ESR, ownership records and AML

Economic Substance reporting requirements were removed for financial years ending after 31 December 2022. Obligations for financial years ending on or before that date remain relevant. Do not include ESR notifications as a universal annual task for a new 2026 company. This statement is based on the ministry's explanation of Cabinet Decision 98/2024; the underlying amending decision was not independently retrieved.

Cabinet Decision 109/2023 covers legal persons licensed or registered in the UAE, including commercial free zones, with specified exclusions for wholly government-owned companies and subsidiaries, financial free zones and the defined Governmental Partner. Identify the ultimate natural person with at least 25% ownership or voting rights, or other qualifying control. If those tests identify nobody, the decision provides a senior-management fallback. Maintain ownership records and update relevant changes within the applicable 15-day period. Financial-free-zone exclusion from this decision does not mean those jurisdictions have no ownership-disclosure rules.

AML reporting duties depend on the activity and regulator. Cabinet Resolution 134/2025 includes real-estate brokers/agents conducting customer property purchases or sales; precious-metal/stone dealers handling cash transactions of AED 55,000 or more, including linked transactions; specified customer-transaction work by independent legal/accounting professionals; and specified company/trust services such as incorporation, director arrangements, registered addresses, trusteeship and nominee shareholding. It also covers commercial gaming at its AED 11,000 financial-transaction threshold and permits additional designated categories. Financial institutions and virtual-asset service providers have their own scope. In-scope businesses need risk assessment and proportionate controls. Do not label every consultancy or every new company a DNFBP.

For businesses supervised by the Ministry of Economy and Tourism, goAML registration uses a preliminary registration stage followed by system registration. Follow the appropriate supervisor's process; selecting the ministry is not universal for all regulated businesses.

Match these requirements to your entity, activity and authority. This guide does not establish an applicant-specific approval, complete cost or end-to-end timeline.