3 September 2026 · Who Files
Which Companies Must File
Legal persons licensed on the UAE mainland or in commercial free zones must maintain beneficial owner, partner/shareholder and nominee-director registers and file UBO data with the licensing authority. Companies wholly owned by the federal or local government are outside the regime, and DIFC and ADGM run their own beneficial-ownership rules. Most Dubai companies fall within the Cabinet Decision 109 regime.
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Covered entities
The default is that you must file.
- Mainland licensed companies.
- Commercial free-zone companies.
- Must keep the three registers.
- Must file UBO data with the authority.
Who is outside
A few sit outside the regime.
- Wholly government-owned companies.
- DIFC entities (own regime).
- ADGM entities (own regime).
- Check which regime applies to you.
Related guides
Frequently Asked Questions
For confirming your obligation.
Do free-zone companies file UBO?
Commercial free-zone companies do under the Cabinet Decision 109 regime; DIFC and ADGM run their own rules.
Are government companies exempt?
Companies wholly owned by the federal or local government are outside the regime.
What registers must I keep?
A beneficial owner register, a partner/shareholder register, and a nominee-director register where relevant.
Can Exiloz confirm if we must file?
Yes. We confirm which beneficial-ownership regime applies to your company.
Do you have to file?
Exiloz confirms whether your company must file UBO data and which regime applies.