UBO Filing Requirements in UAE | Did You Know?

The UBO filing requirements in UAE remain a vital aspect for one to comply with business regulations. Whether your company is on the mainland, free zone side, or offshore, an accurate and timely UBO submission would certainly help you avoid any fines and augment transparency at the regulatory level.

The guide explains what UBO is, who needs to file, how it is done, deadlines and penalties, along with how Arnifi can handle the whole compliance procedure for you.

1. Introduction

Running a corporation or an establishment in the UAE shall mean you would have seen all the mentions of Ultimate Beneficial Owner or UBO. In layman’s terms, the real person benefiting from or controlling your company may even be absent from the share register. To increase transparency in line with anti-money laundering (AML) laws, the UAE requires all eligible businesses to provide this information under strict filing requirements imposed upon the UBO. 

This isn’t just another formality. Filing your UBO details is a legal necessity, covering most businesses operating in the UAE. It’s also part of a wider compliance system that keeps your operations in good standing. To understand how UBO fits within the bigger picture of corporate obligations, check out our guide on Corporate Compliance in the UAE.

2. What is UBO Filing?

The Ultimate Beneficial Owner is the person with ultimate ownership or control of a company, normally 25% or more of the shares or voting rights, or who is able to give directions of a major nature to the company. Even if through a holding structure, the person who is at the end of the holding line is considered the UBO.

UBO filing means officially submitting this information to the relevant UAE authority so that regulators know who truly controls the business. The purpose is threefold:

• Transparency: Making corporate structures clear to the government
• AML compliance: Helping prevent illegal activities such as money laundering
• Oversight: Allowing regulators to track and monitor corporate control

The process is governed by Cabinet Resolution No. (58) of 2020. Mainland companies typically file through the Department of Economic Development (DED), while free zone companies submit to their respective free zone authority.

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3. Who Needs to File UBO in the UAE?

The UBO filing requirements in UAE apply to:

• Mainland businesses registered with the DED
• Free zone companies under authorities like DMCC, IFZA, RAKEZ, or ADGM
• Offshore entities such as RAK ICC or JAFZA offshore companies

Exemptions include:

• Entities fully owned by the UAE federal or local government
• Subsidiaries of such government-owned companies

UBO compliance doesn’t stand alone it’s often managed alongside other obligations like VAT returns, ESR reports, and license renewals. For a broader look at ongoing business obligations, see our Post Compliance Services in Dubai guide.

4. UBO Filing Requirements in UAE – Details

When you file, you’ll need to provide precise and complete details, which usually include:

Required Information	Details
UBO personal details	Full name, nationality, and date of birth
Ownership information	Share percentage and type of ownership
Proof of identity	Passport copy, Emirates ID if applicable
Control details	How the UBO exerts control over the business

How to Submit

• Mainland companies: File online through the DED portal
• Free zone companies: Use your free zone’s dedicated platform

Ongoing Obligations:

• Confirm UBO details yearly
• Report any changes within 15 days of them occurring

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5. Step-by-Step UBO Filing Process in Dubai

Step 1 – Identify Your UBO(s)
Whoever meets the criteria of UBO, i.e., any person behind 25%+ ownership or a person exerting considerable influence.

Step 2 – Collect Documentation:
Prepare all the required documents since these usually consist of passports, Emirates IDs, shareholder registers and organizational charts.

Step 3 – Fill Out the UBO Declaration Form:
This form is available through the relevant authority and must be completed with accurate details.

Step 4 – Submit to the Authority
Send the completed declaration through the DED e-services portal or your free zone’s filing system.

Step 5 – Continue Compliance:
Ensure that UBO information remains updated at all times. Remember, any changes must be submitted within the legal timeframe.

6. Penalties for Non-Compliance

Ignoring UBO filing requirements in UAE can be costly.

Offense	Penalty
Late submission	AED 50,000
Providing false details	AED 50,000
Repeat violations	Additional AED 100,000
Continued non-compliance	Possible license suspension

Failing to file on time can also affect your standing with other obligations like VAT. For more on tax compliance, read our VAT Filing in Dubai article.

7. UBO Filing Deadlines & Renewal

• For new companies: File within 60 days after incorporation
• Annually Renewals: Confirm UBO details before the renewal date
• When ownership changes: within 15 days of such change

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8. How Arnifi Can Help with UBO Filing in Dubai

At Arnifi, we handle the full UBO filing process in Dubai from start to finish. We:

• Prepare and file accurate declarations
• Track renewal dates and changes
• Combine UBO filing with other compliance matters such as VAT, ESR, and license booking renewals

An all-in-one approach helps you save time, keeps stress levels free, and your business stay out of any penalty.

9. FAQs on UBO Filing in the UAE

Q1: What is the UBO filing deadline?
60 days from incorporation, annual confirmation is required.

Q2: Is UBO filing mandatory for free zone companies?
Yes, unless your business qualifies for an exemption.

Q3: Can one person be the UBO for multiple companies?
Yes, if they meet the ownership or control criteria for each.

Q4: How do I update my UBO information?
Submit changes within 15 days from the desired date via your authority’s portal.

10. Conclusion

Fulfilling UBO filing requirements in UAE is highly crucial for ensuring legal compliance and to avoid penalties that can be extremely expensive. It may seem like an easy task, but accuracy, timeliness, and the knowledge of having very heavy fines attached to errors or delays in the process must be borne in mind. 

When handled properly by Arnifi, your UBO filing, VAT requirements, and applications for other compliance matters will be taken care of, allowing you to concentrate on growing your business.