New UAE Cabinet Decision on Ultimate Beneficial Owner Procedures (UBO) 2025

New UAE Cabinet Decision on Ultimate Beneficial Owner Procedures (UBO) 2025

New UAE Cabinet Decision on Ultimate Beneficial Owner Procedures (UBO) 2025

Understanding the New UBO Regulations

The UAE government always tries to make business more transparent and reliable. In 2025, UAE introduced Cabinet Resolution No. (58) on Ultimate Beneficial Owner (UBO) Procedures. This law started on August 28, 2025, and replaced the earlier Cabinet Resolution No. 34 of 2025. Dubai wants to keep its place as a top world trade hub, so new rules help fight financial fraud and support a transparent business environment.

In recent years, investigators have found more suspicious financial transactions. Companies sometimes hide real ownership. Now, with this new resolution, every company must provide full and current information about their real owners. These new steps help authorities verify each business’s legitimacy and accuracy.

Objectives of the UBO Resolution

The UAE wants to achieve several goals through the UBO Cabinet Resolution:

  • Increase transparency for all UAE-registered entities
  • Develop better systems for tracking UBO data
  • Introduce strong regulatory mechanisms for compliance

Main Requirements for Companies

All companies licensed in the UAE must submit and update three main registers within sixty (60) days of the law’s start date or from their own establishment date:

  • Ultimate Beneficial Owner (UBO) Register
  • Nominee Director Register
  • Partners or Shareholders Register

These registers must be kept current, and any changes need to be reported within fifteen (15) days.

Who Must Follow the UBO Law?

The law applies to most companies in the UAE, such as:

  • Mainland Companies
  • Free Zone Companies

Who Is Not Covered by the UBO Law?

The UBO regulations do not apply to:

  • Entities in Financial Free Zones (like Dubai International Financial Centre, DIFC)
  • Entities fully owned by the Federal or Emirate Government

Who Qualifies as a UBO?

A UBO is a real person who owns or controls at least 25% of the company’s shares or has similar voting rights. The person can have this ownership directly or indirectly. If no one fits this rule, then any person who controls the company by other means, or who is part of senior management, will be listed as the UBO.

The UBO Register must include:

  • Full name, residence, and nationality
  • Identification or passport number
  • Date of appointment as a UBO
  • Date and reason for ceasing to be a UBO
  • The reason for being named as a UBO

What Is a Nominee Director Register?

Companies must record details about all directors and managers. This information is added to the Nominee Director Register, following company records and instructions.

What Goes in the Partners or Shareholders Register?

The register must state:

  • Each partner or shareholder’s ownership share
  • The date of acquiring those shares
  • Percentage of interest
  • Voting rights

Points Every Entity Must Remember

Businesses must keep all records up to date. If there are any changes to UBO, director, or shareholder details, companies must inform the relevant authority within fifteen (15) days.

All companies subject to the UBO rules must:

  • Prepare and update registers for UBOs, partners/shareholders, and nominee directors
  • Submit registers to the correct government authority on time
  • Notify the authority about changes immediately

Benefits of the UBO Regulation

  • Encourages openness in business ownership
  • Protects against illegal or fraudulent activity
  • Helps UAE maintain global trust as a trade center
  • Simplifies due diligence for banks and partners
  • Strengthens compliance with international standards

How Mubarak Al Ketbi (MAK) Auditing Can Help With UBO Compliance 🥇

Mubarak Al Ketbi (MAK) Auditing helps clients meet all UBO legal requirements. Our expert team supports you by:

  • Preparing UBO, director, and shareholder registers
  • Verifying and updating documents for accuracy
  • Submitting all registers to the correct government authorities
  • Managing your registers and UBO data on an ongoing basis
  • Notifying authorities quickly about any changes
  • Giving on-call support for any UBO or compliance questions

For more information:

  • Visit our office: Saraya Avenue Building – Office M-06, Block/A, Al Garhoud – Dubai – United Arab Emirates
  • Contact/WhatsApp: +971 50 276 2132

FAQs New UAE Cabinet Decision on Ultimate Beneficial Owner Procedures (UBO) 2025

Why do companies need to check asset classification during the pandemic?
The pandemic changed the business environment. Companies must update asset types to follow IFRS 9 rules.
What’s the main challenge in ECL calculations during COVID-19?
There’s more credit risk and less certainty. Companies need to update ECL models with new data and more checks.
Should companies change their ECL models now?
Companies should use overlays instead of changing the main model. Overlays help reflect new risks.
Why is sensitivity analysis important for ECL?
Sensitivity analysis shows how changes in variables affect ECL. This helps companies make better decisions.
Who can help with IFRS 9 assessment in UAE?
Mubarak Al Ketbi (MAK) Auditing helps companies with IFRS 9 models, reviews, and compliance checks.

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