UBO Annual Declaration
Annual Ultimate Beneficial Owner declaration filed with the licensing authority (Free Zone or DED). Identifies natural persons with 25%+ ownership or substantial control. The register must hold each beneficial owner's full name, nationality, date of birth, address and the percentage and nature of ownership or control. A beneficial owner holds 25 percent or more of the share capital or voting rights, or exercises control by other means. The register is kept by the company and filed with the licensing authority.
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Who this applies to
- All UAE-licensed companies
- Excludes companies wholly owned by federal/local government
What to file
UBO register with full legal name, nationality, DOB, address, and ID document for each beneficial owner. Many authorities ask for a signed declaration at licence renewal.
How to file
Via the licensing authority's portal: DMCC, IFZA, DED, etc. Each authority has its own form and upload process, and a mainland company should ask its licensing department for the current template.
Payment due
No fee.
Penalties for missing this deadline
AED 50,000 for failure to maintain register. AED 100,000 for failure to provide accurate info. The fines apply to the company and its managers, and they run alongside any licence consequences from the authority, so a lapsed register can hold up a licence renewal.
Filing checklist
- Identify all 25%+ beneficial owners
- Identify any individuals exercising substantial control
- Collect required ID documents
- File UBO declaration with authority
- Update within 15 days of any change
- Record the percentage of ownership and the nature of control for each beneficial owner
Documents you'll need
- Passport copies and Emirates ID copies of each beneficial owner
- Share register and shareholder agreements
- Trust deeds or nominee agreements if shares are held through them
- Organisation chart showing ownership chains above the company
Common mistakes to avoid
- Forgetting to update on shareholder changes
- Not identifying control through trusts or nominee structures
- Missing the 15-day update window
- Recording only the immediate shareholder when the shares are held through another company, so the individual at the top of the chain is missing
- Keeping the register on a shared drive but not filing it with the authority
Never miss a United Arab Emirates deadline
AccountsOS tracks every Federal Tax Authority (FTA) and Department of Economic Development (DED) / Free Zone Authority deadline and reminds you weeks ahead.
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