Three registers, not one

The legal basis is Cabinet Decision No. 58 of 2020 on Regulating Beneficial Owner Procedures. It requires a UAE company to keep three separate registers: a Partners or Shareholders Register listing who legally holds the shares, a Real Beneficiary Register (the UBO register itself) recording each beneficial owner’s full name, nationality, date and place of birth, residential address, passport or ID number, and the date and basis on which they became a UBO, and a Register of Nominee Directors or Managers for anyone who holds a director or manager role on someone else’s instructions rather than in their own right.

The 25% ownership-or-voting-rights test is the starting point, not the only route to being named a UBO. If no single natural person holds 25% either directly or through a chain of ownership, the company has to look at control instead: whoever can appoint or remove a majority of the board, or who otherwise exercises effective control over the company’s decisions, is the UBO. If that still doesn’t identify anyone — genuinely diffuse ownership with no dominant controller — the company’s own senior manager is designated as the UBO by default, purely so that every company has a named natural person on file.

The initial filing is due within 60 days of the company’s trade licence being issued, which catches out new incorporations that treat it as a later administrative task rather than a launch-week requirement. After that, any change — a share transfer, a new director, a shift in who controls the company — has to be reflected within 15 days, not at the next renewal.

For a group with entities across the mainland and one or more free zones, VIVOS Corporate Services L.L.C. tracks which register each entity needs to update and within what deadline whenever ownership or management changes, so a share transfer in one jurisdiction doesn’t quietly leave another entity’s filing out of date.

The exemption list is short, and free zones aren’t automatically on it

Only three categories sit outside Cabinet Decision 58/2020 entirely: companies wholly owned, directly or indirectly, by the federal or a local government and their subsidiaries; and companies listed on a regulated stock exchange, along with their subsidiaries, which meet the disclosure requirement through the exchange’s own rules instead. Being registered in a free zone is not on that list. Most free zone companies still have to file, just through their own free zone authority’s registrar rather than a mainland Department of Economy portal. The two commonly cited as “exempt” — DIFC and ADGM — aren’t skipping beneficial ownership disclosure at all; they run their own separate beneficial ownership regulations under their own financial free zone laws, administered by their own registrars, instead of following the federal Cabinet Decision 58/2020 process.