Key Takeaways
- Companies licensed or registered in the UAE, including those in non-financial free zones, have 60 days from licensing to hand their registers to the registrar (Cabinet Decision 109 of 2023).
- The beneficial owner is the real person behind the company who holds or controls 25% or more of the capital or votes. When that changes, you have 15 days from the moment the company learns of it to update the register.
- For most duties, the first breach gets you a written warning. Fines come with the second, and a third can lead to your licence being suspended (Cabinet Resolution 132 of 2023).
- A company that never sets up its beneficial owner register pays AED 50,000 for a second breach and AED 100,000 for a third.
- The anti-money laundering law, Federal Decree-Law 10 of 2025, applies from 14 October 2025. Businesses in certain sectors also have to register on goAML.
Once your UAE trade licence is issued, a clock starts. Within 60 days you have to give the registrar two records. One is the UBO register, short for ultimate beneficial owner register, which names the people who really own or control the company. The other is a register of its partners or shareholders. This page explains who has to do it, the deadlines, the fines and the anti-money laundering (AML) duties that come with it, as the rules stood in October 2026. The English texts of the decisions are translations hosted by the government. If they differ from the Arabic, the Arabic wins.
Who must file and who is exempt
The duty covers every legal person licensed or registered in the UAE. That includes companies in non-financial free zones (Cabinet Resolution 132 of 2023, Article 2). Companies in the financial free zones are outside the federal rules, and so are companies the government owns outright.
The two financial free zones, the Dubai International Financial Centre (DIFC) and Abu Dhabi Global Market (ADGM), have their own registrar rules. The DIFC Registrar's handbook, for example, gives a company 30 days to report changes, and a change of UBO is one of them (September 2026).
You send the registers to whichever authority keeps your trade name register. A mainland company, meaning one licensed anywhere in the emirate outside a free zone, deals with its licensing department. A free zone company deals with its free zone authority. The current rules are in Cabinet Decision 109 of 2023, issued on 6 November 2023. It replaced Cabinet Decision 58 of 2020 (Article 22).
What a beneficial owner is
A beneficial owner is the real person who, at the end of the chain, owns or controls the company. It's always a human being, never another company. The usual test is 25% or more of the capital or the votes, whether held directly, indirectly or by some other means (Cabinet Decision 109 of 2023). If a holding company owns your shares, you look past it to the people who own the holding company.
Banks use the same 25% test. Before they open an account they run customer due diligence, the checks a bank makes to find out who it is really dealing with (Cabinet Resolution 134 of 2025). When your UBO register names the same people the bank has found, you'll get fewer questions at the account opening stage.
Registers and deadlines
You need both records: the beneficial owner register and the register of partners or shareholders. When shares change hands, the company may only record the transfer once the new holder has said whether the beneficial owner changes as a result (Article 8(5)). Bearer shares, which belong to whoever holds the paper certificate, are banned.
Use the table below to put each deadline in your diary.
| Duty | Deadline | Source |
|---|---|---|
| Set up both registers and send them to the registrar | Within 60 days of licensing or registration | Cabinet Decision 109 of 2023, Articles 8 and 11 |
| Update the beneficial owner register after a change | Within 15 days of the company finding out | Article 8(1) |
| Update the register of partners or shareholders | Within 15 days of becoming aware | Article 10(1) |
| A nominee board member tells the company that they act as a nominee, or that this has ended | Within 15 days | Article 9 |
| Tell named persons or board members about a share issue | Within 15 days | Article 11(6) |
| Send the registrar any extra data it asks for | Within 14 days | Article 11(2) |
| Hand the registers to the liquidator | Within 30 days; records kept for 5 years | Cabinet Decision 109 of 2023 |
Company law adds a second set of dates. If the company changes its name, address, capital, shareholders or legal form, the authority must hear about it within 15 working days (Commercial Companies Law, Article 15, 2021 text; check the current wording after Federal Decree-Law 20 of 2025). The register of partners also goes to the authority every January (Article 74). Both belong in the company calendar.
The authorised person and nominee disclosure
Every company has to name one person who lives in the UAE and is authorised to give the registrar its beneficial owner information. It must be an individual. If nobody holds the role, that alone counts as a breach and is fined.
Nominees come with a disclosure duty of their own. A nominee is someone who holds shares or a board seat on behalf of another person. Nominee directors and nominee shareholders must declare that they act as nominees (Cabinet Resolution 134 of 2025), and the registrar can fine a company that doesn't pass this information on. Banks watch for the same thing. Central Bank guidance names nominee shareholders, and owners who are reluctant to say who controls the company, as red flags. A gap in your disclosure will show up when the bank checks you too.
DNFBPs, goAML and the 2025 AML law
The UAE's anti-money laundering law changed in 2025. Federal Decree-Law 10 of 2025 took effect on 14 October 2025 and replaced Federal Decree-Law 20 of 2018. Its Executive Regulations, issued as Cabinet Resolution 134 of 2025, followed on 14 December 2025.
The regulations name certain trades as designated non-financial businesses and professions (DNFBPs). These are businesses outside banking that still have money laundering duties. Real estate brokers and agents are on the list. So are dealers in precious metals and stones, for cash deals of AED 55,000 or more, and commercial gaming from AED 11,000. Lawyers, notaries and independent accountants are covered for specified transactions, and the same goes for company and trust service providers. A DNFBP keeps its records for at least 5 years.
DNFBPs supervised by the Ministry of Economy and Tourism (MoET), whether on the mainland or in a free zone, must register on goAML. That's the online system used to report suspicious transactions. You start on the SACM portal and then log in to goAML with a one-time password. The Ministry asks for an authorisation letter, the Emirates ID or passport, and a copy of the trade licence (MoET, October 2026).
Registration is due when the regulated activity starts. Your supervisor can tell you the deadline that applies today.
The Ministry has shown it enforces this. On 21 August 2023 it announced that 50 DNFBP establishments had been suspended for three months because they hadn't registered. It also said it had fined 225 DNFBP companies about AED 76.9 million since the start of 2023. Under the 2025 law, criminal and administrative penalties can run into millions of dirhams.
Most companies aren't DNFBPs. They still meet the same questions at the bank, which runs its customer due diligence on the people named in the registers described above.
Consequences of not filing
The fines are set by Cabinet Resolution 132 of 2023. For most duties a first breach brings a written warning, and you then have 15 or 30 days to put it right. Money penalties begin with the second breach. After a third, the registrar can also suspend the commercial licence and close the shop until you've paid and fixed the problem (Article 3).
The table lists what each breach costs the second and third time.
| Breach | Second breach | Third breach |
|---|---|---|
| Beneficial owner details not registered properly | AED 20,000 | AED 40,000 |
| No beneficial owner register set up, or ownership layers in a complex structure not disclosed | AED 50,000 | AED 100,000 |
| Beneficial owner register not updated | AED 15,000 | AED 30,000 |
| Nominee director data not given to the registrar | AED 40,000 | AED 80,000 |
| No register of partners or shareholders set up | AED 50,000 | AED 100,000 |
| That register not updated within 15 days | AED 15,000 | AED 30,000 |
| Incomplete data in that register | AED 30,000 | AED 60,000 |
| Registers not provided, extra data not sent within 14 days, or share issue not disclosed within 15 days | AED 15,000 | AED 30,000 |
| No UAE-resident authorised person named | AED 10,000 | AED 20,000 |
You can challenge a fine within 30 days of being notified (Cabinet Decision 109 of 2023). One oddity: the resolution still refers to the 2018 AML law, which has since been repealed. The Cabinet can change the amounts at any time (Article 4). Your licensing authority can confirm whether this schedule is still the one in use.
Problems here spill into other paperwork. With a suspended licence you can't complete a licence renewal, and a bank will hold up an application when the ownership chain it sees doesn't match your registers.
Who helps with the registers
Plenty of owners handle this alone. With one shareholder and a standard licence, you can usually draft both registers, name the authorised person and submit them yourself. Watch three things: the 60 days that start at licensing, the 15 days that start again after every share transfer, and the layers of any holding structure. Miss an update and you'll get a warning first, then AED 15,000 if it happens again.
Keeping registers up to date is part of corporate secretarial work, the routine legal admin of running a company. A lawyer or an accounting firm can take it on together with the share register and your other company filings. For the rest of what's due in year one, see the Corporate Tax guide.
AdvisoryHub may receive a fee when you request an introduction; it does not affect the information on this page.
More Company Setup Guides
Related Company Setup Guides
- PRO services Dubai and UAE, tasks, fees and how to choose
- Corporate Tax registration UAE, deadline, QFZP and penalties
- Ejari Dubai for businesses, what it is and when you need it
- Tax residency certificate Dubai, who can apply and fees
- Trade license renewal Dubai, steps and common blockers
- Business bank account Dubai, documents and published fees
- Qualifying Free Zone Person explained, when 0% tax applies
- VAT registration UAE for a new company, threshold and process
- Lawyers in the UAE
- Audit firms in the UAE
- Accounting firms in the UAE
