UBO Declaration Services in Dubai
Compliant UBO Filing for Dubai Mainland Companies Through an Authorised DET Service Centre
The Dubai Department of Economy and Tourism (DET) requires every mainland company to identify and register its Ultimate Beneficial Owners as a condition of licensing compliance. Over 513,000 establishments across the UAE, regulated by 38 licensing authorities, fall under the beneficial ownership framework established by Cabinet Resolution No. (109) of 2023 on Regulating the Real Beneficiary Procedures.
EGSH operates as an authorised Dubai Economy and Tourism service centre, facilitating UBO submissions through DET's official e-services platform on behalf of Dubai mainland companies. EGSH consultants review the company's ownership structure, prepare the required registers — the Register of Real Beneficiaries and the Register of Partners or Shareholders — and submit the beneficial ownership data directly to DET.
The terms Ultimate Beneficial Owner, Real Beneficiary, and Genuine Beneficiary are used interchangeably across official sources to describe the natural person who ultimately owns or controls a company.
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Real beneficiary filings are typically processed upon receipt of complete and accurate documentation, with confirmation issued through the DET e-services portal.
How to File a UBO Declaration in the UAE
A Structured and Compliant Process Through Official DET Systems
01
Visit EGSH
Book an appointment or walk in to EGSH with your company’s trade licence, Memorandum of Association, and identification documents of all shareholders and beneficial owners — VIP service with no queues.
02
Document and Ownership Review
An EGSH consultant verifies your company’s ownership structure against DET requirements and identifies the Ultimate Beneficial Owner (s) under the three-tier classification established by Cabinet Resolution No. (109) of 2023.
03
Register Preparation and Submission
EGSH prepares the Register of Real Beneficiaries and the Register of Partners or Shareholders in the format required by DET, then submits the data through DET’s official e-services platform.
04
Receive Your UBO Declaration Confirmation
Upon successful submission, the company receives confirmation from DET that the UBO data has been registered in the authority’s system, and records must be retained for a minimum of five years.
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Documents Required for a UBO Declaration in the UAE
Prepare the Required Documentation for Compliant Authority Submission
Company Licensing Documents
A valid trade licence and Memorandum of Association (or equivalent constitutional document) must be presented to verify the company’s legal form, ownership structure, and registered activities.
Identification of Shareholders and Beneficial Owners
Clear passport copies and Emirates ID (where applicable) for every shareholder, partner, and identified Ultimate Beneficial Owner must be provided, along with details of ownership percentages and voting rights.
Corporate Structure Documentation
For companies with layered or indirect ownership, a complete organisational chart showing all intermediate entities, shareholding percentages, and the chain of control leading to the natural person (s) identified as UBO must be submitted.
Power of Attorney or Authorisation Letter
If the submission is made by an authorised representative rather than the company’s owner or legal signatory, a notarised Power of Attorney or a signed and stamped company authorisation letter must accompany the application.
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What Is a UBO Declaration in the UAE
The UBO declaration in the UAE is a mandatory compliance process through which every licensed company identifies the natural person or persons who ultimately own or control the business, records their data in prescribed registers, and submits that data to the relevant licensing authority. The terms Ultimate Beneficial Owner, Real Beneficiary, and Genuine Beneficiary are used interchangeably across official and unofficial sources to describe this individual.
The regulatory framework underpinning the beneficial ownership obligation is built on several legislative instruments. The primary AML/CFT framework is established by Federal Decree-Law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations, which introduced the foundational requirement for entities to maintain beneficial ownership records. This law remains in force and is supported by subsequent regulations, including Federal Decree-Law No. (10) of 2025, which further strengthened the UAE's alignment with Financial Action Task Force (FATF) standards.
The specific procedures governing beneficial ownership registers, their content, submission, and ongoing maintenance are set out in Cabinet Resolution No. (109) of 2023 on Regulating the Real Beneficiary Procedures. This resolution came into effect on 16 November 2023 and replaced Cabinet Resolution No. (58) of 2020. Administrative penalties for non-compliance are defined separately under Cabinet Decision No. (132) of 2023, which was issued on 15 December 2023 and superseded Cabinet Decision No. (53) of 2021.
Who Is Considered an Ultimate Beneficial Owner
Under Cabinet Resolution No. (109) of 2023, the UBO is always a natural person — never a corporate entity. The resolution establishes a three-tier identification process. First, any natural person who directly or indirectly owns or controls 25% or more of the company's shares or voting rights is classified as the UBO. Second, if no such person can be identified, the individual who exercises control through other means — such as the right to appoint or dismiss the majority of directors — is considered the UBO. Third, if no natural person is identifiable under either of the first two tiers, the person holding the position of Senior Management Officer is deemed the beneficial owner.
Where ownership structures are complex or layered, the relevant licensing authority may apply a risk-based approach to determine the UBO, a discretionary power introduced under the current resolution.
Who Must File a UBO Declaration in the UAE
The obligation applies to all legal persons licensed and registered on the UAE mainland and in non-financial free zones across all emirates. This includes limited liability companies, sole proprietorships, civil companies, partnerships, and branches of foreign companies.
Certain categories are exempt. Companies incorporated in financial free zones, specifically the Abu Dhabi Global Market (ADGM) and the Dubai International Financial Centre (DIFC), are subject to their own beneficial ownership regimes and fall outside the scope of Cabinet Resolution No. (109) of 2023. Companies wholly owned, directly or indirectly, by the federal or local government are also exempt. The same applies to companies listed on a recognised stock exchange that imposes requirements ensuring sufficient transparency of beneficial ownership, as well as the 100% subsidiaries of such listed companies.
For Dubai mainland companies, the licensing authority responsible for receiving beneficial ownership submissions is the Dubai Department of Economy and Tourism (DET). EGSH, as an authorised DET service centre, facilitates this submission on behalf of companies through DET's official e-services platform.
What Information Must Be Included in the UBO Register
Companies are required to maintain two registers at their registered headquarters in the UAE.
The Register of Real Beneficiaries must contain the following data for each identified UBO: full name, nationality, date of birth, residential address, passport or national identity card number with issue and expiry dates, the basis for classification as a UBO, the percentage of ownership or nature of control, and the date on which the individual became or ceased to be a beneficial owner.
The Register of Partners or Shareholders must record the name, nationality, legal form (for entity shareholders), ownership interests and percentages, voting rights, address, and identification details of every partner or shareholder.
Both registers must be kept accurate and current. Any changes to the information contained in either register must be notified to the licensing authority within 15 business days of the change occurring.
Filing Deadlines and Ongoing Obligations
Under current practice, UBO data is typically required at the point of licensing or immediately after registration. Licensing authorities, including DET, may require beneficial ownership information as part of the initial trade licence application process. Companies that have not yet submitted their UBO registers should file without delay, as non-compliance may block licence renewals and amendments.
Beyond the initial filing, companies must update their registers and notify the licensing authority of any change in beneficial ownership within 15 days of the change. An annual verification is also required; companies must review and confirm the accuracy of their register data at least once per year.
Each company is required to appoint a natural person residing in the UAE as a designated contact for the licensing authority. This individual must be authorised to communicate with the registrar regarding all matters related to UBO data, updates, and requests for information.
In the event of dissolution or liquidation, the appointed liquidator must submit the Register of Real Beneficiaries and the Register of Partners or Shareholders to the registrar within 30 days of appointment. All records, data, and supporting documents must be retained for a minimum of five years from the date of dissolution, liquidation, or deregistration.
Penalties for Non-Compliance with UBO Requirements
Cabinet Decision No. (132) of 2023 establishes a progressive penalty framework for violations of the beneficial ownership regulations. For initial non-compliance, the registrar issues a written warning with a specified correction period. If the violation persists or recurs, monetary fines may be imposed, escalating with each repeated offence and reaching up to AED 100,000 for third and subsequent violations.
For serious or repeated violations, the registrar has the authority to temporarily suspend the company's trade licence or close the entity until the fine is paid and the violation is rectified. DET may refuse to process trade licence renewal applications if the company's UBO data is not current. The same restriction applies to trade licence amendment transactions involving ownership changes or structural modifications.
Companies that are the subject of penalties may file a grievance with the Grievances Committee within 30 days of notification. The Committee is required to adjudicate the grievance within 45 working days.
Separately, the submission of false or misleading information regarding beneficial ownership carries the risk of criminal liability under the broader anti-money laundering framework, including Federal Decree-Law No. (10) of 2025, which provides for imprisonment and substantial fines for individuals who intentionally provide incorrect UBO data to any authority.
UBO Compliance and Trade Licence Operations
The beneficial ownership filing is not an isolated regulatory obligation. It intersects directly with core DET licensing operations. DET may require current UBO data as a precondition for processing trade licence registration, renewal, and amendment transactions. Companies planning to amend their ownership structure, change shareholders, or restructure their business should ensure that UBO registers are updated before initiating any DET transaction.
For companies undergoing Dubai mainland company formation, the UBO identification and register preparation process should be integrated into the licensing workflow from the outset. Completing the UBO filing at the time of formation avoids the need for a separate compliance exercise and ensures the company is fully compliant from the date of licensing.
Confidentiality of UBO Data
UBO data submitted to the licensing authority is not publicly accessible. The registrar is prohibited from disclosing beneficial ownership information except to UAE competent authorities upon official request, or to foreign authorities under applicable international cooperation agreements. Companies and their beneficial owners should be aware that while the data remains confidential within the regulatory system, it may be shared with law enforcement, judicial, or regulatory bodies in the course of anti-money laundering investigations.
Frequently Asked Questions
What is a UBO declaration in the UAE?
A UBO declaration is the mandatory process of identifying the natural person or persons who ultimately own or control a company, maintaining this data in prescribed registers, and submitting it to the relevant licensing authority. For Dubai mainland companies, submissions are made to the Dubai Department of Economy and Tourism (DET) under Cabinet Resolution No. (109) of 2023.
Who is considered an Ultimate Beneficial Owner?
Under UAE regulations, the UBO is the natural person who directly or indirectly owns or controls 25% or more of a company’s shares or voting rights. If no such individual is identifiable, the person exercising control through other means is considered the UBO. As a final tier, the natural person holding a Senior Management position may be designated as the beneficial owner.
Which companies must file a UBO declaration in the UAE?
All legal persons licensed on the UAE mainland and in non-financial free zones must comply. This includes LLCs, sole proprietorships, civil companies, partnerships, and branches of foreign companies. Companies in the ADGM and DIFC financial free zones are exempt, as are government-owned entities and qualifying listed companies.
What are the penalties for not filing a UBO declaration?
Cabinet Decision No. (132) of 2023 establishes a progressive penalty structure starting with written warnings, followed by escalating fines for repeated violations. For serious or ongoing non-compliance, the registrar may suspend the trade licence. Submission of false or misleading UBO information may result in criminal liability under UAE anti-money laundering legislation.
What documents are needed for a UBO declaration?
The standard documentation includes a valid trade licence, the company’s Memorandum of Association, passport copies and Emirates ID of all shareholders and beneficial owners, and an organisational chart for companies with layered ownership structures. If an authorised representative submits on the company’s behalf, a notarised Power of Attorney or signed company authorisation letter is required.
How often must the UBO register be updated?
Companies must notify the licensing authority of any change in beneficial ownership within 15 days of the change. An annual verification of register accuracy is also required. Records must be retained for a minimum of five years, including after dissolution or deregistration.
Can EGSH submit the UBO declaration to DET on my behalf?
Yes. As an authorised DET service centre, EGSH reviews the company’s ownership structure, prepares both required registers in the format prescribed by DET, and submits the UBO data through DET’s official e-services platform.
Is UBO information made public?
No. UBO data submitted to the licensing authority remains confidential and is shared only with UAE competent authorities upon official request or with foreign authorities under applicable international cooperation agreements.
Official Sources
Ministry of Economy and Tourism (MOET) — Federal authority overseeing UBO compliance, beneficial ownership regulations, and AML/CFT implementation across the UAE.
Dubai Department of Economy and Tourism (DET) — Licensing authority and registrar for Dubai mainland companies; receives UBO register submissions through its official e-services portal.
UAE Legislation Portal — Official publication source for Cabinet Resolutions, Federal Decree-Laws, and associated regulatory instruments.
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Disclaimer
The information on this page is provided for general guidance purposes. Fees, timelines, and procedural requirements are current as of the date of publication and are subject to change by the relevant authorities without prior notice. EGSH does not provide legal, tax, or compliance advisory services. Companies with complex ownership structures should seek independent professional advice to determine their specific UBO obligations. All final compliance determinations are made by the relevant licensing authority.














































































































