20 July 2026 · How To
How to File & Maintain the Register
Build the beneficial owner register with each UBO's identity details and the basis and date of their beneficial ownership, then file the data with your licensing authority within 60 days of licence issue or amendment. Any change — a share transfer, a new owner, a change of control, or a new nominee arrangement — must be recorded and updated within 15 days, which is a far tighter window than the initial filing and the one most companies miss. Alongside the beneficial-owner register you also build the partner/shareholder register and, where relevant, the nominee-director register, and all three should be backed by documentary evidence — passports, share certificates and structure charts — so the filing can be verified at any time, not only reconstructed when the authority asks.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
Build and file
Start by identifying every UBO using the 25% ownership, voting and control test, then record their full identity details — name, nationality, passport or Emirates ID number, date of birth and residential address — together with the exact basis on which they qualify and the date that basis took effect. This becomes the Register of Beneficial Owners. The UBO data from that register, not the register document itself, is what gets submitted to the licensing authority, and the statutory clock for the initial filing is 60 days from licence issue or from any amendment that changes the UBO position.
- Identify every UBO first, applying the 25% shareholding, voting and control test.
- Record identity details in full — name, nationality, ID number, date of birth, address.
- Note the exact basis and date on which each person became a beneficial owner.
- File the UBO data with the licensing authority, not just the internal register document.
- Complete the initial filing within 60 days of licence issue or amendment.
Keep it updated
The register is not a one-time filing; it is a living document that has to track the company for as long as it holds a licence. Any change to who owns, controls or manages the company — a share transfer, a new shareholder, a restructuring, a change of nominee, or even a change in control that leaves the share register unchanged — starts a fresh 15-day clock. Because that window is so much shorter than the 60-day initial filing, the practical fix is to build UBO review into the same checklist as every corporate event, rather than treating it as a separate compliance task someone remembers to do later.
- Update any change to beneficial ownership or control within 15 days of it happening.
- Trigger a review on share transfers, capital restructurings and new shareholder agreements.
- Trigger a review on control changes even where the share register itself is unchanged.
- Update the nominee-director register whenever a nominee arrangement starts or ends.
- Retain the register at the registered office, ready to produce on request.
Documents that back up the register
A register entry is only as strong as the evidence behind it. Each UBO's file should hold a certified passport or Emirates ID copy, proof of the ownership or control basis — a share certificate, a shareholders' agreement clause, or board minutes recording a control arrangement — and, for indirect holdings, a structure chart showing every layer between the individual and the UAE entity. This is the same evidence a bank will ask for during account-opening or periodic KYC review, so building it once, to a standard that satisfies both the licensing authority and the bank, saves having to assemble it twice under time pressure.
- Certified passport or Emirates ID copy for every declared UBO.
- Documentary proof of the ownership or control basis, not just a stated percentage.
- A structure chart for any indirect holding through a holding company or trust.
- Keep the evidence file aligned with what your bank requests for KYC purposes.
Filing and maintaining the register for you
We handle the register as an ongoing service rather than a one-off filing: identifying UBOs at the outset, building all three statutory registers with full supporting evidence, filing the initial UBO data within the 60-day window, and then tracking your corporate calendar so any share transfer, new investor or control change triggers an update within the 15-day deadline automatically rather than being caught late. Where a company has missed a deadline before we start, we also handle the remediation filing and correspondence with the licensing authority to bring the register back into good standing.
- Identify UBOs and build all three registers with supporting evidence from day one.
- File the initial UBO data within the 60-day statutory window.
- Monitor corporate events so 15-day updates never slip past deadline.
- Remediate and re-file where a previous filing was missed or incomplete.
Related guides
Frequently Asked Questions
For running the register correctly — the practical questions that come up once a company actually starts building and filing its UBO data.
When is the initial UBO filing due?
Within 60 days of licence issue, or within 60 days of any amendment that changes who your beneficial owners are. The clock starts from the event, not from when you get around to it.
How fast must I report a change?
Within 15 days of any change to the beneficial owners, their stake, or the basis of their control. This window is far shorter than the initial 60-day filing, which is exactly why it is the deadline most companies miss.
What goes in the register?
Each UBO's full identity details, plus the exact basis and date on which they became a beneficial owner. The partner/shareholder register and, where relevant, the nominee-director register are built and maintained alongside it.
What evidence should back up each register entry?
A certified passport or Emirates ID copy, documentary proof of the ownership or control basis, and, for indirect holders, a structure chart showing every layer of the holding structure down to the UAE company.
What happens if I file the register but never update it?
The register falls out of date the first time anything changes, and an outdated register is treated the same as a missed filing if the licensing authority or a bank checks it against current reality.
Do minor changes, like a change of address, need updating too?
Yes. Any change to the recorded identity details of a UBO, not only a change of ownership stake, should be reflected in the register within the same 15-day window.
Can Exiloz maintain it for us?
Yes. We build and keep your UBO register current and filed, monitor your corporate calendar for triggering events, and handle both the initial filing and every subsequent 15-day update.
Keep your register current
Exiloz builds and maintains your UBO register — identity details, evidence and all three statutory registers — and files every update within the 15-day deadline.