What is the 25% threshold for identifying a beneficial owner in the UAE?
The 25 percent threshold is the starting point for identifying the beneficial owner of a company under the UAE AML framework. The Executive Regulations require regulated entities to identify the natural person who ultimately owns, individually or jointly, an actual controlling ownership interest or shares of 25 percent or more in a legal person.
The threshold is a first test, not the only one. Where there is doubt that the 25 percent owner is truly the beneficial owner, or where no natural person controls the entity through ownership, the regulated entity must instead identify the natural person who exercises control by legal or other means, whether directly or indirectly. If no such person can be found, the entity must identify the natural person holding a senior management position. This tiered approach ensures a real individual is always identified. The UAE also operates a beneficial owner register regime under Cabinet Resolution No. 109 of 2023 for companies to declare their beneficiaries.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 10 — the 25 percent ownership test and fallback measures.
· CBUAE Rulebook – Identification of Beneficial Owners — supervisory guidance on the ownership threshold.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.
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