3 September 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. DIFC and ADGM operate separate beneficial-ownership frameworks. A Dubai free-zone company should confirm its zone's exact portal and process, but the substance (identifying and filing the 25% owners) is the same.
Exiloz Management & Tax Consultant · Dubai-based FTA-focused advisory · VAT, corporate tax & accounting
How free zones collect it
Same substance, different portals.
- Commercial free zones apply the CD 109 regime.
- Each has its own filing portal.
- Same 25% test and deadlines.
- Confirm your zone's exact process.
DIFC and ADGM
Financial free zones differ.
- DIFC runs its own UBO framework.
- ADGM runs its own UBO framework.
- Rules and portals differ from the mainland.
- Apply the correct regime for your entity.
Related guides
Frequently Asked Questions
For Dubai free-zone owners.
Do Dubai free-zone companies file UBO?
Yes. Commercial free zones apply the CD 109 regime, each through its own portal; DIFC and ADGM have 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 across the CD 109 regime.
How do DIFC and ADGM differ?
They operate their own beneficial-ownership frameworks, separate from the mainland/commercial free-zone rules.
Can Exiloz file in our free zone?
Yes. We handle UBO filing across Dubai's free-zone portals and the mainland.
File UBO in your free zone
Exiloz handles UBO filing across Dubai's free zones and the mainland.