UBO Compliance & Filing
UBO Compliance and Filing Services
Ensure complete compliance with UAE Ultimate Beneficial Owner (UBO) regulations. RH and Hale Law Firm in Dubai provides complete UBO compliance and filing services for mainland, free zone and commercial entities in the UAE.
As UBO compliance lawyers and consultants based in Dubai, we help the businesses identify the beneficial owners, file timely declarations and maintain necessary compliance to avoid penalties and protect your license.
Schedule a free consultation
Schedule a consultation to discuss your legal matter with an experienced attorney. We’ll review your situation, explain your options, and help you understand the best path forward at no cost and no obligation.
What is UBO Compliance in UAE?
The UAE UBO compliance requires each UAE company to identify the person or persons who ultimately own or control the company / entity and file relevant information with a licensing authority. This information will enhance transparency and support the country’s anti-money laundering (AML) and anti-terrorist financing regime.
A UBO is a natural person who:
- Owns or controls 25% or more of the shares or voting rights (directly or indirectly), or
- Has the right to appoint or remove the majority of directors, or
- Exercises effective control by other means, or
- Holds a senior management position (if no other natural person qualifies).
Corporate entities cannot be listed as UBOs — ownership chains must be traced to natural persons.
UBO Requirements Applicable UAE Laws
UBO requirements are governed by:
- Cabinet Decision No. 58 of 2020 on the Regulation of Beneficial Owner Procedures (original framework);
- Cabinet Decision No. 109 of 2023 (the revised and strengthened regulations, effective from late 2023).
These decisions make it obligatory for companies to maintain certain registers and to file UBO information with the Registrar (the Department of Economy and Tourism /DET in Dubai mainland and respective economic departments in the other emirates, or the free zone authority in case of free zone companies).
Entities fully owned by the federal and local governments and those in financial free zones (DIFC and ADGM) generally fall under different regimes or exemptions.
Failure to comply with UBO requirements can result in fines up to AED 100,000, cancellation or suspension of the license, among other actions.
Who Must File UBO Information in the UAE?
Most legal entities licensed or registered in the UAE mainland and commercial free zones must comply. This includes:
- Mainland companies (Dubai DET and other emirates)
- Commercial free zone companies (DMCC, JAFZA, IFZA, RAKEZ, Meydan, SHAMS, Dubai South, and similar zones)
- Active, dormant, and newly incorporated entities
- Companies with multi-layered or cross-border ownership structures
Exemptions currently only apply to the financial free zones and a few entity types that are 100% owned by the UAE federal or local governments.
Our UBO lawyers and compliance consultants will review your structure and confirm the applicability.
Key UBO Registers and Obligations
Companies are required to prepare, maintain and file the following registers:
- Register of Beneficial Owners (UBO Register): full name, nationality, date and place of birth, residential address, passport/Emirates ID and other details, basis of ownership or control and dates of becoming/ceasing to be a UBO.
- Register of Partners / Shareholders: full name/address of legal owners and their shareholding.
- Register of Nominee Directors (where applicable): names of any directors who have been appointed on instructions to act on behalf of another person.
Exact copies of these registers must be kept in the company’s registered office (or with the registered agent) and must be updated within 15 days of any changes in ownership or control.
Initial filings for new entities are generally due within 60 days of incorporation, or as required by the licensing authority. Any other documents required by the Registrar must be submitted within 14 days.
UBO Compliance Filing Services across the UAE and UAE Mainland and Freezone
RH and Hale Law Firm provides complete and practical UBO compliance support as trusted UBO compliance lawyers and consultants in Dubai, that are meeting mainland and free zone UBO compliance requirements:
- UBO Identification and Ownership Structure Mapping: We carefully analyse the shareholding, voting rights, nominee arrangements and other control arrangements in order to accurately identify all the UBOs.
- Preparation of Compliant Registers: Drafting of the UBO Register, Shareholders/Partners Register and Nominee Director Register in compliance with the current laws.
- UBO Declaration and Regulatory Filings: Preparation and filing of declarations to the respective portals (DET e-services for mainland Dubai, free zone portals such as DMCC, IFZA, RAKEZ, etc).
- Document Compilation and Verification: Compilation and verification of the required supporting documents such as passports, Emirates ID, proof of address, ownership chart, MOA, trade licence etc.
- Ongoing Compliance Monitoring and Updates: Keeping track of updates and filing within the 15 days statutory period after recognizing the change in ownership.
- Gap analysis in the structure: Checking the current structure for any gaps, penalties and recommended remediation options.
- Advising on complex structures: Advising on multi-jurisdictional holdings, trust, foundations, and nominee structure while staying compliant.
- Support for the Authority: Any additional information requirement and inspections.
We are responsible for filing in UAE mainland, other Emirates and major commercial free zones with the correct portal and process for your business.
Why Choose RH and HALE Law Firm for UBO Services in Dubai?
- We are a full-service law firm based in Dubai providing UBO filing services in Dubai and the UAE.
- Our team of UBO lawyers and consultants combines legal expertise with practical knowledge of licensing authorities and free zone procedures.
- We focus on services that are clear, simple and effective ensuring you comply accurately with your UBO obligations without any unnecessary hassle.
- We work with businesses of all sizes, from start-ups and small businesses to multi-entity groups, and
- Provide reliable support for both one-time filings and ongoing maintenance as your ultimate beneficial owner lawyer and consultant in the UAE.
Why UBO Compliance Matters for Your Business?
- Meeting the legal requirements for UBO filing on time and accurately protects you from the risk of hefty financial penalties, licensing restrictions and loss of reputation.
- It also supports smoother banking relationships, investor due diligence, and alignment with broader UAE AML and Economic Substance Regulation (ESR) expectations.
- Maintaining transparent ownership records shows good corporate governance and readiness for regulatory scrutiny.
Contact RP and Hale for expert UBO compliance support
Ensure your UAE Company stays compliant and penalty-free. RH and HALE Law Firm in Dubai provides professional UBO identification, register preparation, filing and ongoing support from UBO lawyers and consultants.
FAQs – UBO Compliance and Filing Services
What is the penalty for non-compliance with UBO rules in the UAE?
In the UAE, failure to register or providing incorrect/incomplete information may result in administrative penalties up to AED 100,000. In addition, penalties will apply for the failure to update the register before the deadline. License may also be suspended or cancelled.
How often does the UBO register need to be updated?
Any change in ownership or control, the register must be updated within 15 days. Most companies are required to confirm the UBO annually as part of the trade licence renewal process.
Do free zone companies need to file UBO declarations?
Yes. Commercial free zone entities are normally required to file with their free zone authority. Each free zone has its own UBO filing portal and requirements.
What documents are usually required?
Some of the documents required include the trade licence, copies of the passports and Emirates IDs of all identified UBOs, proof of residential address, a chart of the ownership structure and completed declaration forms.
Can RH and Hale assist with both mainland and free zone filings?
Yes. We are UBO compliance lawyers and consultants in Dubai. We handle the entire filing process for Dubai DET mainland and major commercial free zone entities across the UAE.