In Brief

1. Under Cabinet Decision No. 109 of 2023, every UAE mainland and commercial free zone entity must maintain a register of its Ultimate Beneficial Owners (UBOs) and file that information with its licensing authority. A UBO is any natural person who owns or controls 25% or more of the company’s shares or voting rights.

2. The UAE operates a “regulator-first” model: UBO data is disclosed to government authorities and competent bodies, but it is not publicly searchable. The RAK ICC register of shareholders and directors is not a public document.

3. The penalty framework under Cabinet Resolution No. 132 of 2023 provides for escalating sanctions, from written warnings on first offence to fines of up to AED 100,000 and potential licence suspension for repeated violations.

When the UAE introduced mandatory Ultimate Beneficial Ownership (UBO) disclosure requirements, many business owners assumed the worst: that their personal details, ownership percentages, and asset holdings would become publicly searchable, much as they are in the UK through Companies House. That assumption is incorrect. The UAE’s approach to beneficial ownership transparency follows a different model. It provides full disclosure to government regulators and competent authorities while maintaining strict confidentiality from the public. Understanding the distinction between what is visible to regulators and what is visible to the general public is essential for any business owner structuring their affairs in the UAE.

UBO (cid:127) Beneficial Ownership (cid:127) Privacy (cid:127) AML/CFT Compliance

The legal framework: Cabinet Decision No. 109 of 2023

The primary instrument governing UBO disclosure in the UAE is Cabinet Decision No. 109 of 2023 on Regulating the Real Beneficiary Procedures. This decision replaced the earlier Cabinet Resolution No. 58 of 2020 and established a unified reporting standard for all UAE-registered entities on the mainland and in commercial free zones.

Who qualifies as a UBO Under the decision, a Real Beneficial Owner is any natural person who ultimately owns or controls a legal entity, either directly or indirectly, through ownership or control of at least 25% of the company’s shares or voting rights, or through the right to appoint or dismiss the majority of the board of directors. If no individual meets these criteria, the senior management official responsible for day-to-day operations is recorded as the UBO.

What must be maintained The law requires every company to maintain three specific registers: a Register of Real Beneficial Owners, a Register of Partners or Shareholders, and a Register of Nominee Directors (where applicable). These registers must include each UBO’s full name, nationality, date of birth, residential address, passport or ID details, ownership percentage, and the date they became (or ceased to be) a UBO. New companies must file this information within 15 days of incorporation. Existing companies must update any changes within 15 days of the change occurring.

What the public can see versus what regulators can access

The distinction between public registers and regulator-held data is where the UAE’s approach differs most significantly from jurisdictions such as the UK.

	UK (Companies House)	UAE / RAK ICC
Public visibility	Full name, month/year of birth, and service address of Persons with Significant Control are publicly searchable, free of charge, and indexed by search engines.	Only the company’s existence and its Registered Agent are publicly visible. UBO details are not publicly searchable.
Regulator access	Same data plus additional details held by HMRC.	Full UBO data (passport, address, ownership %) is filed with the licensing authority and the Ministry of Economy’s Unified Economic Register. Accessible to competent authorities under specific legal conditions.
Search engine indexing	Yes. PSC data appears in Google search results.	No. UBO filings are held in secure government systems and aren’t indexed.

For individuals with a high public profile or significant asset holdings, this distinction is material. A standard search of the RAK ICC registry will confirm that a company exists and identify its registered agent, but it won’t reveal the identity of the beneficial owner, their residential address, or their ownership percentage. That information is disclosed only to the regulatory authorities.

Which authorities can access UBO data, and under what conditions

Under Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism, and Countering Proliferation Financing (which came into effect on 14 October 2025 and replaced the 2018 AML framework), the UAE has established a data-sharing network between regulators and competent authorities. UBO data can be requested by authorised governmental bodies for specific, lawful purposes. These include the Central Bank of the UAE (CBUAE) for banking supervision and AML checks; the Federal Tax Authority (FTA) for corporate tax and VAT compliance verification; law enforcement agencies in the context of formal criminal investigations or Mutual Legal Assistance Treaty (MLAT) requests from foreign governments; and the Ministry of Economy to ensure the UAE’s compliance with international transparency obligations. This is the framework’s deliberate trade-off. Full transparency to the state ensures the UAE meets its FATF commitments and maintains its position on the white list. Strict confidentiality from the public protects business owners from the risks that come with unrestricted access to personal financial information.

The penalty framework for non-compliance

The penalty regime for UBO violations is set out in Cabinet Resolution No. 132 of 2023, which replaced the earlier Cabinet Decision No. 53 of 2021 and introduced an escalating sanctions framework.

Fact-check correction: the applicable penalty resolution The original version of this article cited “Cabinet Resolution No. 129 of 2025” as the source of UBO penalties. The correct instrument is Cabinet Resolution No. 132 of 2023, which established the current administrative penalty structure for UBO violations. This resolution was issued on 15 December 2023 and provides penalties ranging from written warnings to fines of up to AED 100,000.

Violation	First offence	Repeated offence
Failure to maintain UBO register	Written warning	Fines up to AED 50,000; potential licence suspension
Providing false or inaccurate UBO data	Fines from AED 20,000	Fines up to AED 100,000
Failure to update within 15 days of a change	Written warning	Fines up to AED 15,000
Failure to appoint a UAE-resident contact person	Written warning	Fines from AED 20,000

Under the current framework, repeated violations can also result in restrictions on the directors’ ability to hold similar positions in other UAE entities. The penalties are designed to be proportionate but firm: a first-time administrative oversight may result in a warning, but persistent non-compliance carries genuine financial and operational consequences.

Why controlled transparency is a commercial advantage

In the current global regulatory environment, the absence of any identifiable beneficial owner is itself a risk factor. Banks conducting KYC (Know Your Customer) due diligence will flag entities with incomplete or missing UBO filings. In practice, this can mean delayed account openings, restricted transaction processing, or account closures. A properly filed UBO register, held with the licensing authority and matched to the company’s corporate records, creates what might be called “institutional trust.” The bank sees that the entity’s ownership is documented, filed, and consistent with the regulatory record. Transactions process faster. Account relationships remain stable. The commercial logic is clear: full compliance with UBO requirements is the precondition for the privacy that the UAE’s regulator-first model provides. By being transparent to the state, business owners earn the right to remain private from the public. Attempting to avoid disclosure doesn’t preserve privacy; it creates the kind of regulatory gap that attracts scrutiny rather than deflecting it.

How RAK ICC handles UBO data in practice

RAK ICC, as one of the UAE’s international corporate registries, maintains UBO records for all entities registered under its framework. The data is filed with RAK ICC and, where required, with the Ministry of Economy’s Unified Economic Register. The RAK ICC Register of Shareholders and Register of Directors are not publicly accessible documents. A search of the RAK ICC registry will confirm that a company is registered and in good standing, and will identify the company’s registered agent, but it won’t disclose the identity of the shareholders, directors, or beneficial owners. That information is held securely within the registry and shared only with competent authorities on request. For founders who are concerned about public visibility of their corporate interests, particularly those transitioning from jurisdictions with public registers, the RAK ICC model offers a practical solution. Full regulatory compliance is maintained; public exposure is not.

Maintaining compliance as the framework evolves

The UAE’s UBO regime continues to develop. The introduction of Federal Decree-Law No. 10 of 2025 brought enhanced enforcement powers and broader data-sharing mechanisms. The executive regulations under Cabinet Resolution No. 134 of 2025 have further operationalised these requirements. Business owners should expect the compliance framework to become more detailed, not less, as the UAE continues to align with evolving international standards. The Alldren compliance team manages UBO filings for RAK ICC entities, ensuring data is accurate, filed within the required timeframes, and consistent with the company’s corporate records. For a review of your current UBO compliance position, contact our team.

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This article is for general informational purposes only and does not constitute legal, tax, or financial advice. Readers should seek professional advice tailored to their specific circumstances. Entities in financial free zones (DIFC, ADGM) are subject to separate UBO regulations administered by their own regulators. Information is current as of March 2026 and may be subject to change.