Ubo Declarations In The Uae: What Companies Need Ready

By Author: Samuel Watts
Total Articles: 10
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Understanding who ultimately owns or controls a business is an important part of corporate transparency and regulatory compliance in the UAE. A UBO Declaration helps authorities identify the individuals behind a company's ownership structure, supporting accountability and reducing the risk of financial crime.
For businesses, meeting these requirements involves more than submitting ownership details. Companies must maintain accurate records, verify beneficial ownership information, and keep relevant filings updated as ownership structures change.
What Is a UBO Declaration?
A UBO Declaration identifies the Ultimate Beneficial Owners of a company. Under UAE Cabinet Decision No. 109 of 2023, a beneficial owner generally includes an individual who directly or indirectly owns or controls 25% or more of a company's capital or voting rights.

Beneficial Ownership can also arise through other forms of control, including the authority to appoint or remove most board members. Where no individual can be identified through ownership or control after applying the relevant criteria, senior management may be considered ...
... under the prescribed rules.

This framework helps establish transparency across corporate structures, including businesses with multiple shareholders or holding companies.
What Ownership Information Should Companies Prepare?
Before completing a UBO Declaration, businesses should organise the information needed to establish and verify their ownership structure.

Key records include:
- Shareholder information: Names, ownership percentages, shareholding arrangements, and voting rights.
- Beneficial owner identification: Full name, nationality, date of birth, residential address, and identification document details.
- Corporate ownership structure: Documents showing direct and indirect ownership through parent companies or subsidiaries.
- Supporting records: Trade licences, incorporation documents, shareholder registers, and relevant ownership agreements.
- Ownership changes: Records of share transfers, changes in controlling interests, and dates when beneficial ownership began or ended.

Maintaining consistent information across these records can reduce discrepancies during regulatory reviews and corporate verification.
How Should Businesses Manage UBO Filings?
Companies subject to UAE beneficial ownership requirements must maintain a Beneficial Owner Register and a Register of Partners or Shareholders.

Under Cabinet Decision No. 109 of 2023, relevant records generally must be established and submitted within 60 days of incorporation or registration. Changes to beneficial ownership records must be recorded within 15 days of becoming known.

Businesses should also confirm the submission procedures applicable to their licensing authority, as mainland and free zone filing processes may differ.

A practical filing process should include reviewing ownership records, validating supporting documents, assigning internal responsibility, and tracking relevant submission deadlines.
How Does Beneficial Ownership Support Know Your Customer Compliance?
Beneficial Ownership information also plays an important role in Know Your Customer (KYC) and Anti-Money Laundering checks.

When businesses establish relationships with customers, suppliers, investors, or other third parties, identifying the individuals who ultimately control those entities can help strengthen due diligence.

Reliable ownership information supports companies in identifying complex corporate structures, assessing potential compliance risks, and conducting appropriate screening.
It also helps reduce reliance on incomplete company registration information when evaluating business relationships.
Why Is Ongoing UBO Monitoring Important?
A UBO Declaration should not be treated as a one-time administrative requirement.

Shareholders may change, ownership percentages may shift, and restructuring may introduce additional layers of control. Without regular reviews, previously submitted information can become inaccurate.

Companies should periodically reconcile ownership records, document changes, and establish procedures for updating declarations when necessary.
Strengthening Corporate Transparency Through Reliable Business Information
Effective UBO compliance depends on accurate company information, clearly documented ownership structures, and consistent record maintenance.

Dun & Bradstreet UAE supports businesses with company information and business intelligence that can strengthen corporate due diligence and Know Your Customer processes.

By combining reliable business data with structured internal compliance procedures, companies can improve ownership visibility, support informed decisions, and maintain greater confidence in their business relationships.