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Ownership records change when shares move, directors change or a holding company is added. Keep the registers next to your entity data so a 15-day update deadline is not missed.
A UAE group can hold its beneficial owner, shareholder and nominee registers in the ERP next to entity data, with dates, documents and reminders, so changes are updated within the 15-day deadline. UBO rules sit in Cabinet Decision No. 109 of 2023. Economic substance reports are no longer required for financial years ending after 31 December 2022; confirm specifics with your advisor.
Group finance teams already maintain entity lists, trade licence dates and bank signatories, often across several spreadsheets. A UAE economic substance and UBO records ERP setup brings the beneficial owner register, the shareholder register and nominee details into the same place as entity data, with dates, documents and reminders.
The current UBO rules are in Cabinet Decision No. 109 of 2023 regulating beneficial owner procedures, which applies to legal persons licensed or registered in the UAE, including commercial free zones. Companies wholly owned by federal or local government, financial free zones and governmental partners are exempt. DIFC and ADGM, as financial free zones, run their own beneficial ownership rules.
Economic Substance is a different story. The Ministry of Finance announced that, following Cabinet Decision No. 98 of 2024, economic substance notifications and reports are no longer required for financial years ending after 31 December 2022. Obligations for earlier years remain. For groups with intercompany flows, see also our transfer pricing ERP guide.
Drawn from Cabinet Decision No. 109 of 2023 and Ministry of Finance announcements. This is general information, not legal advice, and registrars may add their own procedures, so confirm the steps with your licensing authority or corporate lawyer.
A natural person who owns or controls 25% or more of the capital or voting rights, directly or through a chain of ownership, or who controls the company by other means, such as appointing or dismissing most directors. If no one qualifies, the person in the most senior management role is treated as the beneficial owner.
Each legal person keeps a Beneficial Owners' Register and a Register of Partners or Shareholders, and records nominee board members. Data is submitted to the Registrar within 60 days of the decision taking effect or of licensing, and on later events such as renewal.
Changes to the registers must be recorded within 15 days of the company becoming aware of them, and nominee board members notify changes within 15 days. Additional data requested by the Registrar is due within 14 days.
On dissolution or liquidation, the liquidator delivers the registers to the Registrar within 30 days of appointment and keeps the records for at least five years.
The Ministry of Finance states that economic substance notifications and reports are no longer required for financial years ending after 31 December 2022. Companies still handle obligations for earlier years, answer requests from authorities or the FTA, and pay penalties imposed for those years. Companies with non-calendar year-ends should confirm which periods are covered.
General information, not tax or legal advice. Rules change; confirm current FTA, MOHRE and Ministry of Finance guidance with your advisor.
These items turn scattered ownership data into maintained registers. Most can sit in an ERP's entity or company records with simple custom objects.
Most missed deadlines happen because the share transfer is handled by lawyers and finance learns about it later. A defined workflow closes that gap.
One shared database: every step updates stock, finance and reports in real time.
None of these platforms submits data to registrars. Each can hold structured registers and reminders. Confirm features against your edition.
| Zoho | Odoo | ERPNext | Dynamics 365 | |
|---|---|---|---|---|
| Entity master | Zoho Creator app or CRM custom module | Company records with custom fields | Company doctype with custom fields | Company records or Dataverse tables |
| Shareholder and UBO registers | Zoho Creator custom app | Custom model or studio fields | Custom doctypes | Dataverse tables or extension |
| Documents | Zoho WorkDrive links | Documents app | Attachments on records | SharePoint integration |
| Reminders | Workflow rules and tasks | Activities and automated actions | Notifications and assignments | Power Automate flows |
| Best fit | Groups on Zoho One | Groups running all entities in one Odoo database | Teams wanting custom doctypes | Groups on the Microsoft stack |
Restrict access to ownership registers. They contain personal data of owners and directors.
Ranges for a group with up to a few dozen entities. Complex chains through foreign holding companies take longer.
Durations are typical ranges; your plan is agreed after discovery.
We gather licences, shareholder lists, UBO declarations and nominee details from your corporate secretary or lawyers.
Entity, shareholder, beneficial owner and nominee records are designed with access rules.
Custom records, reminders and document links are built, and current data is loaded and checked.
Finance and legal staff agree who updates what, and practise the ownership change workflow.
Ownership records connect to tax, AML and multi-entity accounting.
On-site workshops in Dubai, Abu Dhabi and Sharjah, and remote or on-site delivery across the Northern Emirates and free zones.
Official sources and references
Facts on this page were checked against these sources in October 2026. Rules change, so confirm current requirements before acting.
Still have a question? Our consultants are happy to help.
Ask an ExpertThe Ministry of Finance says notifications and reports are no longer required for financial years ending after 31 December 2022. Earlier years still have to be dealt with, including any authority requests or penalties. If your financial year does not follow the calendar, confirm the position with your advisor.
Cabinet Decision No. 109 of 2023 covers companies in commercial free zones. Financial free zones such as DIFC and ADGM are exempt from it and apply their own beneficial ownership rules, so check with the relevant registrar.
The decision looks at control by other means, such as appointing most directors. If no natural person can be identified that way, the person holding the most senior management position is treated as the beneficial owner. Record the reasoning with the register.
The company itself. In practice, assign a named owner in finance or legal, and give the corporate secretary or law firm a simple route to notify changes so the 15-day window is met.
No. Filing goes through the licensing authority's own channels. The ERP keeps the authoritative copy, the change history and the documents, so filing is quick and consistent.
Send us your entity list and we will propose a register structure that fits your current ERP.
Dubai, United Arab Emirates
