In short
- Threshold: more than 25% in Cyprus, 25% or more in the UAE, 10% or more in the BVI.
- A change is reported within 45 days in Cyprus, 15 in the UAE and 30 in the BVI.
- Cyprus alone asks for a yearly confirmation, between 1 October and 31 December.
- Fines reach €5,000 in Cyprus, AED 100,000 in the UAE and $75,000 in the BVI.
In this guide
What a UBO register is and who counts as a beneficial owner
UBO stands for ultimate beneficial owner: the natural person who owns or controls a company in the end, directly or through other companies. A UBO register is the record of those people that a state keeps, so that tax offices, the police and banks can see who stands behind a company. The company has to find the person, keep the details current and file them.
All three laws apply the same order of tests. First comes ownership: a share of the capital or the votes that reaches the threshold. Then control by other means, such as the right to appoint or remove most of the directors. Where nobody passes either test, the company enters its senior manager.
A nominee changes nothing in this. The register of companies shows the nominee shareholder or director, and the UBO register shows the person the nominee acts for.
Cyprus, the UAE and the BVI: the three UBO registers side by side
| Point | Cyprus | UAE | BVI |
|---|---|---|---|
| Threshold | More than 25%: 25% plus one share | 25% or more of the capital or the votes | 10% or more of the shares or the votes |
| Who files | Companies, European companies and partnerships, through an officer | Every company on the mainland, in a commercial free zone or on an offshore registry | Every company and limited partnership, through its registered agent |
| Where | Registrar of Companies, in its online system for beneficial owners | The registrar that licensed the company | Registrar of Corporate Affairs, in the VIRRGIN system |
| New company | Within 90 days of incorporation | Within 60 days of the licence | Within 30 days of incorporation |
| A change | Within 45 days of learning of it | Within 15 days | Within 30 days of learning of it |
| Each year | Confirmation from 1 October to 31 December | No yearly confirmation | No yearly confirmation |
| Who can read it | Authorities, banks and other obliged entities, and people who prove a legitimate interest | Authorities. The data is confidential | Authorities and, from 1 April 2026, people who prove a legitimate interest |
| Fines | €100, then €50 a day, up to €5,000 | A warning, then AED 5,000 to 50,000, then AED 10,000 to 100,000 | $500 to $600 a month for a late filing, up to $75,000 for other breaches |
Cyprus UBO register: 90 days, 45 days and a confirmation each autumn
Companies under the Companies Law, European companies and partnerships file in the Cyprus register. Listed companies, overseas companies and business names are outside it. An officer or a partner of the entity files through the Registrar's online system. A service provider files only as an officer of the company, for example as its secretary.
A new company enters its owners within 90 days of incorporation. A change is filed within 45 days of the day the company learned of it. Every year, between 1 October and 31 December, the company confirms the entry online, once, even when nothing has changed. By law the Registrar writes to each company at least 30 days before a term for filing or confirming runs out.
A missed term costs €100 on the first day and €50 for each day after, up to €5,000. A confirmation due by 31 December 2026 and made on 20 January 2027 is 20 days late: €100 and 19 times €50, which is €1,050. The directors answer for the fine together with the company, unless they show due diligence. The Registrar can also strike the company off: see the guide to company strike-off in Cyprus.
Who may read the register changed on 20 March 2026. The authorities have full access. Banks and other obliged entities search it when they check a client, for €3.50 a company. Access for the general public has been suspended since an EU Court judgment of 22 November 2022.
Law 25(I)/2026 replaced public access with access for a person who proves a legitimate interest in fighting money laundering. The law lets that person see the owner's name, month and year of birth, country of residence, nationality and the extent of the interest. Directive (EU) 2024/1640 presumes a legitimate interest for journalists and civil society organisations working against money laundering and for a person about to do business with the company. From 10 November 2026 it gives a register 12 working days to answer a request. The Registrar's pages offered no such search yet on 10 October 2026.
UBO registration in the UAE: three registers, 60 days to file and 15 days for a change
The rules are in Cabinet Decision No. 109 of 2023, which replaced Decision No. 58 of 2020 in November 2023. It covers every company licensed or registered in the UAE: on the mainland, in a commercial free zone or with an offshore registry. Companies wholly owned by the federal or a local government are exempt. The two financial free zones, ADGM and DIFC, apply regulations of their own, also at 25%.
A UAE company keeps three records: a register of beneficial owners, a register of partners or shareholders, and the details of any nominee board member. It files the first two with its registrar within 60 days of the licence. The registrar is the authority that licensed the company: on the mainland the economic department of the emirate, in a free zone the zone authority.
A change of owner or shareholder goes into the registers and to the registrar within 15 days. The registrar may ask for more information and allows 14 days for it. Each company also names a person resident in the UAE who is authorised to give the registrar its data. The Ministry of Economy and the registrars may not disclose the registers without the owner's written consent, except to the authorities and under international agreements.
Fines follow Cabinet Decision No. 132 of 2023 and rise with each repeat. The first violation brings a written warning and 15 or 30 days to correct it.
| Violation | Second time | Third time |
|---|---|---|
| No register of beneficial owners | AED 50,000 | AED 100,000 |
| Owner's details not recorded properly | AED 20,000 | AED 40,000 |
| Register not updated | AED 15,000 | AED 30,000 |
| Registers not filed with the registrar | AED 15,000 | AED 30,000 |
After a third violation the registrar may also suspend the licence until the fine is paid and the fault corrected. We keep the three registers of a UAE company and enter each change in time as part of PRO services in Dubai and the UAE.
BVI: the 10% threshold and access by legitimate interest from 1 April 2026
The BVI Business Companies (Amendment) Act, 2024 and its beneficial ownership regulations came into force on 2 January 2025. A beneficial owner is now a person with 10% or more of the shares or the votes, where the earlier secure search system worked at 25%. A shareholder with 15% who was outside the old rule is inside the new one. The Registrar of Corporate Affairs keeps the register in VIRRGIN, the regulator's online system.
Only the registered agent of the company can file, after checking the identity of each owner. A new company files within 30 days of incorporation and reports a change within 30 days of learning of it. Companies that existed before the law had until 1 January 2026, after the Registrar added six months to the first term. Listed companies do not file, and certain funds keep their data with a licensed person who can produce it within 24 hours.
A late first filing costs $500 for the first month, $550 for each of the next two and $600 for each of the three after that. That is $3,400 over six months, after which the company can be struck off. A change filed late costs $500 a month, up to $6,000. For other breaches the regulations set four tiers of penalty, with ceilings of $10,000, $25,000, $50,000 and $75,000.
The register is closed to the public. Competent authorities and law enforcement read it. From 1 April 2026 a person who proves a legitimate interest, for example in investigating money laundering, can apply online for $75 a company. The company is told through its registered agent and has 5 days to object. The applicant is shown only owners with 25% or more: name, month and year of birth, nationality and the nature of the interest.
Worked example: one group in all three registers
Three partners own a BVI company with 70%, 18% and 12%. The BVI company owns all of a Cyprus holding company, which owns all of a UAE free-zone company. Each partner holds the same share of every company in the chain.
| Partner | BVI | Cyprus | UAE |
|---|---|---|---|
| 70% | Declared | Declared | Declared |
| 18% | Declared: 10% or more | Not declared: under 25% | Not declared: under 25% |
| 12% | Declared: 10% or more | Not declared: under 25% | Not declared: under 25% |
On 1 March the first partner sells 10% to the second, who now holds 28% and passes the threshold in Cyprus and the UAE too. The UAE company updates its registers and its registrar by 16 March. The BVI agent files the new percentages by 31 March. The Cyprus company files by 15 April. A partner below the threshold is still declared where he or she controls the company by other means, for example through a shareholders' agreement.
How the same structure is taxed is in Cyprus vs UAE for a holding company.
How to find out who the beneficial owner of a company is
None of the three registers can be searched freely, so the route depends on who asks. A bank or another obliged entity asks the client for the structure and, in Cyprus, checks the register for €3.50. A person with a legitimate interest relies on the law of March 2026 in Cyprus and applies online, for $75, in the BVI. In the UAE the registers are confidential, and the company itself is the source.
What anyone can see is the Cyprus register of companies: directors and secretary free of charge, and the shareholders in the detailed search for €10.
How to read that register: Cyprus company register.
One calendar for three registers: how to keep them in step
A filing in one country counts for nothing in the others. A group with companies in all three keeps three clocks, and the 15 days of the UAE set the pace.
- Draw the structure once, with every company, every holder and every percentage, and have the owner sign it. Banks ask for the same chart when they open an account: Cyprus company bank account.
- Mark for each company its register, its threshold and its terms for a new entry and for a change.
- Give every agent, secretary and service provider one standing instruction: report any change in shares, votes or control on the day it happens.
- Put the Cyprus confirmation in the diary for October and make it before December.
- Keep the confirmation of each filing with the chart.
Where a nominee holds the shares or sits on the board of your Cyprus company, we file both sides. The nominee goes into the register of companies and you into the register of beneficial owners. The service and its documents are on our page about nominee services in Cyprus.
