Ultimate Beneficial Owner Declaration (UAE)

An Ultimate Beneficial Owner Declaration (UAE) is a formal document in which a UAE company identifies and discloses the natural persons who are its Ultimate Beneficial Owners — those who ultimately own or control the company — in compliance with Cabinet Decision No. 58 of 2020 Concerning the Regulation of the Procedures of the Real Beneficiary and the Anti-Money Laundering and Combating the Financing of Terrorism Law, Federal Decree-Law No. 20 of 2018.

Cabinet Decision No. 58 of 2020, issued pursuant to the AML law, implements the Financial Action Task Force (FATF) Recommendation 24 on transparency of beneficial ownership of legal persons. The UAE adopted this framework as part of its national anti-money laundering action plan and its commitment to exit the FATF grey list, which it achieved in 2024 following significant legislative and enforcement reforms. The UBO framework is now embedded in the UAE's regulatory infrastructure and is actively enforced by the Ministry of Economy, the Department of Economic Development, free zone authorities, and the Central Bank of the UAE.

An Ultimate Beneficial Owner is defined as any natural person who: directly or indirectly owns 25% or more of the shares of the company; directly or indirectly controls 25% or more of the voting rights; has the right to appoint or remove the majority of the board of directors or management body; or otherwise exercises effective control over the management or decisions of the company. The definition is designed to look through corporate structures and nominee arrangements to identify the natural person who ultimately benefits from and controls the company.

UAE companies — including limited liability companies registered with the Department of Economic Development, free zone entities, and certain offshore companies — are required to identify their UBOs, collect and verify the required information, register UBOs with the relevant licensing authority, maintain an accurate internal UBO register, and update the register within 15 days of any change in beneficial ownership. UAE banks, financial institutions regulated by the Central Bank of the UAE, and commercial counterparties conducting Know Your Customer due diligence all require UBO information as a condition of establishing or continuing a business relationship.

The forms-legal.com Ultimate Beneficial Owner Declaration (UAE) template provides a structured document capturing all required UBO information for use with licensing authorities, UAE banks, and commercial counterparties, available in PDF and Word formats.

A UAE Ultimate Beneficial Owner Declaration is needed in multiple situations.

Company registration and trade licence issuance: When a new UAE company is registered with the Department of Economic Development or a free zone authority, UBO information must typically be provided as part of the incorporation documentation. Some licensing authorities require a separate UBO declaration form; others capture UBO information through online portals. The UBO declaration supports the registration of the company in the UBO register maintained by the licensing authority.

Trade licence renewal: The annual renewal of a UAE trade licence may require the company to confirm or update its UBO information. Where there has been a change in ownership, an updated UBO declaration must be filed with the renewal application.

Banking: Every UAE bank — Emirates NBD, First Abu Dhabi Bank, Abu Dhabi Commercial Bank, Mashreq, Dubai Islamic Bank, and others — is required by the Central Bank of the UAE's AML-CFT regulatory framework to identify and verify the UBOs of their corporate clients as part of Customer Due Diligence. A UBO declaration is a standard document required for opening a corporate bank account, and banks conduct periodic reviews of UBO information as part of ongoing due diligence. Companies that cannot provide accurate UBO information may be unable to open or maintain a bank account.

Commercial due diligence: International and large UAE counterparties, including multinational companies, government-owned entities, and regulated entities, conduct UBO checks on their commercial partners as part of their own AML compliance obligations. A UBO declaration provides the required information in a structured form.

Change of ownership: Whenever the beneficial ownership of a UAE company changes — by share transfer, inheritance, or structural reorganisation — an updated UBO declaration must be prepared and filed with the relevant authority within 15 days under Cabinet Decision No. 58 of 2020.

Regulatory inspections: The Ministry of Economy and licensing authorities conduct AML compliance inspections and may request UBO registers and supporting declarations.

A UAE Ultimate Beneficial Owner Declaration must contain the following key elements to satisfy the requirements of Cabinet Decision No. 58 of 2020 and the Anti-Money Laundering Law, Federal Decree-Law No. 20 of 2018.

Company identification: The company's full registered name, company type, trade licence number, emirate of registration, and registered office address. These details identify the legal entity to which the declaration applies and allow the recipient to match it to the licensing authority's records.

Date of declaration: The specific date on which the declaration is made. The declaration must be current and accurate as at that date.

UBO identity information for each UBO: For each natural person who qualifies as an Ultimate Beneficial Owner, the declaration must include: full legal name as it appears in their identity document; nationality; date of birth; Emirates ID number (for UAE nationals and residents) or passport number (for foreign nationals); residential address; the percentage of ownership or control; and the basis on which the person qualifies as a UBO — direct shareholding, indirect shareholding, voting rights, or effective control.

Nominee disclosure: A statement of whether any shares in the company are held by a nominee on behalf of the beneficial owner, with identification of the nominee and the underlying beneficial owner. Nominee arrangements must be disclosed, and the nominee's identity and the beneficial owner's identity must both be recorded.

Declaration of accuracy: A formal declaration by the company's general manager or a director that the information provided is true, accurate, and complete, together with a commitment to update the declaration within 15 days of any change.

Signature: The signature of the declarant — the general manager or director — with their name and title. Banks and licensing authorities verify the identity of the signatory.

The forms-legal.com UBO Declaration (UAE) template captures all these elements in a format accepted by UAE licensing authorities and financial institutions.

Completing an Ultimate Beneficial Owner Declaration for a UAE company begins with the company identification section. Enter the company's full registered name exactly as it appears on the trade licence, the company type, the trade licence number, the emirate of registration, the registered office address, and the date of the declaration. Ensure the company details match the trade licence to avoid discrepancies.

For UBO 1, enter the full legal name of the first natural person who qualifies as an Ultimate Beneficial Owner — as it appears in their identity document — together with their nationality, date of birth, Emirates ID number or passport number, residential address, the percentage of shares or voting rights they own or control, and the basis of control. If the UBO holds shares directly, select 'direct shareholding'. If they hold shares indirectly through a holding company or chain of companies, select 'indirect shareholding through holding company' and be prepared to provide documentation of the ownership chain to the licensing authority or bank.

For UBO 2, complete the same information if there is a second natural person who holds 25% or more. For wholly owned companies with a single shareholder who is a natural person, only UBO 1 needs to be completed.

In the nominee section, answer whether any shares are held by a nominee. If yes, enter the nominee's name and the nature of the nominee arrangement. If no nominee exists, state 'No nominee shareholders'.

In the declaration section, enter the full name and title of the person signing — the general manager or a director. The declarant is personally certifying the accuracy of the information, so must verify the details before signing. After completing the form, the declarant signs and the declaration is submitted to the relevant licensing authority's UBO register portal, and a copy is retained by the company in its corporate records. Provide copies to UAE banks and other counterparties as required.

Legal requirements for a UAE UBO Declaration arise from Cabinet Decision No. 58 of 2020 and the Anti-Money Laundering Law, Federal Decree-Law No. 20 of 2018.

Cabinet Decision No. 58 of 2020 establishes the UBO registration framework. Article 3 requires companies to identify their Ultimate Beneficial Owners — natural persons who own or control 25% or more of shares or voting rights, or exercise effective control — and to register them with the relevant licensing authority. Article 5 requires companies to update the UBO register within 15 days of any change in beneficial ownership. Article 7 requires companies to provide accurate UBO information to the licensing authority on request. Article 8 empowers licensing authorities to impose administrative sanctions for non-compliance, including fines.

The Anti-Money Laundering Law, Federal Decree-Law No. 20 of 2018, as amended by Federal Decree-Law No. 26 of 2021, is the overarching AML framework. The UBO requirements implement the law's transparency objectives by preventing the misuse of legal persons for money laundering, terrorism financing, and other financial crimes. The Financial Intelligence Unit, which operates under the Central Bank of the UAE, uses UBO information in its analysis of Suspicious Transaction Reports filed by financial institutions and Designated Non-Financial Businesses and Professions.

The UAE Banking Law and the Central Bank of the UAE's regulations require all banks and financial institutions to identify and verify the UBOs of their corporate clients as part of Customer Due Diligence. Failure to provide accurate UBO information to a UAE bank may result in refusal or termination of the banking relationship and a Suspicious Transaction Report to the Financial Intelligence Unit.

Companies in the Dubai International Financial Centre operate under DIFC law — the DIFC Companies Law and DFSA regulations — which have separate but equivalent UBO and beneficial ownership requirements. Companies in the Abu Dhabi Global Market face ADGM Financial Services Regulatory Authority requirements in the same vein.

Common mistakes in a UAE Ultimate Beneficial Owner Declaration begin with failing to look through the corporate structure to identify the natural person. A common error is declaring a holding company or another legal entity — rather than the natural person who ultimately owns or controls it — as the UBO. Cabinet Decision No. 58 of 2020 requires disclosure of natural persons only; any holding structure must be traced to its ultimate human owner.

Using a threshold other than 25% is a mistake. Some companies incorrectly apply a 50% threshold, believing only majority shareholders are UBOs. The UAE threshold is 25%, consistent with FATF Recommendation 24. A natural person holding 30% is a UBO; a natural person holding 24% is not, though effective control by other means may still qualify them.

Failing to disclose nominee arrangements is a serious compliance gap. Where a share is held in the name of a nominee on behalf of a beneficial owner, both the nominee and the true beneficial owner must be disclosed. Omitting the nominee arrangement — whether intentional or through misunderstanding — is a breach of Cabinet Decision No. 58 of 2020 and may constitute a money laundering red flag.

Not updating the declaration after a change of ownership is a frequent and costly error. Companies that transfer shares without updating the UBO register within the required 15-day period are in breach of Cabinet Decision No. 58 of 2020 and may face fines. Share transfers, new investment rounds, inheritance of shares, and corporate restructurings are all triggering events.

Providing incorrect identity information — wrong passport number, wrong date of birth, or a name that differs from the identity document — causes the declaration to be rejected by UAE banks and licensing authorities. All identity details must be taken directly from the relevant identity document and checked carefully before the declaration is signed.