Reviewed 12 September 2026. General guidance; confirm the requirements for your business with the relevant authority.
A shareholder list shows the immediate owners of a company. A beneficial ownership review goes further: it identifies the natural people who ultimately own or control it. Keeping that information current is an ongoing company administration task, particularly when the ownership chain includes other companies.
The framework and the ownership test
Cabinet Decision 109 of 2023 regulates beneficial owner procedures. Review its scope and exemptions for the entity, and use the relevant registrar’s instructions. Financial free zones have their own applicable frameworks; do not automatically apply a commercial free zone checklist to every entity.
The review considers direct or indirect ownership or voting rights of 25% or more, as well as control through other means. If the ownership test does not identify a person, the control and senior-management fallback rules must be considered in the proper sequence. Several people may need to be recorded. Do not list only the company that appears as the immediate shareholder and stop there.
Keep registers and supporting evidence together
Maintain the beneficial owner register, the partners or shareholders register and the required nominee information. A clear ownership chart should agree with incorporation documents, share transfers and the actual control arrangements. Record the basis on which each person is identified, rather than keeping only a name and passport copy.
A practical file includes current identity details, contact information, ownership or control evidence, the dates a person acquired or ceased that status and the records supplied to the registrar. Keep access restricted to people who need the information for company administration or an authorised disclosure.
Track the correct update deadline
The decision requires the beneficial owner register to be updated within 15 days of becoming aware of a change. It also addresses notifying the registrar of amendments within 15 days of the change. These are days, not a general allowance of 15 business days. Initial register and submission requirements use separate rules, including the decision’s 60-day provisions; follow the registrar’s incorporation process and any specific request.
Treat a proposed ownership change as a trigger for review before the transaction completes. Ask whether it changes voting rights, management control, nominee arrangements or the natural people at the end of the chain. Updating the trade licence alone may not complete every related disclosure.
An administration process that is easy to maintain
- Nominate a person responsible for the registers and authority correspondence.
- Maintain an ownership chart with dated evidence for each layer.
- Collect and check supporting identity documents securely.
- Review ownership and control when shares, directors or agreements change.
- Submit the required updates through the registrar’s accepted channel.
- Retain acknowledgements and calendar any follow-up requests.
Review the file before renewal and before a bank onboarding exercise. Banks may request beneficial ownership information for their own checks; that request does not replace the company’s registrar obligations.
Questions owners commonly ask
Is the person with the largest shareholding always the only UBO?
No. Several individuals can meet the relevant tests, and effective control may matter even where an individual’s shareholding is below the ownership threshold.
Are nominee arrangements ignored?
No. Identify the underlying arrangement and provide the required information. A nominee’s name alone does not necessarily explain ultimate ownership or control.
What if our records disagree?
Compare the source documents and obtain clarification before submitting inconsistent information. MNK can help organise the ownership records and the registrar’s checklist; complex control structures may need legal advice.
Official sources and further reading
- Cabinet Decision 109 of 2023, provided by SRTI Park
- Shams: beneficial ownership requirements
- SRTI Park: beneficial ownership guidance
Explore MNK’s related business service or request a consultation with your activity, jurisdiction and the support you need.