Beneficial owner (real beneficiary) rules for UAE companies

Under Cabinet Resolution No. 109 of 2023, every company licensed in the UAE, including those in commercial free zones, must know and record its beneficial owners. A beneficial owner is the natural person who owns or controls 25% or more of the capital or voting rights, directly or through other companies, or who controls the company by other means, such as appointing most of the directors. If no such person can be found, the senior manager is recorded instead. The company keeps two registers, one for beneficial owners and one for partners or shareholders. It must submit both to its registrar within 60 days of being licensed. In Dubai the registrar for mainland businesses is DET. For each owner the register holds the full name, nationality, date and place of birth, address and passport or ID details, plus the basis and date of ownership. Any change must be reported within 15 days. The company must also name one person who lives in the UAE as its contact for this data. Companies wholly owned by the government and those in the financial free zones are exempt. Penalties are set by Cabinet Resolution No. 132 of 2023. A first violation brings a written notice to correct within 15 to 30 days. After that, fines range from AED 5,000 to AED 100,000, and at the third violation the licence can be suspended and the premises closed. DET usually reminds businesses by SMS during licence transactions.