20 July 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, so a company incorporated in either financial free zone follows a different process entirely. Most Dubai companies — whether on the mainland or in a commercial free zone such as JAFZA, DMCC or Dubai South — fall within the Cabinet Decision 109 regime and carry the same filing and registers obligation regardless of size, sector or number of shareholders.
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Covered entities
The starting assumption under Cabinet Decision No. 109 of 2023 is that you are in scope: every legal person licensed on the UAE mainland and every legal person licensed in a commercial free zone must comply, regardless of how small the company is or how simple its ownership looks. This covers LLCs, sole establishments with corporate shareholders, joint-stock companies and branches, and it applies from the moment a licence is issued, not only once the authority asks. Three registers must be built and kept current, and the underlying UBO data must be filed with the relevant licensing authority within the statutory timeframe.
- Mainland companies licensed by the Department of Economic Development or its equivalent.
- Commercial free-zone companies licensed by any UAE free-zone authority outside DIFC and ADGM.
- Sole establishments and joint-stock companies with corporate or multi-layer shareholders.
- Must keep all three statutory registers, not only the beneficial-owner register.
- Must file UBO data with the licensing authority, not merely hold it internally.
Who is outside
A small number of entities sit outside the Cabinet Decision 109 regime entirely. Companies wholly owned by the federal government or a local government are exempt, on the reasoning that state ownership is already transparent by other means. DIFC and ADGM, the UAE's two common-law financial free zones, run their own beneficial-ownership frameworks under their respective regulators, with different forms, portals and timelines, so a company registered in either zone should not assume the mainland rules, or the mainland deadlines, apply to it. Getting the regime wrong — filing under Cabinet Decision 109 when DIFC rules apply, or vice versa — can mean the filing does not count at all.
- Companies wholly owned by the federal government or an emirate-level government.
- DIFC-registered entities, which follow the DIFC's own beneficial-ownership regulations.
- ADGM-registered entities, which follow the ADGM's own beneficial-ownership regulations.
- Confirm which regime applies before filing — a filing under the wrong regime does not satisfy either.
- Branches of foreign companies should confirm their own filing status separately from the parent.
What "must file" actually requires
Filing is not a single form. Companies in scope must build and maintain three separate registers: a Register of Beneficial Owners recording each UBO's identity and the basis of their control, a Register of Partners or Shareholders recording every holder of shares regardless of stake size, and, where the company uses nominee arrangements, a Register of Nominee Directors disclosing the real person behind any nominee. All three sit at the registered office and must be produced on request, and the UBO data from the first register is what gets filed with the licensing authority. A company that files the UBO data but never builds the underlying registers has only completed half the obligation.
- Register of Beneficial Owners — identity, ownership basis and date for every UBO.
- Register of Partners/Shareholders — every shareholder, not only those crossing 25%.
- Register of Nominee Directors — required only where nominee arrangements exist.
- All three registers must be kept at the registered office and produced on request.
Confirming your obligation and filing correctly
The most common mistake we see is a company assuming it is exempt simply because it is small, family-owned, or trades through a free zone — none of those factors removes the obligation under Cabinet Decision 109. We start every engagement by confirming which regime actually applies: mainland, commercial free zone, DIFC or ADGM, since the process, portal and deadlines differ across all four. From there we build the three registers, identify every UBO including indirect holdings through foreign structures, and file the UBO data with the correct licensing authority so nothing is filed twice, filed late, or filed under the wrong regime.
- Confirm which of the four regimes — mainland, commercial free zone, DIFC or ADGM — applies to you.
- Build all three statutory registers, not just the beneficial-owner filing.
- Identify UBOs through multi-layer or offshore structures before filing.
- File with the correct licensing authority and diarise the update deadlines.
Related guides
Frequently Asked Questions
For confirming your obligation — the questions company owners ask most often when working out whether, and how, they must file.
Do free-zone companies file UBO?
Commercial free-zone companies do, under the same Cabinet Decision 109 regime as mainland companies. DIFC and ADGM are the two exceptions — they run their own separate beneficial-ownership rules with their own portals and deadlines.
Are government companies exempt?
Yes. Companies wholly owned by the federal government or a local government sit outside the Cabinet Decision 109 regime entirely. A company that is only partly government-owned does not qualify for this carve-out and must file normally.
What registers must I keep?
A Register of Beneficial Owners, a Register of Partners/Shareholders, and, where nominee arrangements exist, a Register of Nominee Directors. All three are separate obligations, and building the registers is distinct from filing the UBO data itself.
Is a small or single-owner company still in scope?
Yes. There is no size or shareholder-count exemption under Cabinet Decision 109. A single-owner LLC has exactly the same filing and register obligations as a multi-shareholder joint-stock company.
What if my company is registered in DIFC or ADGM?
You follow that free zone's own beneficial-ownership framework instead of Cabinet Decision 109. The identity concept is similar, but the forms, portal and deadlines are different, so confirm the correct regime before filing anything.
Does a branch of a foreign company need to file?
Generally yes, if it holds a UAE mainland or commercial free-zone licence — the branch's own filing obligation should be confirmed separately from whatever the foreign parent does in its home jurisdiction.
Can Exiloz confirm if we must file?
Yes. We confirm which beneficial-ownership regime applies to your company, build the three statutory registers if they do not already exist, and handle the filing with the correct licensing authority.
Do you have to file?
Exiloz confirms whether your company must file UBO data, identifies which of the four regimes applies, and builds every register the law requires.