File UAE Ultimate Beneficial Owner Declaration (UBO register/form)

Skill: Turn an ownership structure into a UAE UBO declaration

Region: United Arab Emirates Category: Government — UBO Does: Takes a company's ownership and control structure and assembles the UBO declaration — the Real Beneficiary, Nominee Director and Partners/Shareholders registers a UAE entity files with its Registrar / licensing (free-zone) authority to disclose its Ultimate Beneficial Owners. Spec: Registrar / free-zone authority — UBO declaration under Cabinet Resolution No. 109 of 2023 (Beneficial Owner Procedures), replacing Cabinet Resolution No. 58 of 2020 (current version)

Cabinet Resolution No. 109 of 2023 requires most UAE companies (mainland and free-zone, with limited exemptions) to maintain and file a Register of Real Beneficiaries, a Register of Partners/Shareholders, and a Register of Nominee Directors/Managers with the relevant Registrar. A Real Beneficiary is generally a natural person who ultimately owns or controls (directly or indirectly) 25% or more of shares/voting rights, or otherwise exercises ultimate control. Field names below follow the declaration form, not a verbatim schema.

When this applies

• A UAE legal entity (LLC, free-zone company, etc.) must create/update its UBO registers and file the declaration with its Registrar — at incorporation and whenever ownership or control changes.
• Entities directly or wholly owned by the federal/local government, and certain regulated/listed entities, may be exempt — confirm the entity is in scope.
• Changes to beneficial owners, partners or nominee arrangements must be notified to the Registrar within the prescribed period (typically 15 days).

Structure (registers → declaration)

Entity details (following the form):
  Legal name, licence number, licensing authority, legal form, address

Register of Real Beneficiaries (repeating natural persons):
  Full name (as in ID), nationality
  Emirates ID / passport number, date & place of birth
  Residential address, contact
  Basis of beneficial ownership   ownership % / voting rights / ultimate control
  Date became / ceased to be a beneficial owner

Register of Partners / Shareholders (repeating):
  Name, number & class of shares / ownership %, voting rights
  For corporate owners: the chain up to the natural-person UBO

Register of Nominee Directors / Managers (where applicable):
  Nominee name + the person on whose behalf they act

Data rules

• Identify the natural-person UBO(s): trace the ownership chain through intermediate entities to the natural person(s) holding ≥25% or exercising ultimate control; where no person meets the threshold, the senior managing official is recorded as the fallback.
• Each individual fully identified: name as per ID, nationality, Emirates ID or passport number, date/place of birth, address, and the basis and date of becoming a beneficial owner.
• The three registers must reconcile: the Partners/Shareholders register and the ownership chain must support the Real Beneficiaries determination; nominee arrangements disclosed.
• Keep current: notify the Registrar of changes within the prescribed period; non-filing/inaccurate filing attracts administrative penalties.
• Filed/maintained with the entity's licensing authority (DED for mainland, or the specific free-zone authority); DIFC/ADGM maintain their own beneficial-ownership regimes.

Worked example (outline)

Entity: ABC Trading LLC, licence 56789, Dubai DED, LLC
Partners: Holdings X FZ-LLC 60%, Ms. A 40%
Chain: Holdings X FZ-LLC is owned 100% by Mr. B (natural person)
Real Beneficiaries register:
  Mr. B — basis: 60% indirect ownership via Holdings X — passport P1234567, since 2022-03-01
  Ms. A — basis: 40% direct ownership — Emirates ID 784-..., since 2020-01-15
Nominee directors: none

Filed with the licensing authority and kept current as ownership changes.

Validation checklist

• Entity in scope (not an exempt government/regulated/listed entity)
• Natural-person UBO(s) identified via the ownership/control chain (≥25% or ultimate control; senior-official fallback)
• Each UBO fully identified: name, nationality, Emirates ID / passport, DOB, address, basis & dates
• Partners/Shareholders register reconciles with the Real Beneficiaries determination
• Nominee directors/managers disclosed where applicable
• Filed with the correct licensing authority; DIFC/ADGM use their own regimes
• Changes notified within the prescribed period (typically 15 days)

Last updated: 2026-06-04 — confirm the current schema/version, registers, exemptions, thresholds, identifiers, and deadlines against current authority (relevant Registrar / free-zone authority, Cabinet Resolution No. 109 of 2023) guidance before use; DIFC/ADGM maintain separate regimes.