中文: 阿联酋实益拥有人（UBO）登记：谁算、公司要保存什么
Short answer
UAE companies, including those in commercial free zones, must keep a register of their beneficial owners and a register of partners or shareholders, and provide the data to their registrar, under Cabinet Decision No. 109 of 2023 [S2][S3]. The decision was issued on 6 November 2023 [S1][S2].
Who it covers
The decision applies to legal persons registered or licensed in the country, including in commercial free zones [S2]. Exempted are companies wholly owned by the federal or local government (and companies wholly owned by them), financial free zones, and the "Governmental Partner" [S2].
Who is a beneficial owner
A beneficial owner is whoever owns or exercises ultimate control over the company through direct or indirect ownership of 25% or more of its capital, or 25% or more of the voting rights, including through a chain of ownership, or through control by other means such as the right to appoint or dismiss the majority of directors [S2]. If no such natural person is identified, the decision sets a fallback: the natural person who exercises control by other means and, failing that, the natural person in a senior management position [S2].
The registers and deadlines
- The company keeps a Beneficial Owner Register, created within 60 days of the decision's issue or of the company coming into existence, and updates it within 15 days of learning of any change [S2].
- The company also keeps a Register of Partners or Shareholders [S2][S3].
- The company provides the register data to its registrar within 60 days of the decision's enforcement or of its licensing or registration [S2].
How to file
Filing is made to the company's own licensing or registration authority, using that authority's process. Ajman Free Zone, for example, publishes its own UBO declaration page [S3].
Penalties
A separate decision, Cabinet Decision No. 132 of 2023, sets administrative penalties for violations [S3]. Check the amounts with your registrar.
Note on Lexoford
Lexoford Services helps with company setup. This page summarises the published decision; it is not legal advice.
For reference only. The competent authority's rules prevail.
Sources
- [S1] UAE Legislation, Cabinet Resolution Regulating the Real Beneficiary Procedures
- [S2] Cabinet Decision No. 109 of 2023 (English PDF, Ministry of Economy) (Articles 3, 5, 8, 10 and 11)
- [S3] Ajman Free Zone, UBO
FAQ
What law requires a UBO register in the UAE?
Cabinet Decision No. 109 of 2023 on the Regulation of Beneficial Owner Procedures [S1][S2].
Do free zone companies need a UBO register?
Commercial free zone companies are covered; financial free zones are exempt [S2].
Who counts as a beneficial owner?
A natural person with 25% or more of the capital or voting rights, directly or indirectly, or control by other means such as appointing or dismissing most directors [S2].
What if no one holds 25%?
The decision treats the person controlling by other means as the beneficial owner and, failing that, a senior management official [S2].
When must the register be created?
Within 60 days of the decision's issue or of the company coming into existence [S2].
How quickly must changes be recorded?
Within 15 days of the company learning of the change [S2].
Is a shareholder register also required?
Yes, a Register of Partners or Shareholders [S2][S3].
Where is the UBO information filed?
With the company's own registrar or licensing authority, using its process [S2][S3].
Are there penalties?
Cabinet Decision No. 132 of 2023 sets administrative penalties; check amounts with your registrar [S3].