RAK ICC Beneficial Ownership (UBO) Declaration

If you run a RAK ICC company or act as its registered agent, the RAK ICC beneficial ownership declaration is a core compliance obligation. The RAK ICC Beneficial Ownership Regulations 2019 require every registered agent to supply RAK International Corporate Centre with details of each company's ultimate beneficial owners (UBOs) and to keep that information current. Reassuringly, the data is stored by the Companies Registry and is not shown on any public domain — but it must be accurate and complete. This guide explains who qualifies as a beneficial owner, how the 25% rule and nominee arrangements work, and how to complete the form, with the rigour our UAE company incorporation and AML compliance teams apply on every file.

What is the RAK ICC beneficial ownership declaration?

The RAK ICC beneficial ownership declaration is the form through which a company's ultimate beneficial owners are recorded with RAK ICC. It exists because the RAK ICC Beneficial Ownership Regulations 2019 place a positive duty on registered agents to identify each company's UBOs, submit their details, and keep the record up to date as ownership or control changes.

Two features stand out. First, confidentiality: the regulations state that the information is stored by the Companies Registry at RAK ICC and will not be shown on any public domain — so this is a regulatory filing, not a public register. Second, ongoing responsibility: it is not a one-off. The obligation is to keep the information current, which means filing updates whenever the beneficial-ownership picture changes. The declaration is signed by the shareholder (or the nominee) on the basis that the particulars are true.

Who is a beneficial owner under the RAK ICC regulations?

A beneficial owner is defined as an individual who ultimately owns or controls the entity, or on whose behalf a transaction or activity takes place. For a company, the regulations set out six routes to beneficial-owner status — and meeting any one of them is enough. Crucially, a beneficial owner is always a natural person; you must look through companies and other layers to the human being at the top.

What is the 25% ownership and voting threshold?

The 25% threshold is the headline test. Any individual who owns or controls 25% or more of a company's shares or voting rights is a beneficial owner — whether that holding is direct or indirect. The "or voting rights" wording matters: a person can cross the threshold through voting control even if their shareholding is smaller, and someone can be a UBO through control routes without holding 25% at all.

A short worked example shows why indirect holdings catch people out. Suppose an individual owns 100% of Holdco, and Holdco owns 30% of your RAK ICC company. That individual indirectly controls 30% of your company and is a beneficial owner who must be declared — even though their name never appears on your company's share register. The same beneficial-ownership discipline underpins clean company formation and, where relevant, a UAE Corporate Tax analysis of who ultimately controls the business.

How are nominee arrangements treated?

Nominee arrangements are handled by looking through the nominee to the real owner. The regulations are explicit: if shares or rights are held by a nominee, the beneficial owner is the person for whom the nominee is acting. And if the nominee is acting for a legal entity, the beneficial owner is the person who exercises ultimate control over that entity.

On the form, this is where Parts C and D come in. Part C captures the nominee's details — whether a nominee arrangement exists, the type (shareholder or director), the nature of the relationship, and whether the nominee is a corporate service provider. Part D then captures the nominator — the person behind the nominee, who is typically the true beneficial owner. If a shareholder or director is acting as a nominee, both parts must be completed. Declaring the nominee but omitting the nominator defeats the entire purpose of the exercise.

How are trusts and foundations handled?

Where a RAK ICC entity is owned through a trust or foundation, the beneficial-owner net widens. The regulations state that a beneficial owner includes the settlor, the trustees, the beneficiaries, and any individual who has control over the trust or foundation. That can mean several individuals are declarable for a single structure.

The practical implication is that trust-owned RAK ICC companies almost always have more than one UBO to declare. Because each beneficial owner files a separate declaration, a structure with a settlor, two trustees and two beneficiaries could require multiple filings. Identifying every controlling individual up front — rather than defaulting to the trustee alone — is essential to getting the filing right.

What information and documents must you provide?

For each beneficial owner, the form (Part B) requires a full identity and contact dataset. Gathering it before you start makes the declaration straightforward rather than a chase for missing details. You need: full name; date of birth; place and country of birth; nationality and any other nationalities held; residential address; home-country address; passport number, country of issuance, issuance and expiry dates (with a copy of the passport); the date the person became a beneficial owner; the UBO's percentage of shares; the grounds on which they are a beneficial owner; and direct contact number and email.

Two document points are easy to miss. A copy of each UBO's passport is mandatory, and a UAE visa copy is required where applicable. Collecting these at the outset — the same standard applied in any robust customer due diligence process — avoids the declaration stalling for want of an attachment.

How is the form structured, and which parts are mandatory?

The declaration is organised into five parts, and which parts you complete depends on the ownership structure. The table below maps each part and when it applies.

Remember the golden rule: if two or more UBOs must be declared, each one submits a separate declaration. A single form does not cover multiple beneficial owners.

How does this fit the wider UAE UBO and AML framework?

RAK ICC entities follow the RAK ICC Beneficial Ownership Regulations 2019, but those sit within the broader UAE approach to beneficial ownership and the country's AML/CFT regime. The federal framework for real-beneficiary procedures (Cabinet Decision No. 58 of 2020) applies across many UAE entities, and the same 25% concept and look-through logic run through it. For registered agents, accurate UBO records are also the foundation of AML compliance — customer due diligence, sanctions screening and ongoing monitoring all depend on knowing who ultimately owns and controls a client.

In other words, the UBO declaration is not a standalone box-tick. It feeds directly into the wider compliance posture that a RAK ICC agent must maintain: goAML registration, CDD files, risk assessment and monitoring. Keeping UBO information current is what keeps the rest of that framework reliable. Where a structure creates a UAE substance or residency question, the same clarity supports a tax residency certificate application.

What are the penalties and ongoing obligations?

The declaration is signed on the footing that the particulars are true to the best of the signatory's knowledge and belief, and the signatory expressly acknowledges the penalties applicable under the regulations in force for providing false information. Just as important, the form states that providing this information does not exonerate the company from its own duties and responsibilities under the applicable regulations — the filing is a floor, not a substitute for wider compliance.

The ongoing obligations are to keep the UBO information up to date and to file a separate, accurate declaration for each beneficial owner. Getting this right is inexpensive; getting it wrong — through inaccurate percentages, an undisclosed nominator, or a stale record — risks penalties and remediation. The table below sets out the recurring obligations, their basis and the consequence of getting them wrong.

How to complete the RAK ICC UBO declaration

Completing the declaration cleanly is a repeatable, five-step process. Work through it in order and each part of the form is supported by evidence.

1. Identify every beneficial owner — apply the six criteria, starting with the 25% shares-or-voting threshold, plus board control, significant influence and ultimate control.
2. Look through nominees and entity layers — trace nominees and corporate layers to the ultimate individual, and capture trust or foundation parties (settlor, trustees, beneficiaries).
3. Gather each UBO's data and documents — identity details, all nationalities, passport copy and UAE visa where applicable.
4. Complete the correct parts — Parts A, B and C for every filing, Part D for nominee arrangements, Parts B and E for indirect owners, with one declaration per UBO.
5. Sign, submit and keep updated — sign the declaration, submit it through the registered agent to the RAK ICC Registry, and update the record whenever ownership or control changes.

This is the exact workflow our team runs as part of a RAK ICC company incorporation engagement, so the UBO declaration, the identity documents and the AML records all line up.

What are the common mistakes on the UBO declaration?

Most rejected or later-corrected declarations fail for the same reasons: they stop at the share register, ignore indirect and nominee ownership, or leave the record to go stale. The comparison below contrasts a defensible filing with the red-flag version.