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The UBO register in the UAE is a record of the real people who own or control a company. Anyone with 25% or more of the shares or votes, or control by other means, goes on it. Mainland companies and companies in commercial free zones must keep the register and give it to their registrar, which for a free zone company is the free zone authority. You usually hand over the first version with your setup application.
This guide is general information from UAEFreeZoneDirectory.com, an independent directory. We are not a registrar, and your free zone has the final word on its own forms and deadlines.
The law behind it
The rules are in Cabinet Decision No. 109 of on the procedures for the real beneficiary. It replaced Cabinet Decision No. 58 of , so older guides that quote Decision 58 are out of date. Penalties for breaking the rules sit in a separate decision, Cabinet Decision No. 132 of .
The decision covers mainland legal persons and legal persons in commercial free zones. Financial free zones, meaning DIFC in Dubai and ADGM in Abu Dhabi, are not named in the sources we read and run their own registries. If your company is there, follow DIFC or ADGM rules.
Who counts as a beneficial owner
A beneficial owner is a natural person who:
- owns 25% or more of the company's shares, directly or through other companies, or
- holds 25% or more of the voting rights, or
- controls the company by other means, even with a smaller share.
Three quick examples:
- You own 100% of an FZE. You are the only beneficial owner.
- Four friends each own 25% of an FZCO. All four are beneficial owners.
- A holding company abroad owns 100% of your FZ-LLC, and two people own that holding company equally. Both people are beneficial owners of your company, because each holds 50% through the parent.
If nobody reaches 25% and nobody controls by other means, ask your registrar who it expects you to name. Do not leave the register empty.
Deadlines: where the sources disagree
| Event | Cabinet Decision text (snippet) | SRTIP rules page |
|---|---|---|
| First register for a new company | Within 60 days | Within 15 days of incorporation |
| Recording a change | Within 15 days | Within 15 days |
| Review | Not stated in the snippet | Yearly |
Sources: Cabinet Decision No. 109 text published by the Ministry of Economy and Tourism (summary only; we did not open the full text) and the SRTIP free zone rules page, checked .
We could only read the decision as a snippet, so treat the 60 day figure with care. In practice the question rarely bites at setup, because most zones take UBO details inside the application. The 15 day change deadline is the one that catches owners out, and both sources agree on it.
How free zones collect UBO details
You will meet the register at several points, not just once:
- At setup. IFZA's application form includes a UBO section. Jafza asks for UBO KYC documents. Dubai CommerCity lists UBO documents in its setup steps. Creative City Fujairah has you sign the incorporation contracts and UBO declaration before the licence is issued.
- For corporate shareholders. UAQ Free Trade Zone asks a corporate subsidiary for an ownership chart up to the beneficial owners.
- At renewal. Fujairah Free Zone and RAK Maritime City both list UBO papers in their renewal checklists.
- In an offshore company. At RAK ICC, the registered agent holds the beneficial owner records for each company.
When ownership changes through a share transfer, the UBO update usually travels with the shareholder amendment. Our licence amendment page covers that process, and the MOA and board resolution page explains the resolution most zones want with it.
What to keep on file
Keep your own copy of everything you give the zone:
- ID details of each beneficial owner and how they hold their share or control
- The ownership chart, if any shareholder is a company
- Corporate documents of parent companies, often attested (see company document attestation)
- The date each person became, or stopped being, a beneficial owner
Banks ask for the same chart when you open an account, so one accurate version saves work twice.
Common mistakes
- Naming the parent company instead of the people behind it.
- Forgetting nominee or side agreements that give someone control below 25%.
- Treating the register as a setup task and never updating it.
- Relying on guides that still cite Decision 58.
Economic substance filings, by contrast, are no longer due for recent years. See the ESR guide. For the full set up sequence, read the free zone company setup steps.
Sources
- Cabinet Decision No. 109 on beneficial owner procedures (scope, replacement of Decision 58, timing snippet)
- https://srtip.ae/free-zone-rules-and-regulations/ (25% definition, 15 day deadlines, penalties decision)
- https://ifza.com/en/set-up-your-business/ (UBO in the IFZA application)
- https://www.jafza.ae/business-setup/company-formation/ (UBO KYC documents)
- https://www.dubaicommercity.ae/set-up-a-business (UBO documents in setup)
- https://creativecity.gov.ae/faqs/ (UBO signed at setup)
- Fujairah Free Zone renewal process and RAK Maritime City renewal checklist (UBO at renewal)
