Sets the administrative penalties for breaches of the 2023 beneficial ownership resolution: failure to keep or file registers of real beneficiaries, shareholders and nominee directors, failure to update changes or to appoint a point of contact, and giving false information. The attached table grades fines from written warnings to AED 100,000 per violation, with licence suspension or restriction for repetition.
Cabinet Resolution No. 132 of 2023 is the penalty schedule for the UAE beneficial ownership regime. Issued on 15 December 2023 and in force from the day after its Official Gazette publication (30 December 2023), it lists the administrative penalties a registrar may impose on a company that breaches Cabinet Resolution No. 109 of 2023, and it repealed the previous list, Cabinet Resolution No. 53 of 2021 (Article 8).
Article 2 applies it to every legal person licensed or registered in the UAE, including the non-financial free zones. Article 3 lets the registrar impose the penalties in the attached table without prejudice to other sanctions and, on a third violation, suspend the commercial licence and close the premises until the fine is paid and the breach corrected. Article 4 lets the Cabinet amend the fines, Article 5 provides for revenue sharing between the federal and emirate governments, and Article 6 has fines collected by Ministry of Finance methods.
The table grades each violation across first, second and third occurrences. A first violation draws a written notice to correct within 15 or 30 days; the second and third draw fines. The heaviest lines are failure to create a real beneficiary register or a partners or shareholders register (AED 50,000 then AED 100,000), failure to disclose the classes of real beneficiary in a complex structure (AED 50,000 then AED 100,000) and a liquidator's failure to keep records for five years (AED 100,000). Failure to provide director or nominee board member data costs AED 40,000 then AED 80,000; omitting partner data from the shareholder register AED 30,000 then AED 60,000; recording real beneficiary details incorrectly or incompletely AED 20,000 then AED 40,000; failing to update either register within 15 days, failing to provide additional data within 14 days, failing to keep register records or failing to disclose shares issued in other persons' names AED 15,000 then AED 30,000; failing to name a resident authorised person AED 10,000 then AED 20,000; and failing to hand registers to a liquidator within 30 days AED 5,000 then AED 10,000.
The resolution contains no grievance article of its own; appeals follow Article 19 of Cabinet Resolution No. 109 of 2023 (Registrar Appeal Committee, 30 days to appeal, decision within 45 working days). Status: in force; no amendment recorded.
Every legal person licensed or registered in the UAE mainland or a non-financial free zone that breaches Cabinet Resolution No. 109 of 2023, its managers and nominee board members, and liquidators; the licensing authorities acting as registrar impose the penalties. DIFC and ADGM entities fall under those centres' own regimes.
| Article 2 | Scope: licensed or registered legal persons in the State, including those in non-financial free zones, that violate the real beneficiary procedures resolution. |
| Article 3 | The registrar may impose the penalties in the attached table; on a third violation it may also suspend the commercial licence and close the premises until the fine is paid and the violation corrected. |
| Article 4 | The Cabinet may add to, delete or amend the fines in the table on the Minister's proposal. |
| Article 6 | Fines are collected by the methods set by the Ministry of Finance; a part of a day or month counts as a whole day or month for compliance periods. |
| Article 8 | Repeals Cabinet Resolution No. 53 of 2021 and any provision that conflicts with the resolution. |
| Article 9 | Published in the Official Gazette and in force from the day following publication. |
| Table | Fifteen violations graded by occurrence: written notice with 15 or 30 days to correct on the first, fines from AED 5,000 to AED 50,000 on the second and from AED 10,000 to AED 100,000 on the third, each with a direction to correct the violation. |
First violation: written notice to correct within 15 or 30 days. Second and third violations: fines of AED 20,000 and AED 40,000 for incorrect or incomplete real beneficiary data; AED 50,000 and AED 100,000 for failing to create either register or to disclose beneficiary classes in a complex structure; AED 40,000 and AED 80,000 for missing director or nominee data; AED 15,000 and AED 30,000 for late updates, late replies to data requests or missing records; AED 10,000 and AED 20,000 for no resident authorised person; AED 5,000 and AED 10,000 for late handover to a liquidator; AED 100,000 for a liquidator not keeping records five years. Third violation may also bring licence suspension and closure.
This table is why we treat UBO filings as a dated obligation rather than a form. The two fines our clients are most exposed to are the AED 15,000 to AED 30,000 for missing the 15-day update after a share transfer or change of director, and the AED 10,000 to AED 20,000 for having no resident authorised person once the original contact has left the country. We cover the second risk by acting as the resident point of contact for companies we administer, and the first by raising the register update in the same instruction as the transfer or appointment. Because the first violation only draws a written notice, a registrar letter is a warning to be acted on within the stated 15 or 30 days, not a fine to be budgeted; we respond for clients within that window and keep the correction evidence on file so the next occurrence cannot be counted as a repeat.
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