Ultimate Beneficial Owner (UBO)


Regulation of Procedures relating to Real Beneficiaries – Cabinet Decision No. 58 of 2020

On 24th August 2020, the UAE Ministry of Economy issued a Cabinet Resolution No.58 of 2020 on the “Regulation of Procedures Related to Real Beneficiaries”.

Who has the Applicability of this Resolution?

  • It is applicable to all legal entities licensed or registered in the UAE including commercial free zones and
  • It excludes companies that are wholly owned by the federal or local government and its wholly owned subsidiaries and financial free zones (Abu Dhabi Global Market – ADGM and Dubai International Financial Centre – DIFC).

What are the Registers to be maintained?

  • Register of Shareholders
  • Register of Ultimate Beneficial Owners (UBO Register)

Time limit for creation / submission / updating of UBO information?

The legal person shall create and maintain an UBO Register within 60 days from:

        • Date of publication of this Resolution which is August 24, 2020 or
        • The date of the registration (in case of new company)

In case of any changes, legal person shall update the Register with in fifteen (15) days from the date of being aware of the change.

Who is the Ultimate Beneficial Owner of the Company?

    • The natural person who owns or finally controls the company directly or indirectly through:
        • Holding 25% or more equity of the company
        • Having 25% or more voting powers of the company
        • Appointing or dismissing most of the directors of the company.
    • If more than a person is owning the shares or controlling the company, then all of them shall be treated as beneficial owners.
    • If UBO is not known, or there is a suspicious about the UBO, then Natural Person who exercises control over the legal person (through other mean) shall be deemed beneficiary
    • If there is no UBO for the legal person in accordance with the above, the UBO shall be deemed to be the natural person who occupy the senior management position.


A number of administrative sanctions may be imposed on any violations of the cabinet resolution.

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