Ultimate Beneficial Owner (UBO)
Filing & Compliance

Stay compliant with the UAE's beneficial-ownership rules. Under Cabinet Decision 109/2023 (which replaced 58/2020), most UAE companies must identify their real owners, maintain the required registers and file UBO data with their licensing authority. Avyanco handles it end-to-end.

  • Cabinet Decision 109/2023
  • UBO & Shareholder Registers
  • Filing & Updates
  • Penalty Avoidance
  • All Mainland & Free Zones

Who Really Owns the Company — On the Record

UAE beneficial-ownership rules, currently set out in Cabinet Decision No. 109 of 2023 (which replaced No. 58 of 2020), require most companies to identify their Ultimate Beneficial Owners, the natural persons who ultimately own or control the business, commonly through a 25% or greater shareholding or voting right. Companies must maintain registers and file UBO data with their licensing authority or registrar.

UAE beneficial-ownership rules, currently set out in Cabinet Decision No. 109 of 2023 (which replaced No. 58 of 2020), require most companies in the country to identify their Ultimate Beneficial Owners — the natural persons who ultimately own or control the business — and to keep this on the record. In practice that means creating and maintaining a Register of Beneficial Owners and a Register of Partners or Shareholders, and filing the UBO information with the relevant licensing authority or registrar.

A Beneficial Owner is generally the natural person who ultimately owns or controls the entity, commonly through a 25% or greater shareholding or voting right, or through control by other means. The rules apply to most mainland and free-zone companies, while entities in the financial free zones (ADGM and DIFC) and certain government-owned bodies follow their own regimes. Getting this right matters: non-compliance carries administrative penalties, and UBO data must be kept current as ownership changes. Avyanco identifies your beneficial owners, prepares the registers, makes the filing and keeps it updated.

UBO filing and beneficial-ownership compliance in the UAE — Avyanco

What UBO Compliance Covers

Three connected obligations under the beneficial-ownership rules.

Register of Beneficial Owners

Identifying the natural persons who ultimately own or control the company and recording the required details in the UBO register.

  • Beneficial-owner identification
  • Ownership / control analysis
  • Register creation & upkeep
  • Supporting evidence & KYC
  • Determination where ownership is layered

Register of Partners / Shareholders

Maintaining the register of the company's direct partners or shareholders and their holdings, alongside the UBO register.

  • Shareholder / partner register
  • Holding & class details
  • Nominee disclosures where relevant
  • Cross-checks against the MoA
  • Document retention

Filing & Ongoing Updates

Filing the UBO data with the licensing authority and updating it within the required window whenever ownership or control changes.

  • Initial filing with the authority
  • Change notifications & re-filing
  • Annual confirmation where required
  • Penalty-risk review
  • Coordination across multiple entities

How Avyanco Handles UBO Filing

Six steps from analysis to a compliant, maintained register.

  1. 01

    Ownership Mapping

    We map the ownership and control chain — including holding companies and layered structures — to find the real beneficial owners.

  2. 02

    Determine Beneficial Owners

    We apply the 25% ownership/control test and the control-by-other-means rules to determine who must be recorded.

  3. 03

    Build the Registers

    We prepare the Register of Beneficial Owners and the Register of Partners/Shareholders with the required details and evidence.

  4. 04

    File with the Authority

    We submit the UBO data to the relevant licensing authority or registrar in the prescribed format.

  5. 05

    Maintain & Update

    When ownership or control changes, we update the registers and re-file within the required window.

  6. 06

    Compliance Calendar

    We keep UBO alongside your other filings (ESR, Corporate Tax, licence renewal) on one compliance calendar.

Why Get UBO Right

Beneficial-ownership compliance is low-effort to maintain and costly to ignore.

Avoids administrative penalties for non-filing or inaccurate data

Keeps the company in good standing for licence renewal

Supports smoother bank account opening and KYC

Gives a clean, defensible ownership record

Reduces friction in audits, financing and transactions

Keeps UBO aligned with the MoA and shareholder records

One coordinated view across multiple group entities

Current data ready whenever an authority requests it

The Avyanco Advantage

Avyanco treats UBO as part of an integrated compliance service, not a one-off form.

Ownership-Chain Expertise

We unpick layered and cross-border ownership to identify beneficial owners correctly the first time.

Filing Done Properly

We prepare and file the registers in the right format with the right authority, mainland or free zone.

Kept Up to Date

We track ownership changes and re-file within the window, so the record never goes stale.

Joined-Up Compliance

UBO sits alongside ESR, Corporate Tax and licence renewal on one calendar, handled by one team.

Banking-Ready Records

Clean UBO and shareholder registers that stand up to bank KYC and onboarding.

Group Coverage

Consistent UBO handling across all your UAE entities, with a single point of contact.

Meet Our Specialists

Partner-level advisors covering beneficial-ownership analysis, filing and ongoing compliance.

Vikas Dhingra, CFO at Avyanco

Vikas Dhingra

Chief Financial Officer · Tax & Structuring

Anshul Agarwala, Senior Consultant at Avyanco

Anshul Agarwala

Senior Consultant · Accounts, Tax & Audit

Jaikishan Kishnani, Tax Consultant at Avyanco

Jaikishan Kishnani

Tax Consultant · Corporate Tax & VAT

Shoaib Shaikh, Tax Consultant at Avyanco

Shoaib Shaikh

Tax Consultant · Corporate Tax & VAT

Abel, Accounts & Tax Associate at Avyanco

Abel

Accounts & Tax Associate

Subura, Accounts & Tax Associate at Avyanco

Subura

Accounts & Tax Associate

Why Companies Choose Avyanco for UBO

Three things that come up in every UBO engagement.

Avyanco advisor handling UBO compliance

Get the Owners Right

We correctly identify beneficial owners even through holding companies and layered structures.

Penalty Protection

Accurate registers filed on time keep you clear of the administrative penalties for non-compliance.

Always Current

We update and re-file as ownership changes, so the record stays compliant year-round.

What Clients Say

A slice of recent feedback from founders who run their UAE compliance through Avyanco.

UBO Filing — Frequently Asked Questions

Common questions about UAE beneficial-ownership compliance.

What is a UBO and what does the UAE require?
An Ultimate Beneficial Owner (UBO) is the natural person who ultimately owns or controls a company — commonly through a 25% or greater shareholding or voting right, or through control by other means. Under Cabinet Decision 109/2023 (which replaced 58/2020), most UAE companies must identify their UBOs, maintain a Register of Beneficial Owners and a Register of Partners/Shareholders, and file the UBO data with their licensing authority.
Which companies have to comply?
Most mainland and free-zone companies in the UAE must comply. Entities in the financial free zones (ADGM and DIFC) and certain government-owned bodies follow their own regimes. We confirm the exact obligation for your entity and licensing authority.
What happens if I don't file or my data is wrong?
The rules carry administrative penalties for failing to maintain or file accurate UBO data, and non-compliance can affect licence renewal and banking. Because the penalty schedule and procedures can change, we work to the current requirements of your authority.
Do I need to update the UBO register?
Yes. UBO data must be kept current — when ownership or control changes, the registers must be updated and the change re-filed within the required window. Avyanco tracks this so the record never goes stale.
How does UBO relate to my other compliance?
UBO sits alongside ESR, Corporate Tax filing, VAT and licence renewal. We keep all of them on one compliance calendar so nothing is missed and the records stay consistent with your MoA.
Can Avyanco handle UBO for a group of companies?
Yes. We handle beneficial-ownership analysis and filing consistently across all your UAE entities, including holding structures, with a single point of contact.
Verification & independence

This page describes UAE beneficial-ownership compliance in general terms, anchored to Cabinet Decision No. 109 of 2023 (which replaced No. 58 of 2020) as understood in June 2026. Avyanco Business Consultancy LLC is independent of all UAE government authorities and provides advisory and administrative services; it is not a government body.

Beneficial-ownership rules, thresholds, exemptions, filing procedures and penalties evolve and differ by licensing authority. Always confirm the current requirements for your specific entity directly with your licensing authority before acting on any fact on this page.

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Need to File or Update Your UBO?

Speak to an Avyanco advisor about your beneficial-ownership compliance — identification, registers, filing and ongoing updates across all your UAE entities.

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