UAE UBO declaration & register support
Identify beneficial owners, maintain the register and complete declarations with the relevant registrar. The UBO regime is a separate, continuing obligation under Cabinet Decision 109 of 2023 — not an FTA tax filing and not cancelled with ESR. Standard declaration fee AED 1,500.
UBO and tax registration are different obligations
UBO identifies the natural persons who ultimately own or control an entity, and sits with the relevant commercial registrar (DED, free-zone authority or other licensing authority) rather than the FTA. It is distinct from VAT and Corporate Tax registration and was not cancelled when the ESR reporting regime was amended.
Who is covered
Cabinet Decision 109 of 2023 applies to most UAE legal entities licensed on the mainland and in many free zones. DIFC and ADGM operate under their own separate beneficial-owner regimes; those entities should check their financial-free-zone rules rather than assume Cabinet Decision 109 of 2023 applies directly.
Mainland companies
LLCs, private shareholding companies and most other entities licensed by DED fall within the regime. Register maintenance sits with the company and declarations are made to DED.
Non-financial free zones
Companies in non-financial free zones are generally within scope and declare to the relevant free-zone authority. Exact templates and portals vary by authority.
Financial free zones (DIFC/ADGM)
Separate beneficial-owner regimes under DIFC/ADGM law apply. We refer or coordinate with specialist financial-free-zone counsel rather than apply the mainland template.
Exemptions
Certain government-owned entities and listed companies have specific carve-outs. The assessment confirms which parts of the regime apply to your structure.
What a UBO engagement delivers
- 1
Ownership and control analysis
Map the ownership chain to natural persons. Apply the control tests where no single person meets the ownership threshold.
- 2
Register of beneficial owners
Draft or update the company's internal UBO register with the fields required by Cabinet Decision 109 of 2023.
- 3
Registrar declaration
Submit the declaration to the relevant registrar (DED or free-zone authority), with supporting evidence.
- 4
Change tracking
Document the triggers that will require a future update (share transfers, new controller, change of director) so the register stays current.
Frequently asked questions
Who is a beneficial owner?
Broadly, a natural person who ultimately owns or controls at least 25% of the entity, directly or indirectly, or who otherwise exercises control. Where no such person is identified, the person who holds a senior management position is treated as the beneficial owner. Specific definitions are in Cabinet Decision 109 of 2023.
Is UBO filed with the FTA?
No. UBO declarations are made to the commercial registrar (DED, free-zone authority or other licensing authority), not to the Federal Tax Authority. UBO sits outside the FTA tax regime.
Did ESR cancellation end UBO?
No. ESR and UBO are different regimes with different legal bases. The amendment to ESR reporting does not remove UBO obligations. UBO remains a continuing requirement.
Do DIFC and ADGM use the same rules?
No. DIFC and ADGM operate their own beneficial-owner regimes under their own laws. If your entity is in a financial free zone, the mainland Cabinet Decision does not apply directly; we engage specialist counsel for those cases.
Is AED 1,500 an all-in fee?
AED 1,500 covers a standard declaration for a single-entity structure with a clear ownership chain. Complex multi-tier structures, trust/nominee arrangements and remediation of inconsistent prior filings are quoted separately.
Request UBO support
Share your trade licence and a current shareholder certificate. We confirm the scope and fee in writing.
Start a UBO engagement