfer, a new partner, an exit, or a change further up the chain — means the registers must be updated and the change filed with your licensing authority within the period the UBO rules set. We can handle the update as part of the share transfer, so the registers and the MOA change together.

Then the analysis continues up the chain until it reaches natural persons. A corporate shareholder’s own owners, a trust’s settlor, trustees and beneficiaries, or anyone with control through agreements may need to be considered. Documents from foreign entities usually need to be attested before they are accepted. We map each layer and keep the evidence on file.

Failing to keep, file or update the registers breaches the UBO rules and can lead to administrative penalties from your licensing authority, as well as problems at licence renewal and with banks and auditors who rely on accurate ownership records. Penalty amounts are set by the rules; the practical fix is to file correctly now and keep the registers current.

No. The registers are filed with your licensing authority and are not published as a public register. They can be accessed by the authorities the UBO rules allow, such as supervisors and law enforcement, for compliance and investigation purposes. Banks will usually ask you for the same information directly as part of their own due diligence.