20 July 2026 · Dubai Free Zones
UBO Filing for Dubai Free-Zone Companies
Most Dubai commercial free zones apply the Cabinet Decision 109 beneficial-ownership regime, collecting UBO data through their own portals with the same 25% test, 60-day filing and 15-day update rules as the mainland. DIFC and ADGM operate separate beneficial-ownership frameworks under their own regulators, with different forms, filing systems and, in places, different timelines, so a company in either financial free zone should not assume the mainland process applies. A Dubai free-zone company — whether in JAFZA, DMCC, Dubai South, Dubai Internet City or any other commercial zone — should confirm its zone's exact portal and submission process, but the substance of the exercise — identifying the 25% owners and filing them on time — is the same wherever the licence sits.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
How free zones collect it
Each commercial free zone in Dubai operates its own licensing system and, in turn, its own portal or submission channel for UBO data, but the underlying rule they are all applying is the same Cabinet Decision No. 109 of 2023. That means the 25% ownership, voting and control test, the requirement to build all three statutory registers, and the 60-day and 15-day deadlines carry across every commercial zone without variation. What differs from zone to zone is purely administrative — which portal you log into, what the form looks like, and which department to contact if something needs correcting — not the substance of what has to be filed or when.
- Commercial free zones apply the Cabinet Decision 109 regime, not a zone-specific set of rules.
- Each zone has its own filing portal or submission channel administered by its own authority.
- The 25% test and the 60-day/15-day deadlines are identical across every commercial zone.
- Registration requirements can differ slightly in form even where the substance is the same.
- Always confirm your specific free zone's exact process before assuming a generic one applies.
DIFC and ADGM
DIFC and ADGM sit outside Cabinet Decision 109 entirely and instead run their own beneficial-ownership regulations under their respective independent regulators. The concept of a beneficial owner is broadly similar — a natural person exercising significant ownership or control — but the forms, the filing platform, and in places the specific deadlines differ from the mainland and commercial free-zone regime, so treating a DIFC or ADGM filing as interchangeable with a Cabinet Decision 109 filing is a mistake that can leave a company technically non-compliant in either direction. A company that operates across both a commercial free zone and DIFC or ADGM, for instance through a group structure, needs to run two separate compliance tracks, not one.
- DIFC runs its own UBO framework under the Dubai Financial Services Authority.
- ADGM runs its own UBO framework under its own registrar and regulator.
- Rules, forms and portals differ from the Cabinet Decision 109 mainland/commercial free-zone regime.
- A group with entities in both a commercial free zone and DIFC/ADGM needs two compliance tracks.
- Apply the correct regime for each entity individually — do not assume one filing covers a group.
What tends to differ across free zones
While the substance is uniform, the practical experience of filing varies. Larger, longer-established free zones such as JAFZA and DMCC tend to have UBO submission built into their main licensing portal alongside renewals and amendments, so the filing sits inside a process companies already use. Newer or smaller zones sometimes route UBO submissions through a separate form or a direct request from the compliance department, which is easy to miss if a company is only watching its main portal for reminders. In every case, the safest approach is to confirm the exact channel directly with the free-zone authority rather than assuming it mirrors what a sister company in a different zone experienced.
- Established zones often build UBO filing into the existing licensing portal.
- Smaller or newer zones may use a separate form or direct compliance-department request.
- A reminder from one free zone should never be assumed to also cover another zone.
- Confirm the exact channel and contact directly with each free-zone authority you hold a licence in.
Filing across every Dubai zone from one place
For groups and individuals holding licences across more than one Dubai free zone, or across a free zone and the mainland, we run UBO compliance as a single coordinated exercise rather than separate, disconnected filings. That means one structure chart, one set of identified UBOs, and one tracked calendar of deadlines, translated into whatever form and portal each specific free zone or the mainland authority requires — including DIFC and ADGM where they apply. This avoids the common failure mode where one entity in a group is filed correctly and current while a related entity in a different zone quietly falls out of compliance because nobody was tracking it separately.
- One coordinated structure chart and UBO list used across every licence in the group.
- Deadlines tracked per entity and per zone, so nothing falls through the gap between them.
- Correct handling of DIFC and ADGM alongside commercial free-zone and mainland filings.
- A single point of contact for UBO compliance across a multi-zone group structure.
Related guides
Frequently Asked Questions
For Dubai free-zone owners — the questions that come up most for companies licensed outside the mainland.
Do Dubai free-zone companies file UBO?
Yes. Commercial free zones apply the Cabinet Decision 109 regime, each through its own portal or submission channel; DIFC and ADGM are the two exceptions and run their own separate rules.
Is the 25% test the same in free zones?
Yes. The 25% ownership/control test and the 60-day/15-day deadlines apply identically across the Cabinet Decision 109 regime, whichever commercial free zone the licence sits in.
How do DIFC and ADGM differ?
They operate their own beneficial-ownership frameworks under their own regulators, with different forms and filing platforms from the mainland and commercial free-zone rules, so a DIFC or ADGM entity should never assume the Cabinet Decision 109 process applies to it.
What if my group has entities in more than one zone?
Each entity's filing obligation is separate. A group with licences across a commercial free zone and DIFC or ADGM, for example, needs two distinct compliance tracks run in parallel, not a single filing assumed to cover both.
Does every free-zone portal work the same way?
Not exactly. The underlying rule is identical, but the submission channel, form and department can differ from zone to zone, so it is worth confirming the exact process with each specific free-zone authority rather than assuming it matches another zone.
Who do I contact if I am unsure which regime applies?
Your free-zone authority can confirm whether your entity falls under Cabinet Decision 109 or a separate regime, but for a definitive answer across a multi-zone structure, a compliance advisor who works across all the regimes is generally faster and less error-prone.
Can Exiloz file in our free zone?
Yes. We handle UBO filing across Dubai's commercial free-zone portals, DIFC, ADGM and the mainland, coordinated through a single structure chart and tracked deadline calendar wherever your entities are licensed.
File UBO in your free zone
Exiloz handles UBO filing across Dubai's commercial free zones, DIFC, ADGM and the mainland, coordinated from a single structure chart so nothing falls out of compliance.