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Post-formation compliance in the UAE
Four obligations start the day your licence is issued: the beneficial owner register, Emiratisation, the Wage Protection System and employee health insurance. None are optional.
- Beneficial owner register due within 60 days
- Wage protection set up before your first payroll
- Emiratisation checked on 30 June and 31 December
What is due for you
Which of these describes your company right now?
Create the Beneficial Owner Register within 60 days of registration, along with the Partners or Shareholders Register. Name a UAE-resident person authorised to disclose the data.
- Deadline
- 60 days from registration
- If missed
- Notice with 30 days to fix, then AED 50,000
- Third violation
- AED 100,000
A general guide based on federal rules; DIFC and ADGM run their own beneficial owner regimes, and filing routes differ by Registrar.
What a UAE company owes after the licence.
Post-formation compliance is the set of legal duties that begin the day a UAE company is licensed. The main four are the Ultimate Beneficial Owner (UBO) register, Emiratisation, the Wage Protection System (WPS) and employee health insurance.
Every legal person licensed or registered in the UAE needs this, including companies in non-financial Freezones. My Eloah Business Hub takes you through each obligation at handover and helps you put the deadlines in your diary.
- UBO register
- Within 60 days of registration
- Changes
- Update within 15 days
- Emiratisation
- Measured 30 June and 31 December
- Wages
- Paid within 15 days of the due date
Obligation, deadline and penalty.
These are the federal rules. Beneficial owner penalties come from Cabinet Decree 132 of 2023 and run in three strikes: a notice, a fine, then double the fine.
| Obligation | Deadline | Penalty |
|---|---|---|
| Beneficial Owner Register | Create within 60 days of registration | Notice with 30 days to fix, then AED 50,000, then AED 100,000 |
| Partners or Shareholders Register | Create it with the beneficial owner register | AED 50,000 on the second violation, AED 100,000 on the third |
| Update the shareholder register | Within 15 days of a change | Notice with 30 days to fix, then AED 15,000, then AED 30,000 |
| UAE-resident authorised discloser | Name one when you create the registers | Notice with 30 days to fix, then AED 10,000, then AED 20,000 |
| Data requested by the Registrar | Within 14 days | Notice with 30 days to fix, then AED 15,000, then AED 30,000 |
| Emiratisation target | 30 June and 31 December each year | AED 96,000 per Emirati not appointed for 2024; AED 108,000 for 2025 |
| Wages through the WPS | At least 85% of wages due, within the first 15 days of the due date | Services suspended on day 17; repeat within 6 months is AED 1,000 per worker, capped at AED 20,000 |
| Employee health insurance | Before a residence permit is issued or renewed | The residence permit cannot be issued or renewed without it |
On a third beneficial owner violation the Registrar may suspend the trade licence and close the premises until the fine is paid and the fault corrected. Corporate tax, VAT and goAML have their own deadlines; ask us on WhatsApp which apply to you.
Your target depends on headcount.
The Ministry of Human Resources and Emiratisation (MOHRE) measures on 30 June and 31 December and collects contributions the following January. The amount is per unfilled position and rises each year.
2% growth a year
Grow the number of Emiratis in skilled positions by 2% a year, building to 10% by 2026.
At least one UAE national
Applies in 14 sectors, including real estate, professional and technical activities, administrative and support services, construction, and wholesale and retail.
Not currently targeted
No target applies today. Check your headcount at every licence renewal, because the duty starts when you reach 20 employees in a listed sector.
What happens when wages are late.
You are compliant if you transfer at least 85% of total wages due within the set timeframe. After the due date, the ministry escalates in fixed steps.
First notice
MOHRE sends a notice and alert to the establishment.
Second notice
A second notice and alert follows if wages are still unpaid.
Services suspended
MOHRE suspends services to the establishment, which blocks new work permits.
Fine per worker
A repeat violation within 6 months costs AED 1,000 per worker, capped at AED 20,000.
UBO fines, strike by strike.
A beneficial owner is the natural person who owns or controls 25% or more of the capital or voting rights, directly or through a chain, or who has ultimate effective control by other means.
| Violation | First | Second | Third |
|---|---|---|---|
| Fails to create and keep the UBO register | Notice, 30 days | AED 50,000 | AED 100,000 |
| Fails to create the partners or shareholders register | None stated | AED 50,000 | AED 100,000 |
| Fails to provide manager or nominee director data | Notice, 30 days | AED 40,000 | AED 80,000 |
| Fails to keep partner or shareholder data properly | Notice, 30 days | AED 30,000 | AED 60,000 |
| Fails to record UBO ownership details properly | Notice, 15 days | AED 20,000 | AED 40,000 |
| Fails to update the UBO register | Notice, 15 days | AED 15,000 | AED 30,000 |
| Fails to update the shareholder register within 15 days | Notice, 30 days | AED 15,000 | AED 30,000 |
| Fails to name a UAE-resident authorised discloser | Notice, 30 days | AED 10,000 | AED 20,000 |
| Fails to hand registers to the liquidator within 30 days | Notice, 30 days | AED 5,000 | AED 10,000 |
Part of a day counts as a full day and part of a month as a full month. A liquidator who fails to keep records for 5 years after dissolution faces AED 100,000.
Your first-year checklist.
Tick these off after your licence is issued. The first two carry the earliest deadline.
Six steps to stay compliant.
Work through these in order once your licence is issued.
Start on WhatsApp →Confirm the ownership chain
Trace every corporate shareholder up to the natural persons behind it and confirm the chain in writing.
Create the registers
Create the Beneficial Owner Register and the Partners or Shareholders Register within 60 days of registration.
Name your discloser
Name a UAE-resident person who is authorised to disclose the register data.
Set up payroll and insurance
Buy employee health insurance before any visa application and have the WPS live before the first payroll run.
Check Emiratisation
Compare your headcount and sector with the targets and diarise 30 June and 31 December.
Keep it current
Update the registers within 15 days of any ownership change and diarise licence, establishment card and lease renewals.
Post-formation compliance, answered.
Ask anything else on WhatsApp and we will answer for your company.
What must a UAE company do after getting its trade licence?
Create a beneficial owner register within 60 days, set up the Wage Protection System before the first payroll, buy employee health insurance before any visa application and check Emiratisation targets. Corporate tax registration, VAT if over the threshold and renewals also belong on the list.
Who counts as an ultimate beneficial owner in the UAE?
The natural person who owns or controls 25% or more of the capital or voting rights, directly or through a chain of ownership, or who has ultimate effective control by any other means. If no one meets the test, senior management is named. A corporate shareholder is never the beneficial owner.
What is the deadline for the UBO register?
Within 60 days of registration. After that, update the shareholder register within 15 days of any change and answer Registrar data requests within 14 days.
What is the penalty for not keeping a UBO register?
A notice with 30 days to fix it, then AED 50,000 on the second violation and AED 100,000 on the third. On the third violation the Registrar may suspend the trade licence and close the premises until it is paid and corrected.
Do Freezone companies need a UBO register?
Yes. The rule covers every legal person licensed or registered in the UAE, including non-financial Freezones. DIFC and ADGM run their own regimes.
How much is the Emiratisation fine?
AED 96,000 for each Emirati not appointed against the 2024 target and AED 108,000 against the 2025 target. Circumventing the targets with fictitious Emiratisation carries fines of up to AED 500,000.
When is a company late paying wages under the WPS?
When wages are not paid within the first 15 days of the due date, unless the contract sets a shorter period. A company is compliant if it transfers at least 85% of total wages due on time.
Is employee health insurance mandatory in every emirate?
Yes, since 1 January 2025 it is mandatory in all seven emirates. The employer buys it, the basic package is AED 320 per year, and permits dated before 1 January 2025 are exempt until renewal.
Get your first-year deadlines in order
Message My Eloah Business Hub on WhatsApp and we will tell you which obligations apply to your company and when each is due.