The first general UAE beneficial ownership regime. It required mainland and free zone companies (outside the financial free zones) to keep registers of beneficial owners, partners or shareholders and nominee directors and to file them with their registrars within sixty days. Repealed Cabinet Decision No. 34 of 2020 and was itself repealed by Cabinet Decision No. 109 of 2023.
Cabinet Decision No. 58 of 2020 was the first general UAE beneficial ownership regime. Effective from 25 August 2020, it repealed Cabinet Decision No. 34 of 2020 (Article 19) and was itself repealed by Cabinet Resolution No. 109 of 2023, which the Central Bank rulebook records as the repealing instrument. It is kept in the library because free zone portals, bank forms and older board resolutions still refer to it.
The structure is the one the 2023 resolution carried forward. Article 3 applied it to registrars and to all licensed or registered legal persons, including those in commercial free zones, while excluding wholly government-owned companies, their wholly owned subsidiaries and the financial free zones. Article 5 set the identification test: any natural person holding 25% or more of the shares or voting rights, directly or through a chain of ownership, failing that a person exercising control by other means, failing that the senior manager. Article 6 required reasonable steps to obtain and keep accurate beneficial owner data and exempted entities owned by companies listed on a recognised exchange with adequate disclosure.
Article 8 required a Register of Beneficial Owners to be set up within 60 days and updated within 15 days of a change, with notification to anyone entered without their knowledge and a court route to correct entries. Article 9 obliged nominee board members to disclose their status within 15 days (30 days for existing nominees). Article 10 required a Register of Partners or Shareholders with holdings, voting rights, acquisition dates and identity details. Article 11 required both registers to be filed with the registrar within 60 days of the decision's promulgation or of licensing, named a UAE-resident natural person as point of contact, banned bearer share warrants, required handover to a liquidator and five-year retention. Article 14 required changes to be notified to the registrar within 15 days.
Article 17 allowed the Minister or a delegated licensing authority to impose sanctions from a list set by Cabinet decision (which became Cabinet Resolution No. 53 of 2021); Article 18 allowed a grievance within 30 days, decided within 30 days.
What changed in 2023: the tests, deadlines and registers survived almost unchanged; Cabinet Resolution No. 109 of 2023 moved penalty powers to the registrar, lengthened the appeal committee's decision period to 45 working days, added a 14-day limit for answering registrar data requests and was paired with a new penalty schedule in Cabinet Resolution No. 132 of 2023. Status: repealed.
Historically, every legal person licensed or registered in the UAE mainland or a commercial free zone, its nominee board members, shareholders and beneficial owners, and the licensing authorities acting as registrar; excluded wholly government-owned companies and the financial free zones. No longer in force; replaced by Cabinet Resolution No. 109 of 2023.
| Article 1 | Defines the beneficial owner as the natural person who ultimately owns or controls the legal person, whether directly or through a chain of ownership, together with nominee board member, higher management and the two registers. |
| Article 3 | Scope: registrars and licensed or registered entities including commercial free zones; excludes wholly government-owned companies, their wholly owned subsidiaries and the financial free zones. |
| Article 5 | Identification test: 25% or more of the shares or voting rights, directly or through a chain of ownership, jointly held stakes aggregated, then control by other means, then senior management as fallback. |
| Article 8 | Register of Beneficial Owners to be set up within 60 days and updated within 15 days of a change, with notification to persons entered without their knowledge and a court application to correct the register. |
| Article 9 | Nominee board members must disclose their status and principal within 15 days and report changes or cessation within 15 days; existing nominees had 30 days from the decision's entry into force. |
| Article 11 | Both registers filed with the registrar within 60 days of promulgation or licensing; UAE-resident natural person named as point of contact; bearer share warrants banned; liquidator handover; five-year retention. |
| Article 14 | All registers must be kept accurate and the registrar notified of any change within 15 days. |
| Article 17 | The Minister, or a licensing authority delegated by the Minister, may impose sanctions from a list set by Cabinet decision. |
| Article 19 | Repeals Cabinet Decision No. 34 of 2020 on the regulation of beneficial owner procedures and any conflicting provision. |
The decision itself set no amounts. Article 17 referred sanctions to a Cabinet list, which was Cabinet Resolution No. 53 of 2021; that list has been replaced by Cabinet Resolution No. 132 of 2023, which now applies under the 2023 regime.
We meet this decision in legacy paperwork: RAKEZ, Ajman and DMCC portal forms, bank beneficial-ownership declarations and board resolutions drafted in 2020 to 2023 often recite Cabinet Decision No. 58 of 2020 as the basis for the UBO declaration. The substantive content (25% test, 60-day filing, 15-day updates, resident point of contact) is the same under Cabinet Resolution No. 109 of 2023, so a declaration made under the old decision remains accurate; what we change is the citation and, where a penalty clause is quoted, the reference to Cabinet Resolution No. 132 of 2023. When onboarding a company previously administered elsewhere, we check that the register filed under the 2020 decision was actually updated for later changes, because the 15-day update duty carried over and unfiled changes are the most common gap we find.
Beneficial Owner Procedures 2023
The current UAE beneficial ownership regime, replacing Cabinet Decision No. 58 of 2020. Companies licensed in the mainland and in non-financial free zones must identify t…
UBO Administrative Penalties 2023
Sets the administrative penalties for breaches of the 2023 beneficial ownership resolution: failure to keep or file registers of real beneficiaries, shareholders and nomi…
AML Implementing Regulation 2019 (repealed)
The former executive regulation of the 2018 AML law. It defined the DNFBP categories (including trust and company service providers), set customer due diligence, record-k…
AML Law 2018 (repealed)
The former UAE AML/CFT law, in force from October 2018, which first brought designated non-financial businesses and professions under federal AML supervision and goAML re…
RAKEZ UBO Regulations 2019
Zone-level beneficial ownership rules issued 28 August 2019 under Law No. 2 of 2017 requiring RAKEZ-registered entities to identify their beneficial owners, keep a regist…
Whether you are establishing a new venture, restructuring an existing enterprise, or exploring residency pathways — we are here to advise.
Arrange a Consultation →