Does your company need to maintain a register of UBOs and nominee directors?

The United Arab Emirates (UAE) recently issued Cabinet Resolution No. 58 of 2020 on the Regulation of the Procedures of the Real Beneficiary (the Resolution), which came into effect on 28 August 2020 and replaced Cabinet Resolution No. 34 of 2020 issued earlier this year.

Over the years, certain free zones in Dubai have already implemented requirements about information to be furnished regarding an Ultimate Beneficial Owner (UBO) during the registration process. However, many of the licensing authorities in the UAE previously did not require such information from the companies.

The new Resolution aims to introduce the requirement for a beneficial ownership register in the UAE mainland and unify the minimum disclosure requirements for corporate entities incorporated in the UAE mainland and in the non-financial free zones.

The Resolution addresses the disclosure requirements at the corporate registration stage, as well as the requirement to subsequently maintain a shareholder register, a register of beneficial owners and a register of nominee directors. Companies are now required to file the beneficial ownership information with the relevant Registrar by 27 October 2020.

Key points:

  • All companies in the UAE, both mainland and free zone companies, with the exception of companies incorporated in the financial free zones (Abu Dhabi Global Market (ADGM) and Dubai International Financial Centre (DIFC) and companies owned by the Federal Government and their subsidiaries), must now keep at their office premises:
    • A shareholder register
    • A register of beneficial owners
    • A register of nominee directors.
  • Companies must file such information relating to the shareholders and beneficial owners with the relevant registrar and licensing authorities responsible for supervising the register of trade names for the various types of establishments registered in the UAE (the Registrar) by 27 October 2020.
  • Companies must notify the Registrar of any change or amendment to the information provided within 15 days of such change or amendment. Also, the companies need to designate an Individual who can be contacted by the regulators regarding the matters enacted in the resolution.
  • Companies which are listed on well-regulated stock exchanges or companies which are owned by these listed companies may rely on the disclosures made to the relevant stock exchange rather than making independent inquiries as to the beneficial ownership.

The resolution has been adopted in furtherance of Federal Law no. 20 of 2018, on Anti- Money Laundering, which placed an obligation on corporate entities to disclose any individual ownership (whether beneficial or actual) in an entity which owns twenty five percent (25%) or more of the company, to the relevant regulator.

To understand more about how the above changes can affect your business, please reach out to us on

+971 58 542 3160