Beneficial ownership: UAE legislation

Cabinet Resolution No. 109 of 2023 Regulating the Real Beneficiary Procedures

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 their real beneficiaries (25% ownership or control test, with fallbacks to control and senior management), keep registers of beneficial owners, shareholders and nominee directors, file them with the registrar and update changes within fifteen days.

Cabinet Resolution No. 132 of 2023 Concerning the Administrative Penalties Imposed on Violators of the Provisions of Cabinet Resolution No. 109 of 2023 Concerning the Regulation of Real Beneficiary Procedures

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 Decision No. 58 of 2020 Regulating the Beneficial Owner Procedures

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 Repealed Cabinet Decision No. 34 of 2020 and was itself repealed by Cabinet Decision No. 109 of 2023.

ADGM Beneficial Ownership and Control Regulations 2022 (consolidated April 2026)

Enacted 14 December 2022 to replace the 2018 regulations, they define a beneficial owner as a natural person owning or controlling 25% or more of an ADGM entity or otherwise controlling it, require every ADGM entity (other than foreign branches) to keep a beneficial-ownership record and file it with the Registrar's central register; amended six times to April 2026.

DIFC Ultimate Beneficial Ownership Regulations 2018 (Consolidated Version No. 2, in force 8 March 2024)

Made under Article 46 of the Operating Law, the Regulations require DIFC companies, partnerships, non-profits and foundations to identify, record and file their ultimate beneficial owners at a 25% ownership or control threshold, oblige nominee directors to disclose their status and set deadlines for updating the register and notifying the Registrar.

Ras Al Khaimah Economic Zone Authority Beneficial Ownership 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 register, notify the Registrar of changes, and setting the Registrar's powers and penalties for non-compliance and false information.